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Quilausing v. Department of Public Safety, State of Hawaii

Citation: Not availableDocket: SCPW-12-0000015

Court: Hawaii Supreme Court; January 24, 2012; Hawaii; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

Petitioner Kyle Quilausing sought a writ of mandamus against the Department of Public Safety, State of Hawai'i, claiming that his minimum and maximum term sentences were not properly adjusted according to a circuit court order from February 23, 2010. The Supreme Court of Hawai'i reviewed the petition and determined that Quilausing failed to provide evidence supporting his claim that the Department had not complied with the court's order. Additionally, he did not demonstrate a clear and indisputable right to relief. The court emphasized that mandamus relief is only granted when the individual's claim is clear and certain, the official's duty is unambiguous and ministerial, and there are no alternative remedies available. Consequently, the court ordered the clerk to process the petition without a filing fee but denied the petition for mandamus relief. The order was signed by Chief Justice Mark E. Recktenwald and Justices Nakayama, Acoba, Duffy, and McKenna on January 25, 2012.

Legal Issues Addressed

Burden of Proof in Mandamus Petitions

Application: Petitioner Kyle Quilausing failed to meet the burden of proof required to obtain mandamus relief as he did not provide evidence supporting his claim nor demonstrate a clear and indisputable right to relief.

Reasoning: The Supreme Court of Hawai'i reviewed the petition and determined that Quilausing failed to provide evidence supporting his claim that the Department had not complied with the court's order. Additionally, he did not demonstrate a clear and indisputable right to relief.

Mandamus Relief Criteria

Application: The court reiterated that mandamus relief is only appropriate when the individual's claim is clear and certain, the duty of the official is unambiguous and purely ministerial, and there are no alternative remedies available.

Reasoning: The court emphasized that mandamus relief is only granted when the individual's claim is clear and certain, the official's duty is unambiguous and ministerial, and there are no alternative remedies available.

Processing of Petitions Without Filing Fees

Application: The court allowed the petition to be processed without a filing fee, demonstrating the court's discretion in waiving fees under specific circumstances.

Reasoning: Consequently, the court ordered the clerk to process the petition without a filing fee but denied the petition for mandamus relief.