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De La Cruz v. State

2026-09-01

Summary

Holding. The court granted summary judgment in favor of the State, holding that Hawaii Revised Statutes § 12-41(b) does not violate equal protection principles and that De La Cruz did not receive the minimum votes required to advance to the general election ballot.

Blessings De La Cruz, an unsuccessful nonpartisan candidate in a primary election for District 44 State Representative, challenged her exclusion from the general election ballot. She contested the constitutionality of Hawaii Revised Statutes § 12-41(b), which sets different advancement thresholds for partisan and nonpartisan candidates. De La Cruz received 41 votes, falling short of the 10 percent requirement (292 votes) and the alternative standard of matching the lowest vote total of a nominated partisan candidate (900 votes).

The court rejected De La Cruz's equal protection arguments, applying precedent from Hustace v. Doi that had previously upheld the statute's differential treatment. The court found that the different pathways for partisan and nonpartisan candidates serve Hawaii's legitimate interest in maintaining an effective direct primary system and do not violate equal protection guarantees. The court also determined that the statutory scheme does not violate Article II, Section 4 of the Hawaii Constitution, which addresses voting secrecy and party preference.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether different advancement thresholds for partisan versus nonpartisan candidates violate equal protection
  • Whether blank and overvotes are included in calculating the 10 percent threshold for nonpartisan candidates
  • Whether Article II, Section 4 of the Hawaii Constitution requires equal treatment of partisan and nonpartisan candidates

Procedural posture

The State filed a motion to dismiss or for summary judgment following De La Cruz's filing of an election contest complaint challenging her exclusion from the general election ballot.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

Electronically Filed

Supreme Court

SCEC-XX-XXXXXXX

01-SEP-2026

08:03 AM

Dkt. 12 FFCL

SCEC-XX-XXXXXXX

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI

BLESSINGS DE LA CRUZ,

Plaintiff,

vs.

STATE OF HAWAIʻI, OFFICE OF ELECTIONS;

SCOTT T. NAGO, Chief Election Officer, State of Hawaiʻi,

Defendants.

ORIGINAL PROCEEDING

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND JUDGMENT

(By: Devens, C.J., McKenna, Eddins, and Ginoza, JJ.,

and Intermediate Court of Appeals Judge Hiraoka,

assigned by reason of vacancy)

On August 24, 2026, Plaintiff Blessings De La Cruz

(Plaintiff) filed an election contest complaint (Complaint). On

August 28, 2022, Defendants State of Hawaiʻi Office of Elections

and Scott T. Nago, Chief Election Officer, State of Hawaiʻi

(collectively, the State) filed a motion to dismiss Plaintiff’s

Complaint or, in the alternative, for summary judgment.

Upon consideration of the Complaint, the motion to dismiss

or for summary judgment, the documents attached and submitted in support of the Complaint and motion, and having heard this

matter without oral argument, we enter the following findings of

fact, conclusions of law, and judgment.

FINDINGS OF FACT

1. On August 8, 2026, a primary election was held for

District 44 State Representative, State of Hawaiʻi (District 44).

2. The final results for the August 8, 2026 primary

election for District 44 were:

Non-Partisan Votes

DE LA CRUZ, Blessings 41

Blank Votes: 13

Over Votes: 0

Republican Votes

WEAVER, Charla (Kahealani) 900

Blank Votes: 85

Over Votes: 0

Democratic Votes

KILA, DARIUS K. 1760

KAHIKINA, Michael P. 228

Blank Votes: 75

Over Votes: 1

3. The total votes cast for the candidates in the primary

election for District 44 was 2,929, and ten percent of that

total is 292 votes.

4. On August 24, 2026, Plaintiff, the unsuccessful

nonpartisan candidate in the primary election for District 44,

filed the Complaint contesting the decision that “she will not

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advance to the 2026 General Election ballot” pursuant to Hawaiʻi

Revised Statutes (HRS) § 12-41(b) (2009).

5. Plaintiff’s Complaint sets forth five counts for

relief. Briefly summarized, Plaintiff’s Complaint, including

these five counts, assert that the different treatment between

partisan and nonpartisan candidates in HRS § 12-41 is

unconstitutional on equal protection grounds. Because HRS § 12-41(b) is unconstitutional, Plaintiff asserts that this results

in an error, mistake, or irregularity that could have caused a

difference in the primary election results for District 44

because Plaintiff ran unopposed as a nonpartisan candidate.

Plaintiff thus seeks a declaration in this primary election

contest that HRS § 12-41(b) is unconstitutional and, based on

this declaration, asks this court to determine which candidates

advance to the general election for District 44.

6. Plaintiff also asserts that Article II, Section 4 of

the Hawaiʻi Constitution should be considered as “constitutional

support” based on the manner that nonpartisan candidates appear

on the ballot with partisan candidates.

7. We construe all of Plaintiff’s requests for relief in

the Complaint as being connected to Plaintiff’s equal protection

argument.

8. On August 28, 2026, the State filed a motion to

dismiss the Complaint or for summary judgment.

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CONCLUSIONS OF LAW

1. Hawaiʻi Revised Statutes (HRS) § 11-172 (Supp. 2021)

states that an election complaint “shall set forth any cause or

causes, such as but not limited to, provable fraud, overages, or

underages, that could cause a difference in the election

results.” See Dicks v. Office of Elections, 155 Hawai‘i 102,

106, 557 P.3d 831, 835 (2024) (“To state a claim under HRS § 11-172, the election contest complaint, at the bare minimum, must

plead that the conduct in question by the election official

could cause a difference in the election results.”).

2. HRS § 11-172’s requirements for an election complaint

are viewed in context with the relief allowed in a primary

election contest, which is that this court’s judgment “shall

decide what candidate was nominated or elected.” HRS § 11-173.5(b) (2009).

3. The plaintiff bears the burden of showing actual

information of mistakes or errors sufficient to change the

result, and “[i]n the absence of facts showing that

irregularities exceed the reported margin between the

candidates, the complaint is legally insufficient.” Akaka v.

Yoshina, 84 Hawaiʻi 383, 388, 935 P.2d 98, 103 (1997). “An

election contest cannot be based upon mere belief or indefinite

information.” Id.

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4. For a primary election contest, the “court shall hear

the contest in a summary manner” and “[t]he judgment shall

decide what candidate was nominated or elected.” HRS § 11-173.5(b).

5. When reviewing a request to dismiss a complaint, the

court’s review “is based on the contents of the complaint, the

allegations of which [the court] accept[s] as true and

construe[s] in the light most favorable to the plaintiff.

Dismissal is improper unless it appears beyond doubt that the

plaintiff can prove no set of facts in support of his claim

which would entitle him to relief.” Casumpang v. ILWU, Local

142, 94 Hawaiʻi 330, 337, 13 P.3d 1235, 1242 (2000) (quotation

marks and citation omitted).

6. The court’s consideration of matters outside the

pleadings converts a motion to dismiss into one for summary

judgment. Foytik v. Chandler, 88 Hawaiʻi 307, 313, 966 P.2d 619,

625 (1998).

7. Because we consider the total votes cast for the

candidates in the August 8, 2026 primary election for District

44, application of the summary judgment standard is appropriate.

See id.

8. Summary judgment is appropriate where there is no

genuine issue as to any material fact and the moving party is

entitled to judgment as a matter of law. Estate of Doe v. Paul

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Revere Ins. Group, 86 Hawaiʻi 262, 269-70, 948 P.2d 1103, 1110-11 (1997).

9. A fact is material if proof of that fact would have

the effect of establishing or refuting an essential element of a

cause of action asserted by one of the parties. Winfrey v. GGP

Ala Moana LLC, 130 Hawaiʻi 262, 271, 308 P.3d 891, 900 (2013).

10. On a motion for summary judgment, this court must view

the evidence in the light most favorable to the nonmoving party.

Id.

11. However, this “court is permitted to draw only those

inferences of which the evidence is reasonably susceptible and

it may not resort to speculation.” Id. (quoting Pioneer Mill

Co. v. Dow, 90 Hawaiʻi 289, 295, 978 P.2d 727, 733 (1999)).

12. HRS § 12-41(b) (2009) provides:

(b) Any nonpartisan candidate receiving at least ten

per cent of the total votes cast for the office for which

the person is a candidate at the primary or special

primary, or a vote equal to the lowest vote received by the

partisan candidate who was nominated in the primary or

special primary, shall also be a candidate at the following

election; provided that when more nonpartisan candidates

qualify for nomination than there are offices to be voted

for at the general or special general election, there shall

be certified as candidates for the following election those

receiving the highest number of votes, but not more

candidates than are to be elected.

(Emphases added.)

13. When viewed in context with the second HRS § 12-41(b)

alternative that allows a nonpartisan candidate to advance to

the general election, blank and overvotes are not included in

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the calculation of the “ten per cent of the total votes cast for

the office for which the person is a candidate” at the primary

election. See HRS § 12-41(b) (“[O]r a vote equal to the lowest

vote received by the partisan candidate who was nominated in the

primary or special primary[.]”); Jijun Yin v. Aguiar, 146 Hawaiʻi

254, 264, 463 P.3d 911, 921 (2020) (“In construing each

individual part of a statute, the court must consider the

statute as a whole to ensure that all parts produce a sensible

and harmonious whole.”).

14. Plaintiff received 41 votes, which is less than ten

percent of the total votes cast for District 44 (292), and is

not equal to the lowest number of votes received by a partisan

candidate who was nominated (Charla (Kahealani) Weaver, 900

total votes).

15. The constitutional arguments in Plaintiff’s Complaint

lack merit. Plaintiff asserts that HRS § 12-41’s alternative

routes for partisan and nonpartisan candidates to advance to the

general election are unfair and denies her equal protection

under the law. This court previously considered and rejected

this argument in Hustace v. Doi, 60 Haw. 282, 588 P.2d 915

(1978).

16. In Hustace, we recognized that HRS § 12-41 mandates a

minimum number of votes needed for a nonpartisan candidate to

advance to the general election, and this minimum number of

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votes can never be more than the lowest number of votes that a

partisan candidate received in order to advance to the general

election. Id. at 290, 588 P.2d at 920. This means that a

nonpartisan candidate will advance to the general election if

the total number of votes cast for the nonpartisan candidate is

equal to or greater than the least-popular partisan candidate

that will also advance to the general election. See HRS § 12-41(b) (“[O]r a vote equal to the lowest vote received by the

partisan candidate who was nominated in the primary or special

primary, shall also be a candidate at the following

election[.]”).

17. And as recognized in Hustace, 60 Haw. at 292, 588 P.2d

at 922, HRS § 12-41(b)’s alternative requirement of a

nonpartisan candidate receiving at least ten per cent of the

total votes cast is similarly required for a partisan

candidate’s party to appear on a primary election ballot. See

HRS § 11-61(b)(2)(A) (2009).

18. In other words, a nonpartisan candidate is not

required to satisfy HRS § 11-61 in order to be placed on the

ballot for the primary election. See HRS § 12-21 (2009) (“The

names of the candidates of each party qualifying under section

11-61 or 11-62 and of nonpartisan candidates may be printed on

separate ballots, or on a single ballot.”). But HRS § 11-61

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applies to partisan candidates who want to be placed on the same

ballot. See id.

19. Recognizing the foregoing, this court held that the

appellant was not deprived of equal protection under the law.

Hustace, 60 Haw. at 293, 588 P.2d at 922.

20. In holding as such, this court also considered

Hawaiʻi’s interest in the different routes that partisan and

nonpartisan candidates take to the general election pursuant to

HRS § 12-41. For example, this court recognized: “The purpose

of providing and protecting an effective direct primary system

is clearly a vital state objective, in pursuit of which a state

may require a nonpartisan candidate to demonstrate substantial

public support as an alternative to being nominated in one of

the direct party primaries.” Id. at 290-91, 588 P.2d at 921

(citing Storer v. Brown, 415 U.S. 724, 733 (1974)).

21. We apply Hustace here and conclude that HRS § 12-41

did not deny Plaintiff equal protection under Article I, Section

5 of the Hawaiʻi Constitution and the Fourteenth Amendment to the

United States Constitution.

22. Accordingly, HRS § 12-41’s different treatment of

partisan and nonpartisan candidates does not constitute an

error, mistake, or irregularity that could have caused a

difference in the election results. See HRS § 11-172.

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23. Article II, Section 4 of the Hawaiʻi Constitution

states in its entirety:

The legislature shall provide for the

registration of voters and for absentee voting and

shall prescribe the method of voting at all

elections. Secrecy of voting shall be preserved;

provided that no person shall be required to declare

a party preference or nonpartisanship as a condition

of voting in any primary or special primary election.

Secrecy of voting and choice of political party

affiliation or nonpartisanship shall be preserved.

24. Article II, Section 4 of the Hawaiʻi Constitution does

not require election officials to set aside the requirements of

HRS § 12-41(b) and allow Plaintiff to appear on the general

election ballot as a nonpartisan candidate.

25. Also, this court recently said that the prohibition on

declaring a party preference in Article II, Section 4 of the

Hawaiʻi Constitution was meant to change elections in Hawaiʻi

from a closed primary system to an open primary system. Dicks,

155 Hawai‘i at 107, 557 P.3d at 836. As such, Article II,

Section 4 of the Hawaiʻi Constitution does not support

Plaintiff’s argument that nonpartisan candidates’ eligibility

for the general election should be treated in the same manner as

partisan candidates under HRS § 12-41.

26. Based on the above, Plaintiff’s Complaint fails to

establish any viable claim to relief under HRS § 11-172.

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27. The complaint also fails to establish any conduct by

election officials that could cause a difference in the election

results. See Dicks, 155 Hawaiʻi at 106, 557 P.3d at 835.

28. We conclude that Plaintiff did not receive the minimum

number of votes required under HRS § 12–41(b) to advance to the

November 3, 2026 general election.

29. Accordingly, based on the above conclusions of law and

there being no genuine issue of material fact in Plaintiff’s

election contest, we find and conclude in favor of the State as

a matter of law.

30. Also, to the extent not already addressed above or in

the Judgment below, any remaining claims for relief in

Plaintiff’s Complaint are denied.

JUDGMENT

Based upon the foregoing findings of fact and conclusions

of law, judgment is entered in favor of the State and against

Plaintiff. Darius K. Kila and Charla (Kahealani) Weaver shall

be placed on the ballot for the general election for District 44

State Representative, State of Hawaiʻi. Plaintiff shall not be

placed on the general election ballot for District 44.

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The clerk of the supreme court shall forthwith serve a

certified copy of this judgment on the chief election officer in

accordance with HRS § 11-173.5(b).

DATED: Honolulu, Hawai‘i, September 1, 2026.

/s/ Vladimir P. Devens

/s/ Sabrina S. McKenna

/s/ Todd W. Eddins

/s/ Lisa M. Ginoza

/s/ Keith K. Hiraoka

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