Hawaii Supreme Court

Oahu Plumbing and Sheet Metal, Ltd., a Hawaii Corporation, Plaintiff-Appellee v. Kona Construction, Inc., a Hawaii…

February 8, 197960 Haw. 372

Summary

The Hawaii Supreme Court affirmed the lower court’s denial of a motion to set aside a default judgment, holding that, except for narrow statutory exceptions, a corporation may be represented in court only by a licensed attorney and that the constitutional due‑process and equal‑protection arguments raised by the corporate officer are without merit.

Holding

  • Whether a corporation may be represented in court by a non‑attorney officer.. A corporation may be represented in court only by a licensed attorney, subject to limited statutory exceptions.
  • Whether the constitutional due‑process and equal‑protection arguments against the attorney‑representation rule are valid.. The constitutional arguments are without merit; the rule does not violate due process or equal protection.

Docket NO. 6823

Cited authorities

  • Rule 55(b)(l)(1972)
  • Rule 4(d)(3)(1972)
  • Rule 55(c)
  • Rule 60(b) of the Hawaii Rules of Civil Procedure
  • Rule 55
  • Rule 60(b)
  • Rule 55(c)
  • Rule 60(b)

Cited by