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2026-05-08 COH-Planning Director Motion to Dismiss for Lack of Standing (PL-BOA-2025-000119)
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2026-05-08 COH-Planning Director Motion to Dismiss for Lack of Standing (PL-BOA-2025-000119)
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5/12/2026 12:16:15 PM
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requirements for this Board are set forth in the Board ofAppeals Rules ofPractice and <br /> Procedure ("BOA Rules") Rule 8-2. <br /> Pursuant to BOA Rule 8-2, an appellant must demonstrate a specific, direct injury in fact <br /> that is distinct from the general public. BOA Rules 8-2. This rule is consistent with the policies <br /> underlying standing requirements including: to ensure that the body does not exceed its <br /> authority; to prevent the body from being flooded with cases based on generalized grievances; to <br /> ensure efficiency and prevent the waste of governmental resources; and to limit legal disputes to <br /> those based in real-world facts involving a direct injury caused by the defendant or appellee <br /> which can be redressed by the body to which the dispute is presented. <br /> Appellant has failed to meet this burden, relying instead on speculative traffic concerns <br /> and generalized grievances that fall outside the scope of Special Management Area ("SMA") <br /> criteria. <br /> II. LEGAL STANDARD FOR STANDING <br /> Standing is a procedural threshold that must be satisfied before the Board may consider <br /> the merits of any case. See Public Access Shoreline Hawaii by Rothstein a Hawai`i Cnty. <br /> Planning Comm'n by Fujimoto, 79 Hawai`i 425, 431, 903 P.2d 1246, 1252 (1995) (noting <br /> "claimant had to have standing to appeal" in order for court to have jurisdiction to decide issues <br /> presented). To establish standing under BOA Rule 8-2, an appellant must show: <br /> 1. An interest in the subject matter that is directly and immediately affected; <br /> 2. An injury that is clearly distinguishable from that of the general public; and <br /> 3. That they are or will be adversely affected by the decision. <br /> Where, as here, a party challenges the government's regulation of a third party (Mr. <br /> Standke), the burden to establish standing is "substantially more difficult" to meet. Lujan u <br /> 2 <br />
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