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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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Defenders of Wildlife, 504 U.S. 555, 562 (1992). The Appellant must provide concrete <br /> evidence—not mere conjecture—that the Board has the authority to redress. <br /> III. ARGUMENT <br /> A. Appellant's Arguments Are Speculative and Fail the "Injury in Fact" Test <br /> Appellant asserts that the construction of a porch and internal staircase will increase the <br /> use of the subject property to the point of causing traffic congestion on Oe Oe Street. However, <br /> Appellant has offered no evidence to support this claim. Under Lujan, an injury must be "actual <br /> or imminent, not conjectural or hypothetical." Lujan, 504 U.S. at 560 (citation and internal <br /> punctuation omitted). A speculative increase in traffic from a residential porch does not <br /> constitute an "injury in fact—an invasion of a legally protected interest which is (a) concrete and <br /> particularized, and (b) actual or imminent, not conjectural or hypothetical." Id. <br /> B. The Alleged Injury is a Generalized Grievance Common to the Public <br /> Even if the Board accepted the traffic allegations as true, they fail Rule 8-2 because <br /> traffic on a public street is a shared community concern. Appellant has not shown how her <br /> interest in public road flow is "clearly distinguishable from that of the general public." BOA <br /> Rule 8-2. Standing exists to protect specific personal stakes, not to provide a forum for <br /> neighborhood-wide grievances. See Life of the Land a Land Use Comm'n of State of Hawai`i, <br /> 63 Haw. 166, 172, 623 P.2d 431, 438 (1981) ("[T]he crucial inquiry in [determining standing] is <br /> whether the plaintiff has alleged such a personal stake in the outcome of the controversy' as to <br /> warrant his invocation of. . . (the court's)jurisdiction and to justify exercise of the court's <br /> remedial powers on his behalf.") (citation and internal punctuation omitted). <br /> C. The Board Lacks Authority to Redress Grievances outside SMA Criteria <br /> 3 <br />
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