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2025-08-18 3CCV-25-0000025 Findings of Fact, Conclusions of Law, and Order Vacating and Remanding to BOA (PL-BOA-2024-000104)
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2025-08-18 3CCV-25-0000025 Findings of Fact, Conclusions of Law, and Order Vacating and Remanding to BOA (PL-BOA-2024-000104)
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applies to appeals from contested case hearings. BOA Rule 3-22 ("Any party may <br /> obtain judicial review of the Board's final decision with the Circuit Court pursuant to <br /> Section 91-14 of the Hawaii Revised Statutes[.]"); BOA Rule 8-17 ("Any party to an <br /> appeal proceeding may obtain judicial review by the Circuit Court of the proceeding <br /> pursuant to Section 91- 14, Hawaii Revised Statutes, as amended."). <br /> 15. The proceeding at the BOA was a contested case and any decision and <br /> order disposing of the matter was required to comply with HRS § 91-12. <br /> Requirements of HRS § 91-12 <br /> 16. HRS § 91-12 mandates that: <br /> Every decision and order adverse to a party to the proceeding, rendered <br /> by an agency in a contested case, shall be in writing or stated in the <br /> record and shall be accompanied by separate findings of fact and <br /> conclusions of law. If any party to the proceeding has filed proposed <br /> findings of fact, the agency shall incorporate in its decision a ruling upon <br /> each proposed finding so presented. <br /> 17. HRS § 91-12 requires that the Board's findings be reasonably clear. In re <br /> Terminal Transp., Inc., 54 Haw. 134, 139, 504 P.2d 1214, 1217 (1972). <br /> 18. A separate ruling on each proposed finding of fact is not indispensable. <br /> Mitchell v. BWK Joint Venture, 57 Haw. 535, 560 P.2d 1292 (1977); In re Terminal <br /> Transportation, Inc., 54 Haw. 134, 504 P.2d 1214 (1972); Freitas v. Pacific Contractors <br /> Co., 1 Haw.App. 77, 613 P.2d 927 (1980). <br /> 19. However, "[t]he requirement of findings is far from a technicality and is a <br /> matter of substance. It has been said that it is a fundamental of fair play that an <br /> administrative judgment express a reasoned conclusion. A conclusion requires <br /> evidence to support it and findings of appropriate definiteness to express it. . .." <br /> 23 <br />
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