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2026-06-19 Motion to Dismiss (PL-BOA-2026-000133 ROHR).pdf
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2026-06-19 Motion to Dismiss (PL-BOA-2026-000133 ROHR).pdf
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6/25/2026 11:12:59 AM
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Document Date
6/19/2026
Permit Number
PL-BOA-2026-000133
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2026-06-19 Motion to Dismiss (PL-BOA-2026-000133 ROHR).pdf
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3. That they are or will be adversely affected by the decision. <br />This rule is consistent with the policies underlying standing requirements including: to <br />ensure that the body does not exceed its authority; to prevent the body from being flooded with <br />cases based on generalized grievances; to ensure efficiency and prevent the waste of <br />governmental resources; and to limit legal disputes to those based in real -world facts involving a <br />direct injury caused by the defendant or appellee which can be redressed by the body to which <br />the dispute is presented. <br />The Hawai'i Supreme Court has established a three-part standing test, which echoes BOA <br />Rule 8-2: <br />1. Has the plaintiff suffered an actual or threatened injury; <br />2. Is the injury traceable to the defendant's actions; and <br />3. Would a favorable decision likely provide relief for plaintiff's injury. <br />See Sierra Club a Dept of Transportation, 115 Haw. 299, 319, 167 P.3d 292, 312 (2007). <br />Where, as here, a party challenges the government's regulation of a third party (the <br />Landowner and the Filming Company), the burden to establish standing is "substantially more <br />difficult" to meet. Lujan a Defenders of Wildlife, 504 U.S. 555, 562 (1992). <br />Under Lujan, an injury must be "actual or imminent, not conjectural or hypothetical." <br />Lujan, 504 U.S. at 560 (citation and internal punctuation omitted). The Appellant must allege <br />concrete evidence that this Board has the authority to redress. While an adjudicative body must <br />take all the factual allegations in the pleadings as true, it is not bound to accept as true a legal <br />conclusion couched as a factual allegation. Ashcroft a Igbal, 556 U.S. 662, 678-79, 129 S. Ct. <br />1937, 1949-50, 173 L. Ed. 2d 868 (2009). <br />3 <br />
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