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2026-05-08 COH-Planning Director Amended Motion to Dismiss for Lack of Standing (PL-BOA-2025-000119).pdf
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2026-05-08 COH-Planning Director Amended Motion to Dismiss for Lack of Standing (PL-BOA-2025-000119).pdf
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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 />tragic 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 Conran '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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