Hawaii Supreme Court
Ralston v. Board of Land and Natural Resources
August 12, 2026
Summary
The court held that Resorttrust Hawaii, LLC is liable under the private attorney general doctrine for all reasonable attorney fees Ralston incurred in the certiorari proceeding, including fees incurred in seeking fees. It approved $9,139.13, inclusive of general excise tax, because the requested hours and hourly rate were reasonable, and remanded for the Intermediate Court of Appeals to determine the reasonable fees attributable to the earlier appellate proceedings. The court also concluded that Resorttrust’s active opposition to Ralston’s contested-case-hearing request and fee claims supported imposing liability on it.