The Hawaii Supreme Court dismissed Samuel Carter's final appeal attempt in his lawsuit against the Honolulu Police Department and several officers, marking the end of his legal challenge in state court. The court issued its order on Jan. 20, 2026, rejecting Carter's motion for reconsideration of a December decision that denied his petition for certiorari review.
Carter had filed what he styled as a "Notice of Appeal" on Jan. 15, 2026, seeking to challenge the Supreme Court's Dec. 30, 2025 order that rejected his applications for writ of certiorari. However, the high court construed Carter's filing as a motion for reconsideration rather than a proper appeal and dismissed it under Hawaii Rules of Appellate Procedure Rule 40.1(h).
The rule explicitly states that "neither acceptance nor rejection of an application for a writ of certiorari shall be subject to a motion for reconsideration in the supreme court" and that "the rejection of an application for certiorari shall be final." This procedural barrier effectively closes the door on Carter's state court challenge.
The case, designated SCWC-XX-XXXXXXX, involved Carter as the petitioner and plaintiff-appellant against multiple defendants including the Honolulu Police Department, the City and County of Honolulu, and the Chief of Police. Five individual officers were also named as defendants: Winston Hale, Justin Gonsalves, Jordan Rego, Kenric Pai, and Florand Blanco.
The Supreme Court order was issued by a panel of five justices: Acting Chief Justice Sabrina McKenna, Justice Todd Eddins, and Justice Lisa Ginoza, along with Circuit Judge James Ashford and Circuit Judge Dyan Medeiros. Judge Ashford served "in place of Devens, J., recused," while Judge Medeiros was "assigned by reason of vacancy," indicating the court operated with substitute members due to recusal and vacancy issues.
The case had progressed through Hawaii's court system, starting in the circuit court (Case No. 1CCV-XX-XXXXXXX) before moving to the Intermediate Court of Appeals (CAAP-XX-XXXXXXX). Carter's petition for certiorari represented his attempt to bring the case before the state's highest court for final review.
Certiorari petitions are discretionary appeals that allow state supreme courts to select which cases merit their attention. Courts typically grant certiorari only for cases involving important questions of law, conflicts between lower courts, or matters of significant public interest. The Supreme Court's rejection of Carter's petition indicates the justices determined the case did not meet these criteria.
The procedural nature of the dismissal means the court did not address the underlying merits of Carter's claims against the police department and officers. The original lawsuit's specific allegations and the lower courts' rulings remain sealed within the case record, which uses redacted case numbers consistent with court privacy practices.
Carter's unsuccessful reconsideration attempt highlights the finality of certiorari decisions in Hawaii's judicial system. State supreme courts maintain strict rules about reconsidering discretionary review decisions to prevent repetitive litigation and ensure judicial efficiency. The Hawaii Rules of Appellate Procedure make clear that once a certiorari petition is rejected, that decision cannot be challenged through additional motions.
The dismissal order was filed electronically on Jan. 20, 2026, at 9:51 a.m., as indicated in the court's electronic filing system. This represents the final action in Carter's state court proceedings, though potential federal court options may remain depending on the nature of his original claims.
Lawsuits against police departments and individual officers often involve complex questions of civil rights, municipal liability, and qualified immunity. While the specific nature of Carter's claims remains unclear from the available court documents, such cases typically arise from allegations of excessive force, constitutional violations, or other misconduct.
The case's progression through all levels of Hawaii's state court system demonstrates the comprehensive nature of Carter's legal challenge. From the initial circuit court filing through intermediate appeals court review and final certiorari petition, Carter exhausted the available state court remedies.
The involvement of multiple individual officers as defendants alongside institutional parties reflects common litigation strategies in police misconduct cases. Plaintiffs often name both the employing agency and individual officers to maximize potential recovery and ensure all responsible parties are held accountable.
With the Supreme Court's dismissal now final, Carter's state court litigation has concluded. The case serves as an example of how Hawaii's appellate rules protect the finality of discretionary review decisions and prevent indefinite relitigation of settled matters.
