D.R. v. T.R.

Hilo, Hawaii family law husband and wife with out layers in a divorce action.



D.R. filed for divorce from T.R. on October 27, 2022. A divorce decree was entered on December 13, 2022. According to the transcript of a June 1, 2023 hearing, D.R. filed a number of post-decree motions: "request for modification, motion to seal, motion to dismiss [T.R.J's motion, motion for post-decree relief, and also [D.R.]'s motion to seal." According to the Decision and Order, evidentiary hearings were held on July 25, 2024, and August 1, 2024. The record on appeal does not contain transcripts of the evidentiary hearings.[2] The family court

announced its decision during an August 8, 2024 hearing.



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Legal issue Can an appellate court affirm a family court's decision when the appellant fails to provide an adequate record and legal argument?

Headnote



FAMILY LAW. APPELLATE PROCEDURE FOR SELF-REPRESENTED LITIGANTS. The case involves an appeal by a self-represented litigant where the appellant's brief failed to comply with appellate procedural rules, and the court addressed the appellant's failure to provide an adequate record to establish error in the family court's decision.



FAMILY LAW. DIVORCE AND POST-DECREE MOTIONS. The case concerns multiple post-decree motions in a divorce proceeding, where the appellant failed to demonstrate any error with the family court's order due to a lack of factual or legal argument in the appeal brief.



Key Phrases Self-represented litigant. Divorce decree. Post-decree motions. Evidentiary hearings. Burden of furnishing the appellate court.

Affirmed