Bloch v Bloch - Divorce Decree Appeal Summary Disposition Order

Hawaii Supreme Court

Filed March 10th, 2026

Detected March 11th, 2026

Summary

The Intermediate Court of Appeals of the State of Hawaiʻi affirmed a divorce decree issued by the family court. The court found the appellant's brief lacked the required statement of errors and discernible argument, thus affirming the lower court's decision.

View original document View source feed page

What changed

The Intermediate Court of Appeals of the State of Hawaiʻi has affirmed a divorce decree previously issued by the Family Court of the Third Circuit in the case of Bloch v. Bloch. The appellate court's Summary Disposition Order, dated March 10, 2026, noted that the self-represented Defendant-Appellant David Michael Bloch failed to comply with appellate rules, specifically Rule 28(b)(4) of the Hawaiʻi Rules of Appellate Procedure, by not including a statement of points of error, providing discernible argument, or citing to the record or legal authority. Consequently, the court was unable to identify any basis for the appeal and affirmed the original divorce decree.

This ruling means the family court's divorce decree remains in effect. For legal professionals involved in appellate cases, this serves as a reminder of the critical importance of adhering to procedural rules, including proper brief formatting, citation requirements, and the inclusion of necessary transcripts. Failure to do so can result in the dismissal or affirmation of an appeal, as demonstrated in this case where the appellant's procedural deficiencies led to the affirmation of the lower court's decision. The court also denied the appellant's subsequent motions.

What to do next

Review appellate procedure rules for brief submission requirements
Ensure all legal arguments are supported by record references and legal citations

Source document (simplified)

Electronically Filed Intermediate Court of Appeals CAAP-24-0000459 10-MAR-2026 08:00 AM Dkt. 190 SO NO. CAAP-24-0000459 IN THE INTERMEDIATE COURT OF APPEALS OF THE STATE OF HAWAI‘I ANNETTE BLOCH, Plaintiff-Appellee, v. DAVID MICHAEL BLOCH, Defendant-Appellant APPEAL FROM THE FAMILY COURT OF THE THIRD CIRCUIT (CASE NO. 3FDV-22-0000791) SUMMARY DISPOSITION ORDER (By: Leonard, Presiding Judge, Hiraoka and Guidry, JJ.) Self-represented Defendant-Appellant David Michael Bloch (Husband) appeals from the "Decree Granting Absolute Divorce" (Divorce Decree) entered on June 13, 2024 by the Family Court of the Third Circuit (family court).The Honorable Jeffrey W. Ng presided.

Upon careful review of the record, the parties' briefs, and relevant legal authorities, we affirm the Divorce Decree. Husband's opening brief contains no statement of the points of error, as required by Rule 28(b)(4) of the Hawaiʻi Rules of Appellate Procedure, and provides no discernible argument, references to the record on appeal, or citations to legal authority. Husband did not order any transcripts of proceedings for the record on appeal. See Bettencourt v.Bettencourt, 80 Hawaiʻi 225, 230, 909 P.2d 553, 558 (1995) ("The burden is upon appellant in an appeal to show error by reference to matters in the record, and he or she has the responsibility of providing an adequate transcript." (cleaned up)). Although we do not automatically foreclose self-represented litigants from appellate review if they do not comply with court rules, Erum v. Llego, 147 Hawaiʻi 368, 380-81, 465 P.3d 815, 827-28 (2020), we are unable to discern any basis for Husband's apparent contention that the family court erred by entering the Divorce Decree. See Kakinami v. Kakinami, 127 Hawaiʻi 126, 144 n.16, 276 P.3d 695, 713 n.16 (2012) (noting that this court may "disregard a particular contention if the appellant makes no discernible argument in support of that position" (citation omitted)).

We therefore affirm the family court's Divorce Decree. DATED: Honolulu, Hawaiʻi, March 10, 2026. On the briefs: David Michael Bloch, Self-represented Defendant-Appellant. Jeremy J.K. Butterfield, for Plaintiff-Appellee. /s/ Katherine G. Leonard Presiding Judge /s/ Keith K. Hiraoka Associate Judge /s/ Kimberly T. Guidry Associate Judge Husband's February 20, 2026 "Appellant/Affiant Personal Affidavit, Consecution," and February 27, 2026 "CAAP-24-0000459: Written Response in Opposition, Memorandum Entered Objection, (UNTIMELY Recordation, Dkt. 182 AF)(EXH A)," which we construe to be motions, are denied.