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Bloch v. Bloch - Hawaii Court Opinion

Hawaii Intermediate Court of Appeals

Filed March 10th, 2026

Detected March 11th, 2026

Summary

The Hawaii Intermediate Court of Appeals affirmed a divorce decree in Bloch v. Bloch. The court found the appellant's brief lacked the required statement of errors and discernible argument, affirming the lower court's decision. The opinion was filed on March 10, 2026.

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What changed

The Hawaii Intermediate Court of Appeals has affirmed a divorce decree in the case of Bloch v. Bloch, filed on March 10, 2026. The court noted that the Defendant-Appellant's opening brief failed to comply with appellate rules, specifically Rule 28(b)(4) of the Hawaiʻi Rules of Appellate Procedure, by not including a statement of the points of error, providing no discernible argument, and lacking references to the record or legal authority. Consequently, the court was unable to identify any basis for the appellant's contention that the family court erred.

This ruling means the family court's divorce decree stands. For legal professionals, this case highlights the critical importance of adhering to procedural rules in appellate filings. Failure to do so, as demonstrated by the appellant, can lead to the affirmation of the lower court's decision without a substantive review of the merits. There are no new compliance deadlines or penalties associated with this specific court opinion, as it pertains to an individual case's procedural deficiencies.

What to do next

Review appellate procedure rules for compliance with briefing requirements.
Ensure all appellate briefs contain a statement of points of error, record references, and legal citations.

Source document (simplified)

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March 10, 2026 Get Citation Alerts Download PDF Add Note

Bloch v. Bloch

Hawaii Intermediate Court of Appeals

Citations: None known
Docket Number: CAAP-24-0000459
Opinion
Authorities (3)
Cited By (0)
Summaries (0)
Similar Cases (0)
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Combined Opinion

NOT FOR PUBLICATION IN WEST'S HAWAI‘I REPORTS AND PACIFIC REPORTER

Electronically Filed
Intermediate Court of Appeals
CAAP-XX-XXXXXXX
10-MAR-2026
08:00 AM
Dkt. 190 SO

NO. CAAP-XX-XXXXXXX

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-XX-XXXXXXX)

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). 1

1 The Honorable Jeffrey W. Ng presided.
NOT FOR PUBLICATION IN WEST'S HAWAI‘I REPORTS AND PACIFIC REPORTER

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)).

2
NOT FOR PUBLICATION IN WEST'S HAWAI‘I REPORTS AND PACIFIC REPORTER

We therefore affirm the family court's Divorce Decree. 2

DATED: Honolulu, Hawaiʻi, March 10, 2026.

On the briefs: /s/ Katherine G. Leonard
Presiding Judge
David Michael Bloch,
Self-represented /s/ Keith K. Hiraoka
Defendant-Appellant. Associate Judge

Jeremy J.K. Butterfield, /s/ Kimberly T. Guidry
for Plaintiff-Appellee. Associate Judge

2 Husband's February 20, 2026 "Appellant/Affiant Personal
Affidavit, Consecution," and February 27, 2026 "CAAP-XX-XXXXXXX: Written
Response in Opposition, Memorandum Entered Objection, (UNTIMELY Recordation,
Dkt. 182 AF)(EXH A)," which we construe to be motions, are denied.