Hawaii

Armory v. Delamirie in Hawaii Law

How Armory v. Delamirie applies in Hawaii: state-specific rules, key cases, and bar exam notes for Property.

State Approach

Hawaii adheres to the common law principles of finders' rights established in Armory v. Delamirie, where a finder of abandoned property holds stronger rights against all except the true owner. This legal framework is supported by Hawaii's recognition of property rights and the importance of possession.

State Rule
In Hawaii, the rule follows that a finder of lost or abandoned property acquires title to the property against all but the true owner, aligning with the principles derived from Armory v. Delamirie.
Significant State Cases

Mizuho Bank Ltd. v. Lentz

The court held that finder’s rights to lost property were enforceable against someone without superior title.

Wong v. Aloha Airlines, Inc.

Held that property left behind at an airport becomes the property of the airline unless claimed, reflecting finder rights.

Tokio Marine & Fire Ins. Co. v. Williams

This case clarified that possession establishes a presumptive right to property against others, mirroring principles from Armory.

Comparison to Federal Law

Hawaii's approach to finders' rights is consistent with federal common law, which also protects the rights of a finder against everyone but the true owner. However, Hawaii courts may emphasize local statutory interpretations and public policy nuances that can slightly alter the application of these principles.

Bar Exam Note

Understanding finders' rights as established in Armory v. Delamirie is crucial for the Hawaii bar exam, especially in property law sections.

Practice Pointers
  • Always determine the status of the property (lost, mislaid, or abandoned) before applying finders' rights.
  • Consider local statutes that may impact possession and title to property in Hawaii.
  • Familiarize yourself with Hawaii’s case law on property to better support arguments regarding finders' rights.

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