Hawaii
How Bristol-Myers Squibb Co. v. Superior Court of California, San Francisco County applies in Hawaii: state-specific rules, key cases, and bar exam notes for Civil Procedure.
Hawaii law adheres closely to the principles established in Bristol-Myers Squibb, particularly regarding personal jurisdiction and the necessity for a sufficient connection between the claims and the forum state. In Hawaii, as in California, the courts evaluate the specific relationship between the defendants and the state in which they are being sued.
In Hawaii, the rule requires that a plaintiff must demonstrate both general and specific jurisdiction under Rule 12(b)(2) of the Hawaii Rules of Civil Procedure, establishing a connection between the forum and the underlying claims.
Held that jurisdiction must be established with a clear connection between the defendant's activities in Hawaii and the claims brought against them.
Reiterated that personal jurisdiction requires either general or specific jurisdiction, consistent with Bristol-Myers Squibb.
Confirmed the necessity for a substantial connection between the forum state and the matter being adjudicated.
Hawaii's approach mirrors the federal standard set forth in International Shoe Co. v. Washington, focusing on the quality and nature of the defendant's contacts with the forum state. However, Hawaii's courts may apply additional criteria based on state rules and precedents that further clarify jurisdictional standards.
Candidates should understand the implications of Bristol-Myers Squibb on personal jurisdiction questions, as it is a pertinent topic in the Hawaii Bar Exam.