Case Summary
The League of Women Voters of Hawaii filed a lawsuit asserting a law on government pensions violated the state constitution’s requirement that bill titles describe legislation’s contents and the legal deadline for bills to be introduced during a legislative session.
Hawaii’s constitution contains several requirements for a bill to be validly enacted in the legislative process.
Article II, Section 12 requires the legislature to set explicit deadlines for when bills can be introduced in the regular legislative session. The deadline for the 2025 legislative session was January 23, 2025.
Article III, Section 14 requires that, “No law shall be passed except by bill. Each law shall embrace but one subject, which shall be expressed in its title.”
On January 17, 2025, SB 935 was introduced. The title was simply “Relating to Government.” The only text in the bill stated (1) it aimed to “to effectuate the title of this Act”; (2) the Hawai`i Revised Statutes would be “amended to conform to the purpose of this Act”; and (3) that the changes “shall take effect upon its approval.”
On February 18, 2025, the bill was amended to add provisions on government pensions. The bill subsequently passed and was signed into law on July 3, 2025, by Governor Josh Green. The bill was then enrolled as Act 290.
On September 2, 2025, the League of Women Voters of Hawaii (“LWVHI”) filed a state court lawsuit in the Circuit Court for the First Circuit, asserting the legislature had violated several provisions of the Hawaii constitution when passing SB 935. LWVHI argued (1) the bill violated Article III, Section 14, by containing a boilerplate description in the title which did nothing to inform voters of its contents, and (2) the legislature had missed the bill introduction deadline by submitting a bill devoid of actual content and substantive text, meaning SB 935’s initial version was not a bill at all. LWVHI asserted the bill introduction deadline existed to ensure the public had a chance to educate itself about proposed legislation.
LWVHI asked the court to declare SB 935 void and issue a declaratory judgment that the procedure used to pass it was unconstitutional.
LWVHI was represented in this matter by the Public First Law Center.
LWV Timeline
League of Women Voters of Hawaii files lawsuit
The League of Women Voters of Hawaii files state court lawsuit challenging SB 935 under the state constitution.
League of Women Voters of Hawaii files motion for summary judgment
League of Women Voters of Hawaii moves for summary judgment, stating that under the facts of the case, the legislature had violated the state constitution beyond a reasonable doubt by using a vague, broad bill title and failing to meet the bill introduction deadline for S.B. 935.
Trial court sends questions to Hawaii Supreme Court
The trial court pauses the case and asks the Hawaii Supreme Court to answer several legal questions, including the definition of a "bill" and the content of a bill's title, in order to help resolve the case.