Citizens Against Reckless Dev. v. Zoning Bd. of Honolulu

In Citizens Against Reckless Dev. v. Zoning Bd. of Honolulu, 114 Haw. 184, 159 P.3d 143 (Haw. 2007), the court held that the declaratory ruling procedure of Hawaii's Administrative Procedure Act was not meant to be used to challenge already-made agency decisions. Id. at 156. In coming to this conclusion, the court stressed that the relevant statute provided for a petition for a declaratory ruling as to the applicability of any rule. Id. The plaintiffs in Citizens were not challenging the validity of a rule but a specific zoning decision. Id. at 155. They were afforded an opportunity to appeal that decision but failed to timely do so. Id. The court's holding effectively prevented the plaintiffs from circumventing the timeliness rules. See id. at 160.