The Hawaii Intermediate Court of Appeals recently upheld rulings against Keaka Martin, an inmate, in his claims against the Department of Public Safety (DPS). The court's decision, issued on September 22, 2026, addresses Martin's allegations related to COVID-19 medical care and his right to judicial access. This ruling is significant as it clarifies the legal standards for inmates seeking redress for medical negligence and access to court hearings.
Martin, who is currently incarcerated, filed a Verified Complaint against DPS alleging negligence regarding his treatment for COVID-19 and claiming his right to judicial access was violated when he was not transported to a court hearing. The court's decision impacts not only Martin but also sets a precedent for how similar claims by inmates may be handled in the future.
The case originated from Martin's conviction in 2014 for attempted murder and firearm violations. Following his conviction, he appealed the judgment, which led to a ruling by the Hawaii Supreme Court that the trial court had erred in handling his case. After his attorney withdrew in 2020, Martin faced issues regarding his representation and access to the courts.
In 2022, Martin filed his Verified Complaint, alleging that DPS failed to provide adequate medical care during his COVID-19 infection and that he was deprived of his right to attend a court hearing in person. The case progressed through the Circuit Court of the First Circuit, where multiple motions for summary judgment were filed by DPS.
On December 20, 2023, the Circuit Court granted DPS's motion regarding Martin's COVID-19 related claims, stating that Martin had not met the requirements outlined in Hawaii Revised Statutes (HRS) chapter 671, which governs medical tort claims. However, the court denied the motion concerning Martin's judicial access claim, allowing that part of the case to continue.
Later, on May 20, 2025, the Circuit Court ruled in favor of DPS regarding the judicial access claim as well. The court found that Martin had not established a right to be physically present at the hearing and had not provided sufficient evidence to support his claims. The court stated, "Martin has provided no basis on which to overturn the Circuit Court's ruling." This ruling effectively ended Martin's claims against DPS.
The court's ruling emphasized that summary judgment is appropriate when there is no genuine issue of material fact, meaning that the evidence presented does not support Martin's claims. The court reviewed the records and determined that Martin's claims were not valid under the law.
The implications of this ruling are significant for inmates who may face similar situations. It reinforces the requirement that inmates must follow specific legal procedures when filing claims related to medical negligence and judicial access. The court's decision indicates that claims must be well-supported and adhere to statutory requirements to proceed in court.
Moreover, the ruling clarifies that claims related to medical treatment, such as those arising from COVID-19, must be submitted to the medical inquiry and conciliation panel as outlined in HRS chapter 671. This requirement is designed to ensure that medical negligence claims are properly evaluated before being brought to court.
Moving forward, this ruling may deter some inmates from pursuing claims that do not meet the strict legal standards set forth by the court. It may also lead to increased scrutiny of how correctional facilities provide medical care to inmates, particularly in light of public health concerns like the COVID-19 pandemic.
As for Martin, he may have limited options for further legal recourse. While he could potentially appeal the court's decision to a higher court, the likelihood of success would depend on whether he can present new evidence or arguments that were not previously considered. Details were not available in the court filing regarding any potential for appeal or related cases pending.