Hawaii court rules in favor of U.S. Bank in foreclosure case

The Hawaii Intermediate Court of Appeals has ruled in favor of U.S. Bank National Association in a foreclosure case involving David D. Goodwin. This decision, issued on May 22, 2026, confirms U.S. Bank's right to enforce a mortgage against Goodwin's property in Honolulu. The ruling is significant as it clarifies the requirements for banks to establish their standing in foreclosure actions, which could affect similar cases in the future.

David Goodwin owned real estate in Honolulu and had previously taken out a loan secured by a mortgage on the property. U.S. Bank, which currently holds the mortgage, filed a foreclosure complaint against Goodwin in September 2017. Goodwin contested the foreclosure, leading to an appeal after the circuit court ruled in favor of U.S. Bank.

The dispute began when Goodwin executed a promissory note in 2006, which was secured by a mortgage. The mortgage was transferred through several entities before U.S. Bank acquired it. Goodwin argued that U.S. Bank did not have the right to enforce the mortgage because it could not prove it had possession of the note at the time the foreclosure complaint was filed.

The case reached the Intermediate Court of Appeals after Goodwin appealed the circuit court's decision that allowed U.S. Bank to proceed with the foreclosure. Goodwin raised several points of error, primarily focusing on the issue of U.S. Bank's standing to enforce the mortgage.

The court ruled that U.S. Bank had established its standing to enforce the mortgage. In its opinion, the court stated, "U.S. Bank was entitled to enforce the underlying promissory note because it was in possession of the Note, which was duly indorsed in blank from June 2014, onwards, including when this action was commenced." The ruling was delivered by a panel of judges including Presiding Judge Katherine G. Leonard, Associate Judge Keith K. Hiraoka, and Associate Judge Kimberly T. Guidry.

The court found that U.S. Bank had demonstrated its possession of the original note through the testimony of Patrick Pittman, a litigation director for Select Portfolio Servicing, Inc., which manages the loan on behalf of U.S. Bank. Pittman testified about the procedures SPS followed to maintain records and ensure that they were accurate and complete. The court noted, "Based upon a preponderance of the evidence, U.S. Bank proved all essential elements of its case and is entitled to judgment as a matter of law."

This ruling has implications for future foreclosure cases in Hawaii. By affirming that U.S. Bank had standing to enforce the mortgage, the court clarified that a bank must demonstrate it was in possession of the note at the time it filed for foreclosure. This decision could influence how banks and mortgage servicers handle documentation and record-keeping in future cases.

In terms of precedent, this ruling reinforces the standard that banks must meet to establish their right to foreclose on a property. It emphasizes the importance of maintaining clear and accurate records regarding the possession of promissory notes. This case may serve as a reference for similar disputes in the future, particularly in Hawaii.

Looking ahead, it is unclear whether Goodwin will seek to appeal the decision to a higher court. The court filing did not provide details on any potential next steps. However, the ruling stands as a significant legal determination regarding mortgage enforcement in Hawaii.