The Hawaii Intermediate Court of Appeals ruled on October 19, 2026, that All In 1 Bonding (AI1 Bonding) cannot set aside a bail forfeiture due to a late filing. This decision affects the bonding company and highlights the strict timelines involved in bail proceedings.
The court's ruling came after AI1 Bonding posted a $20,000 bail for Christopher Adams, who failed to appear in court. The ruling emphasizes the importance of adhering to legal deadlines in bail matters.
Background
The case involves the State of Hawaii as the plaintiff and Christopher Adams as the defendant. AI1 Bonding acted as the surety for Adams' bail. When Adams did not attend a scheduled court hearing, the circuit court issued a forfeiture order on March 20, 2025, which declared that the bail amount was forfeited.
Following the forfeiture, AI1 Bonding received notice of the judgment on March 26, 2025. However, the bonding company did not file its motion to set aside the forfeiture until May 6, 2025, which was 41 days after receiving the notice. The circuit court denied the motion on June 9, 2025, stating that it was filed too late.
The Ruling
The Hawaii Intermediate Court of Appeals upheld the lower court's ruling, affirming that AI1 Bonding's motion was indeed untimely. The court referenced Hawaii Revised Statutes (HRS) § 804-51, which mandates a 30-day period for filing a motion to set aside a bail forfeiture after receiving notice.
The court ruled, "the circuit court correctly determined that it lacked the power to consider AI1 Bonding's untimely Motion to Set Aside."
The judges presiding over the case included Presiding Judge Katherine G. Leonard, Associate Judge Keith K. Hiraoka, and Associate Judge Kimberly T. Guidry. They emphasized that the 30-day window for filing such motions is a jurisdictional requirement, meaning it cannot be waived.
Impact
This ruling serves as a reminder to bonding companies and defendants about the critical nature of adhering to legal timelines in bail matters. The court's decision reinforces the idea that failure to comply with statutory deadlines can lead to significant financial consequences.
The ruling could impact other bonding companies in Hawaii, as it clarifies that courts have no discretion to extend the filing period for motions related to bail forfeitures. This case may also serve as a precedent for future cases involving bail bond forfeiture and the strict adherence to procedural timelines.
What's Next
AI1 Bonding may have the option to appeal this decision to a higher court, but details were not available in the court filing. There are no related cases pending that were mentioned in the opinion.