The Hawaii Supreme Court recently ruled in a case involving a dog named Bigsby, clarifying the limits of small claims court jurisdiction. The court decided that the small claims division of the District Court of the Second Circuit did not have the authority to determine ownership of Bigsby, affecting how similar disputes may be handled in the future.
This ruling is significant as it establishes that small claims courts in Hawaii cannot resolve ownership disputes over personal property, such as pets, which may lead to changes in how people approach custody issues for animals after separations.
The case, known as Miller v. Collins (SCPW-26-0000400), arose from a dispute between Alexandra Miller and Wylan Faulk regarding their shared dog, Bigsby. After the couple separated, they initially shared custody of the dog. However, tensions escalated when Faulk refused to return Bigsby to Miller on the agreed exchange date in January 2026. This led Miller to file a claim in the small claims division, seeking either the return of Bigsby or $3,000 in compensation.
Miller argued that she and Faulk had jointly acquired Bigsby and that she had been responsible for the dog's veterinary care. She described Bigsby as “unique personal property” and claimed that monetary damages would not suffice. The case was heard in March 2026, where both parties presented their testimonies. Faulk contended that he should have full custody of Bigsby to provide stability for the dog.
Judge Lance Collins ruled in favor of Faulk, granting him legal and physical ownership of Bigsby and ordering him to compensate Miller for half of the dog’s valuation and veterinary expenses. Following this ruling, Miller sought to overturn the judgment, arguing that the small claims court lacked jurisdiction to decide on ownership issues.
In its opinion, the Hawaii Supreme Court emphasized that subject matter jurisdiction is crucial for any court to hear a case. The court noted that the small claims division is limited to specific types of cases, including small money claims and disputes over residential security deposits, as defined by Hawaii Revised Statutes (HRS) § 633-27. The court stated, “The small claims division lacked jurisdiction to decide Bigsby’s ownership.”
The court highlighted that Miller’s claim was essentially an action in replevin, a legal term for seeking the return of specific personal property. The ruling clarified that ownership disputes over personal property, including pets, cannot be resolved in small claims court. The court stated, “What the owner may not do is litigate ownership in the small claims division.”
As a result, the Hawaii Supreme Court granted Miller’s petition for a writ of mandamus, vacating the small claims court’s ruling and remanding the case to the district court with instructions to dismiss it without prejudice. This means that Miller can potentially pursue her claim in a different court that has the appropriate jurisdiction.
The ruling has significant implications for future cases involving pet custody disputes. It establishes that individuals cannot rely on small claims courts to resolve ownership issues regarding pets, which may lead to more formal legal proceedings in family or civil courts. This decision reflects a growing recognition of the complexities involved in pet custody disputes, particularly as pets are increasingly viewed as family members rather than mere property.
Moving forward, this ruling may encourage individuals to seek legal advice and consider alternative dispute resolution methods when navigating pet custody issues. It also highlights the importance of understanding the jurisdictional limits of different court divisions, ensuring that parties choose the appropriate venue for their claims.
Details were not available in the court filing regarding whether Miller plans to pursue her claim further or if there are related cases pending. However, the ruling serves as a reminder that ownership disputes over pets must be handled in courts with the proper authority.