Csizmazia v. Brady

── Csizmazia v. Brady ── Court: Hawaii Intermediate Court of Appeals Date: April 24, 2026 Category: General NOT FOR PUBLICATION IN WEST'S HAWAI‘I REPORTS AND PACIFIC REPORTER Electronically Filed Intermediate Court of Appeals CAAP-XX-XXXXXXX 24-APR-2026 07:53 AM Dkt. 74 SO NO. CAAP-XX-XXXXXXX IN THE INTERMEDIATE COURT OF APPEALS OF THE STATE OF HAWAI‘I MARYANNE CSIZMAZIA, as Executrix for the Estate of BRIAN MCCOY, Plaintiff-Appellant, v. SHELAGH BRADY, an individual, Defendant-Appellee APPEAL FROM THE CIRCUIT COURT OF THE SECOND CIRCUIT (CASE NO. 2CCV-XX-XXXXXXX) SUMMARY DISPOSITION ORDER (By: Hiraoka, Presiding Judge, McCullen and Guidry, JJ.) Plaintiff-Appellant Maryanne Csizmazia (Csizmazia) appeals from the "Order Granting Defendant[-Appellee] Shelagh Brady's [(Brady)] Motion to Dismiss Filed October 17, 2023" (Dismissal Order), entered on January 30, 2024 by the Circuit Court of the Second Circuit (circuit court). 1 This matter arises out of a Complaint, filed in March 2023, by Csizmazia, as Committee 2 and Attorney in Fact for Brian 1 The Honorable Kelsey T. Kawano presided. 2 It appears that, in Canada, a "Committee" is akin to a court- appointed guardian or personal representative.  NOT FOR PUBLICATION IN WEST'S HAWAI‘I REPORTS AND PACIFIC REPORTER McCoy (Brian). 3 The Complaint alleged that Brady "wrongfully took advantage of her disabled brother Brian by using [her power of attorney for Brian] to take for her own use substantial funds from the sale of his investment property in Maui, thereby unjustly enriching herself at his expense." Brady, a citizen of Canada, filed a "Motion to Dismiss for Lack of Personal Jurisdiction or, in the Alternative, to Stay Proceedings" (Motion to Dismiss). Following a hearing, the circuit court granted the Motion to Dismiss, on the grounds that it lacked personal jurisdiction over Brady, and entered the Dismissal Order. In July 2024, on temporary remand, the circuit court entered its Final Judgment. On appeal, Csizmazia raises two points of error, contending that the circuit court erred in entering its Dismissal Order because: (1) "[Csizmazia] made a prima facie showing that [Brady's] activities in Hawaiʻi fall into a category specified by Hawaiʻi's long-arm statute in order to establish specific jurisdiction"; and (2) "[Csizmazia] made a prima facie showing that [Brady] purposefully and continuously interjected herself into the forum state such that [the] constitutional due process requirements are satisfied." 3 Csizmazia filed the Complaint on behalf of Brian and, following his death during the pendency of the trial court proceedings, was substituted as executrix for Brian's estate. 2  NOT FOR PUBLICATION IN WEST'S HAWAI‘I REPORTS AND PACIFIC REPORTER We review the circuit court's Dismissal Order de novo. City & Cnty. of Honolulu v. Sunoco LP, 153 Hawaiʻi 326, 340, 537 P.3d 1173, 1187 (2023). Upon careful review of the record, briefs, and relevant legal authorities, and having given due consideration to the arguments advanced and the issues raised by the parties, we resolve Csizmazia's contentions of error as follows. In Yamashita v. LG Chem, Ltd., the Hawaiʻi Supreme Court held that "Hawaiʻi's long-arm statute incorporates the limits of due process," and accepted that "the personal jurisdiction analysis under the Hawai[ʻ]i long-arm statute" can be "collapse[d] into a single due p