§657-4  Two years; libel and slander.  All actions for libel or slander shall be commenced within two years after the cause of action accrued, and not after. [CC 1859, §1037; am imp L 1907, c 113, §1; am L 1913, c 19, §1; RL 1925, §2642; RL 1935, §3913; RL 1945, §10424; RL 1955, §241-4; am L 1965, c 139, §2; HRS §657-4]

 

Case Notes

 

  Portions of plaintiff's defamation claim based on defendant's 2007 report and alleged 2007 statements were time-barred, where plaintiff filed the action in 2010.  892 F. Supp. 2d 1245 (2012).

  Plaintiff, a former state employee, alleged slander against one of the state defendants.  Although plaintiff appeared to conclude that the continuing violation doctrine made plaintiff's claims actionable, the court found that plaintiff failed to allege that the claims fell within the two-year limitations period.  430 F. Supp. 3d 655 (2020).

  Claim for defamation accrues when defamee discovers or reasonably should have discovered publication.  65 H. 478, 653 P.2d 1155 (1982).

  Distinguished from "general" personal injury statute of limitations of §657-7.  73 H. 578, 837 P.2d 1247 (1992).

  Cited:  42 H. 177, 179 (1957).

  Mentioned:  817 F. Supp. 850 (1992).