Appeal Under HRP Bylaw §117
From: Tammy Ash Perkins, State Committee Member

To: State Chair, Hawai‘i Republican Party et al;

Date: October 8, 2025

Subject: Appeal of Improper Actions and Unlawful Censure at Special State Committee Meeting

 
I. Introduction
Pursuant to HRP Bylaw §117, I hereby appeal the rulings and actions that occurred during the October 6, 2025 Special State Committee Meeting. The proceedings were conducted in a manner inconsistent with the Bylaws of the Hawai‘i Republican Party (HRP), Robert’s Rules of Order Newly Revised (RONR), and the contractual and fiduciary duties owed to Party members under HRS Chapter 429.

 
II. Grounds for Appeal
1. Improper and Unlawful Censure
During the meeting, a motion was introduced to censure me for exercising my duty to ensure compliance with HRP Bylaws regarding the composition of committees under HRP §§308(b), 406, and 408.

Under RONR §61:3, no member may be censured or disciplined for exercising their rights of debate, making motions, or holding leadership accountable. The motion to censure lacked written notice, specific charges, or a hearing, in direct violation of RONR §61:9 and due process principles recognized under HRP §107. The censure was therefore procedurally and substantively defective.

2. Ultra Vires Acts and Abuse of Authority
The meeting acted upon matters beyond its lawful authority, including the creation and operation of a so-called “Temporary Standing Discipline Committee.” This committee was never approved by delegates at a State Convention as required by HRP §§406–408 and RONR §50:14, which state that only the body with ultimate authority (the Convention) may establish or alter standing committees. Any actions or recommendations of this “temporary” committee are therefore ultra vires, unlawful, and void ab initio.

3. Improper Presiding Officer
The State Chair was absent.

Instead, the Vice Chair unilaterally assumes control, and proceeded to conduct business, rule on motions, and steer deliberations toward predetermined outcomes. This constitutes a serious breach of parliamentary authority, rendering all subsequent proceedings invalid.

4. Violation of Member Rights and Fiduciary Duty
Retaliatory censure for lawful participation and oversight violates the statutory rights of members under HRS §429-13, which guarantees fair, non-oppressive, and transparent governance in unincorporated nonprofit associations. These actions also breach the fiduciary duties of loyalty and care owed to the membership.

 
III. Relief Requested
Accordingly, I respectfully request that the State Committee:

Declare the censure motion null and void due to procedural and substantive defects.
Void all actions taken at the October 6, 2025 Special State Committee Meeting held without the duly elected Chair.
Dissolve the illegally created “Temporary Standing Discipline Committee.”
Reaffirm the autonomy of County Committees consistent with HRP §§406–408 and the rulings of the State Rules Committee.
Enter into the official minutes that any retaliatory action against members for enforcing the Bylaws is prohibited under HRP §107 and RONR §63.
 
IV. Notice of Escalation and Consequences for Non-Compliance
Failure by the State Committee or the Executive Committee to take immediate corrective action in response to this appeal will leave no alternative but to seek judicial intervention. Continued noncompliance with the Hawai‘i Republican Party Bylaws, RONR, and HRS Chapter 429 constitutes an ongoing deprivation of member rights and fiduciary duties under state law.

Accordingly, I will pursue temporary and permanent injunctive relief under Hawai‘i Rules of Civil Procedure Rule 65, including orders restraining the Party and its officers from enforcing unlawful actions, operating under illegally constituted committees, or engaging in retaliatory conduct against members acting in good faith to uphold the governing rules. These remedies are necessary to prevent further irreparable harm to the integrity of the Party, the rights of its members, and the rule of law itself.

 
V. Certification
I certify that the facts stated herein are true to the best of my knowledge and belief.

Respectfully submitted,
Tammy Ash Perkins
Chair, Maui County Republican Party
State Committee Member | Maui Rules Chair | Maui IPPRC Representative
📧 chair@mauicountygop.com