Case Explained: KANEALII V. SAITO, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-15 Docket: 1:23-cv-00276-DKW-KJM The Ninth Circuit affirmed the district court’s dismissal of Noa Kanealii’s amended complaint for lack of subject matter jurisdiction and its denial of Ryan ManaRa’s motion to intervene as of right. Regarding Kanealii, the court applied a de novo standard of review, accepting the facts alleged in the complaint as true but finding they failed to establish either federal question or diversity jurisdiction under 28 U.S.C. §§ 1331 and 1332. Specifically, the court held that Kanealii’s claim under the Alien Tort Statute (28 U.S.C. § 1350) was invalid because he is an American citizen, not a noncitizen of a foreign sovereign nation as required by precedent, noting that Hawaii is not a sovereign nation. The court also rejected his arguments based on the Supremacy Clause, the 1849-50 Hawaiian Treaty, the Genocide Statute, and various United Nations conventions. Because the complaint was insufficient to confer jurisdiction, the district court properly dismissed the case without prejudice after providing notice and an opportunity to amend. Regarding ManaRa, the court affirmed the denial of his motion to intervene under Federal Rule of Civil Procedure 24(a)(2), reasoning that a court lacks subject matter jurisdiction over the underlying case, thereby terminating the proceeding and leaving no case or controversy in which to intervene. As a practical consequence, the district court’s orders are upheld, the appeal is dismissed, and any pending motions for miscellaneous relief are denied as moot. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.