Hawaii Appeals Court Upholds TRO Blocking Ex-Landlord's COVID Vaccine Texts
A Hawaii intermediate appellate court affirmed a temporary restraining order that bars former landlord Duering from contacting former tenant Gonda after a series of unsolicited health-related texts.
The Hawaii intermediate appellate court, composed of Justices Katherine G. Leonard, Keith K. Hiraoka and Daniel M. Gluck, affirmed a lower-court order that restricts former landlord Duering from contacting former tenant Anaya Gonda. Gonda alleged that Duering sent over 25 text messages after her tenancy ended on September 11, 2023, repeatedly urging her to consider his views that COVID vaccines caused her health issues.
Evidence included testimony from Gonda’s boyfriend, Gustavo D'Amico, who witnessed Duering confronting them on the day of the move-out. The district court found Duering’s behavior met Hawaii’s statutory definition of harassment and issued a temporary restraining order and a three-year injunction. Duering appealed on free-speech and religious-freedom grounds, but the appellate panel concluded the order merely curtails unwanted communication with Gonda, not his broader expression, and saw no indication of judicial bias.
Why it matters
The ruling clarifies that courts can limit persistent, unwanted contact even when the content involves protected speech.
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