Hawaiʻi’s appeals court handed U.S. Bank two foreclosure wins in one day – one on note possession, one a sharp lesson on surplus equity.
Both summary disposition orders came out of the Intermediate Court of Appeals of the State of Hawaiʻi on May 22, 2026. Different panels, different facts, both naming U.S. Bank as trustee for a pre-crisis private-label trust. Read together, they read as a same-day signal to foreclosing trustees and the servicers running their files.
The first ruling, U.S. Bank as Trustee v. Goodwin, was decided by Presiding Judge Katherine G. Leonard with Associate Judges Keith K. Hiraoka and Kimberly T. Guidry. The court affirmed a foreclosure decree against borrower David D. Goodwin over a Honolulu property…