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REAL PROPERTY Royal “patent grants” of land from the Kingdom of Hawaii, which ended in 1894, did not create rights for the descendants of the grantees, the Hawaii Intermediate Court of Appeals held on April 14. Makapono Partners LLC v. Heirs of Simeona, No. 24096. Makapono Partners LLC filed suit to quiet title on property it had acquired. July Simeona, a descendant of the recipient of a royal land grant in the 1800s, challenged Makapono’s title, arguing that royal grants were inalienable, and therefore, title could be held only by the descendants of his great-grandfather, Kalua. A circuit court held for Makapono, and Simeona appealed. Affirming, the appeals court held that royal grants of land were alienable, making Makapono’s title valid. The court said, “titles awarded by Royal Patent may not be vested for ‘perpetuity,’ as July seems to suggest, but rather, all subsequent claimants of land must derive their title from the person to whom the original award was made.”

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