As a vexatious litigant must be a natural person, given plaintiff's corporate status, trial court erred in determining that corporation was a vexatious litigant under this chapter; also, as only a plaintiff may be deemed a vexatious litigant, trial court erred in determining that attorney of record for plaintiffs was a vexatious litigant under this chapter. 98 H. 95 (App.), 43 P.3d 232.

Where Hawaii supreme court had opined in a previous case that plaintiff had "engaged in a pattern of frivolous and vexatious litigation" and that case and the present case were "based upon the same or substantially similar facts, transaction, or occurrence", trial court correctly determined that plaintiff was a vexatious litigant under this section. 98 H. 95 (App.), 43 P.3d 232.