How Animals Came to be in the Reckless Driving Statute (HRS 291-2)

By Roberta Freeland Woods, J.D., M.L.I.Sc.

Do you imagine drunk tourists riding horses fast and furiously dodging in and out of Honolulu traffic when you read, below, Hawaiʻi Revised Statutes section 291-2, “Reckless driving of vehicle or riding of animals; penalty”?

Whoever operates any vehicle or rides any animal recklessly in disregard of the safety of persons or property is guilty of reckless driving of vehicle or reckless riding of an animal, as appropriate, and shall be fined not more than $1,000 or imprisoned not more than thirty days, or both. [1]

If not, you should. That’s how this law got its start in the Hawaiian Kingdom, and it’s why the part about animals is still in the law. It can still happen and when it does, we are prepared to punish those who recklessly ride any animal now. To my 21st century mind, this is the horse chase scene in the 2019 film John Wick: Chapter 3, Parabellum, where Keanu Reeves being chased by motorcycle ninjas, wearing a suit and tie gallops through New York traffic shooting his gun and fending off motorcycle ninjas on horseback.

Reading the history of this statute, one is led to believe that the statute originated with the Penal Code of 1869 as chapter 26, section 1, but that would be incorrect. The Hawaiʻi Revised Statutes shows twelve citations in the history of section 291-2. There should be eighteen citations for this section of the code. Reliance on the history as shown in the Hawaiʻi Revised Statutes would be misplaced given that six citations are missing entirely. It all started in 1841 with the “Law Respecting the Running of Horses.”


[1] Current through Act 32 of the 2019 Regular Session.

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