In Tahara, the court went as far as to lay out the elements of a Section 876 claim before ruling that the specific facts of the case did not give rise to a claim under the Restatement.... As the Hawaii Supreme Court has now clearly recognized and applied Section 876 in Tahara, which is closely related to Sections 312 and 138, this Court concludes that a third party's interference with one's fiduciary duty to another is actionable under Hawaii law.

In Tahara, the underlying action arose out of an employment-related altercation between plaintiff Quentin Hideyuki "Rocky" Tahara ("Tahara") and defendant Bruce Perry ("Perry").Id. at *1.

In Tahara, the court went as far as to lay out the elements of a Section 876 claim before ruling that the specific facts of the case did not give rise to a claim under the Restatement.