The court distinguished the lone case in which itinterpreted the term “general law” in a challenge to a statute passed by the statelegislature to allow Maui County to hold a special election after acouncilmember died between his election and taking office. Bulgo v. County of Maui,430 P.2d 321 (Haw. 1967). The statute in that case was drawn verynarrowly, providing that if someone who was elected to “the office ofchairman of the board of supervisors of a county died before January 2,1967,” a special election would be held, unless the county charterprovided otherwise. Id. at 323. The statute also provided that it applied to each county. The Hawaii Constitution (currently Haw. Const. art. VIII, § 1) required the legislature confer powers upon counties “under general laws.”
TheBulgo court held the statute was a general law even though only Maui County hadone of its councilmembers die before January 2, 1967 because the statute was applicable to all counties, not just Maui.
How this is different from Bulgo, however, is not exactly clear.In that case, the challenged provision of the law only could be appliedto Maui County: “The governor shall issue a proclamation within tendays after the approval of this Act requiring special elections to beheld if any person elected in the general election of 1966 to theoffice of chairman of the board of supervisors of a county died beforeJanuary 2, 1967…”