Matai Titles

Trial court's factual findings with respect to the four matai title criteria can only be reversed if they are clearly erroneous. Tuaolo v. Fruean, 1 ASR3d 28 (1997).

Trial court should follow the traditional rule, and determine clans based upon the children of the original title holder. Tuaolo v. Fruean, 1 ASR3d 28 (1997).