There are four criteria to be
considered when deciding a matai title: 1) best hereditary right; 2) wish of
majority or plurality of the family clans; 3) forcefulness, character,
personality and knowledge of Samoan custom; and 4) value of candidate to
family, village and country. Lealai v. Aoelua, 1 A.S.R.3d 12 (1997).
The trial court’s findings with regard to matai criteria can only be set
aside if clearly erroneous. Lealai v. Aoelua, 1 A.S.R.3d 12 (1997).
The “Satoa Rule” determines best hereditary right based upon
the blood relationship of the candidates to the original titleholder. The “Satoa Rule” should not always be used,
but is appropriate where the family traditionally traces the blood relationship
back to the original titleholder, where clans of the family have not held the
title for several generations, or where the family history is largely
harmonious. In case where family history
was unanimous as to the original titleholder, use of the “Satoa Rule” was less
arbitrary than other methods and was appropriate. Misaalefua v. Hudson, 1 A.S.R.3d 23 (1997).
There is no bright line
rule regarding de minimus blood relationships. A 1/128 blood relationship is not de
minimus when the “Satoa Rule” is used.
Misaalefua v.
Hudson, 1 A.S.R.3d 23 (1997).
Trial Court’s determination of the candidates'
hereditary rankings can only be set aside if clearly erroneous. Misaalefua v. Hudson, 1 A.S.R.3d
23 (1997).
Trial Court’s determination of the family clans
can only be set aside if clearly erroneous.
Misaalefua v.
Hudson, 1 A.S.R.3d 23 (1997).
Trial Court’s determination regarding the support of the majority of the
family can only be set aside if clearly erroneous. Misaalefua v. Hudson, 1 A.S.R.3d 23 (1997).
Trial Court’s determination that there was no
majority support for any one candidate was not clearly erroneous where there
was sufficient evidence to support such conclusion. Misaalefua v. Hudson, 1 A.S.R.3d
23 (1997).
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 A.S.R.3d 33 (1997).
Trial court should follow the traditional rule, and determine clans based upon the children of the original title holder. Tuaolo v. Fruean, 1 A.S.R.3d 33 (1997).