in which this Court's authority to review criminal convictions was greatly circumscribed.” Cotton, 535 U.S. at 629, 122 S.Ct. 1781. It could examine constitutional errors in a criminal trial only on a writ of habeas corpus, and only then if it deemed the error "jurisdictional.” Id. (internal quotation marks omitted). "The Court’s desire to correct obvious constitutional violations led to a 'somewhat expansive notion of jurisdiction.Id. (quoting Custis v. United States, 511 U.S. 485, 494, 114 S.Ct. 1732, 128 L.Ed.2d 517 (1994)) (internal quotation marks omitted). 25 . A charging instrument may be so deficient that a court does not have jurisdiction over the case; for instance, if the charging document was never filed. See State v. Kaulia, 128 Hawai'i 479, 491, 291 P.3d 377, 389 (2013) (<HOLDING>). Without deciding the matter, a charge that
holding that although that the district court erred in finding that plaintiffs lacked standing the appellate court may nonetheless proceed to consider the district courts determination that plaintiffs failed to state a claim upon which relief may be granted holding that an action brought against the state officials in their official capacities was not properly removed to federal court because the district court lacked jurisdiction holding that the appellate court had jurisdiction to hear the interlocutory appeal on a restraining order and the district court retained jurisdiction to proceed with the trial holding that the district court lacked jurisdiction to review state disciplinary proceedings against attorney holding that because the state failed to properly file the complaint the district court lacked jurisdiction to proceed to trial