It does, police say, and it's illegal.

Kailua resident Sharon Kidwell has run newspaper ads since last week giving away her home in a drawing that ends Jan. 15. The ad is also on the Internet at http://www.surfhi.com.

Yesterday, police advised her in person and in writing that the "Hawaii Home Giveaway" is a gambling scheme that violates state laws and those laws would be enforced if she pursues it, she said.

She's hoping it won't come to that.

"I'm pretty sure this is not a no-end situation," she said yesterday. "It's not a sham - it's perfectly legal."

Kidwell's purpose for giving away her home is twofold: Hawaii's real estate market is depressed - homes in the price range of hers are not selling - and she wants to raise money for those who suffer from mental retardation, epilepsy and spinal bifida.

The giveaway does not violate state law because "I'm requesting, not requiring" participants to send a contribution with entries, Kidwell said. Money is requested in the form of a donation.

She was advised by her husband's attorney that the giveaway was within the guidelines of state and federal laws that govern the Internet. "I under<P>stand from the attorney that if I don't perform what I say I will do, they will get me for fraud."

If she cannot raise $1.35 million to cover the purchase of the home, Kidwell plans to disburse the funds to charities that provide services for mental retardation, epilepsy and spina bifida, she said.

She became involved in these organizations when her son, Toby Gene, was born with a form of spina bifida. Doctors operated on him when he was only eight hours old to remove a bulging sac at the back of his head encasing the spinal cord, resulting in mental retardation, Kidwell said. Rather than put him in an institution, she raised Toby Gene at home. He died at age 14 in 1982, of an epileptic seizure, Kidwell said.

So far participants have mailed in $1,000 in donations, some accompanied by entries and some without, she said. Ads for the giveaway ran last week in the Sun Press and this week in Midweek. She's optimistic the money will be raised. "A lot of good people are trying to help," she said. "I know God will come through for me."

Her husband, tired of her vices, long hours at work and not spending enough time with him and the children, left her and their two children in early 1993, she said. She said their home was still under renovation and her husband stopped making payments. The home was up for foreclosure last month, she said.

After watching her children pop fireworks on July 4, she said the Lord spoke to her as she sat down to read her Bible. The word he said was "raffle."

Kidwell later checked with police who told her a raffle would be illegal. However, "they told me anybody could do this type of promotion as long as I did not charge for tickets."

After the house is given away in a drawing expected to be held Jan. 25, Kidwell and her two children plan to move to Buckingham, Va., to set up a prison ministry for about 20,000 inmates, she said. She and the children also plan to build a Church of El-Shaddai there.

Her children are behind her, she said. "They're excited. They know Mom loves the lord and Mommy is not a crackpot. They have faith in God."