Hawaii · state appellate court · 2025

Keaau Development Partnership LLC v. Lawrence, Jr. ICA Opinion, filed 05/12/2025.

Hawaii Intermediate Court of Appeals, 12 May 2025 to 15 May 2025. What the court wrote about citations that did not exist, in its own words, from 2 documents on file.

Case record · Haw. App.

  1. Court. Hawaii Intermediate Court of AppealsCOURT
  2. Level. state appellate courtLEVEL
  3. Dates. 12 May 2025 to 15 May 2025DATED
  4. Docket. No. CAAP-24-0000494DOCKET
  5. Documents. 2 documents, 16 passages quoted belowON FILE
  6. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 15 May 2025 · source · PDF · 6 pages

He stated he had "retained a per diem attorney — someone I had previously worked with and trusted — to handle the drafting" of the motion to dismiss and "failed to verify every single citation meticulously, specifically missing the fabricated citation of the 'Greenspan' case[.]" He stated, "[a]lthough I did not personally use AI [(artificial intelligence)] in this case, I failed to ensure that every citation was accurate before filing the brief." [T]he signing attorney cannot leave it to some trusted subordinate, or to one of his partners, to satisfy himself that the filed paper is factually and legally responsible; by signing he represents not merely the fact that it is so, but also the […]

120, 125 (1989)). The court finds that DiPasquale's citation of Greenspan — a nonexistent case — without first attempting to read it to confirm his contention of its holding was not reasonable under the circumstances, and a violation of HRCP Rule 11(b)(2). Cf.

Apr. 24, 2025) (order imposing sanctions) (stating that "an attorney who submits fake cases clearly has not read those nonexistent cases, which is a violation of Rule 11 of the Federal Rules of Civil Procedure"). "[T]he central purpose of [federal] Rule 11 is to deter baseless filings in district court and thus . . . streamline the administration and procedure of the federal courts." Cooter & Gell v.

384, 393 (1990). Federal courts seem to encounter AI-generated citations to nonexistent cases with increasing frequency, "raising the importance of educating and deterring the larger bar from repeating similar conduct." United States v. Hayes , --- F.

Supp. 3d at ---, 2025 WL 1195925, at *9 ($1,000 for citing nonexistent cases "because of [counsel]'s candor and sincere regret"); Dehghani v. Castro , No.

Apr. 2, 2025) (mem. op. & ord.) ($1,500 for citing nonexistent cases); Hayes , --- F. Supp.

Supp. 3d at ---, 2025 WL 235531, at *15 ($1,500 for citing nonexistent case); Gauthier v. Goodyear Tire & Rubber Co., No.

Nov. 25, 2024) (mem. & ord) ($2,000 for citing nonexistent cases and quotations); Wadsworth , 348 F.R.D. at 498 ($3,000 for citing "hallucinated cases"); Mata, 678 F.Supp.3d at 466 ($5,000 for using AI to generate excerpt of nonexistent opinion); Mid Cent. Operating Eng'rs Health & Welfare Fund v.

Published opinion, 12 May 2025 · source · PDF · 6 pages

He stated he had "retained a per diem attorney — someone I had previously worked with and trusted — to handle the drafting" of the motion to dismiss and "failed to verify every single citation meticulously, specifically missing the fabricated citation of the 'Greenspan' case[.]" He stated, "[a]lthough I did not personally use AI [(artificial intelligence)] in this case, I failed to ensure that every citation was accurate before filing the brief." [T]he signing attorney cannot leave it to some trusted subordinate, or to one of his partners, to satisfy himself that the filed paper is factually and legally responsible; by signing he represents not merely the fact that it is so, but also the […]

120, 125 (1989)). The court finds that DiPasquale's citation of Greenspan — a nonexistent case — without first attempting to read it to confirm his contention of its holding was not reasonable under the circumstances, and a violation of HRCP Rule 11(b)(2). Cf.

Apr. 24, 2025) (order imposing sanctions) (stating that "an attorney who submits fake cases clearly has not read those nonexistent cases, which is a violation of Rule 11 of the Federal Rules of Civil Procedure"). "[T]he central purpose of [federal] Rule 11 is to deter baseless filings in district court and thus . . . streamline the administration and procedure of the federal courts." Cooter & Gell v.

384, 393 (1990). Federal courts seem to encounter AI-generated citations to nonexistent cases with increasing frequency, "raising the importance of educating and deterring the larger bar from repeating similar conduct." United States v. Hayes, --- F.

Supp. 3d at ---, 2025 WL 1195925, at *9 ($1,000 for citing nonexistent cases "because of [counsel]'s candor and sincere regret"); Dehghani v. Castro, No.

Apr. 2, 2025) (mem. op. & ord.) ($1,500 for citing nonexistent cases); Hayes, --- F. Supp.

Supp. 3d at ---, 2025 WL 235531, at *15 ($1,500 for citing nonexistent case); Gauthier v. Goodyear Tire & Rubber Co., No.

Nov. 25, 2024) (mem. & ord) ($2,000 for citing nonexistent cases and quotations); Wadsworth, 348 F.R.D. at 498 ($3,000 for citing "hallucinated cases"); Mata, 678 F.Supp.3d at 466 ($5,000 for using AI to generate excerpt of nonexistent opinion); Mid Cent. Operating Eng'rs Health & Welfare Fund v.

What the text mentions

Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.

Where this fits

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More from Hawaii Intermediate Court of Appeals, from Hawaii, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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