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Keaau Development Partnership LLC v. Lawrence

Court
Hawaii ICA
Jurisdiction
USA
Decided
2025-05-15
AI tool
Implied
Outcome
Monetary sanction against counsel personally; no disciplinary referral
Monetary penalty
100 USD

What was hallucinated

Fabricated: Case Law | Reynolds's memorandum cited a nonexistent case, 'Greenspan v. Greenspan,' to argue against the Forgay Doctrine; the court determined no Hawai‘i appellate decision by that title exists and that the pincites correspond to other cases (Roxas; Madison Capital; City of Boulder).

Details

AI UseCounsel filed a motion to dismiss appeal that cited “Greenspan v. Greenspan, 121 Hawai‘i 60, 71, 214 P.3d 557, 568 (App. 2009).” The court found that:No Hawai‘i case titled Greenspan v. Greenspan existsThe citations to “121 Hawai‘i 60” and “214 P.3d 568” were in fact to other real cases (Estate of Roxas v. Marcos and Colorado Court of Appeals cases), suggesting a garbled AI-generated fabricationCounsel admitted delegating the brief to a per diem attorney and failing to verify the citation before filingRuling/Sanction$100 sanction imposed on counsel personallyPayment to be made to the Supreme Court Clerk of Hawai‘i within seven daysDiPasquale ordered to file a declaration attesting to payment.The amount reflects counsel’s candor and corrective measures, but the court noted that federal courts have imposed higher sanctions in similar cases.

Sanction teardown · Hawaii ICA, USA · 2025-05-15

Keaau Development Partnership LLC v. Lawrence

What happened

In Hawaii ICA, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Reynolds's memorandum cited a nonexistent case, 'Greenspan v. Greenspan,' to argue against the Forgay Doctrine; the court determined no Hawai‘i appellate decision by that title exists and that the pincites correspond to other cases (Roxas; Madison Capital; City of Boulder).

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Monetary sanction against counsel personally; no disciplinary referral (monetary penalty: 100 USD.)

Additional detail

AI UseCounsel filed a motion to dismiss appeal that cited “Greenspan v. Greenspan, 121 Hawai‘i 60, 71, 214 P.3d 557, 568 (App. 2009).” The court found that:No Hawai‘i case titled Greenspan v. Greenspan existsThe citations to “121 Hawai‘i 60” and “214 P.3d 568” were in fact to other real cases (Estate of Roxas v. Marcos and Colorado Court of Appeals cases), suggesting a garbled AI-generated fabricationCounsel admitted delegating the brief to a per diem attorney and failing to verify the citation before filingRuling/Sanction$100 sanction imposed on counsel personallyPayment to be made to the Supreme Court Clerk of Hawai‘i within seven daysDiPasquale ordered to file a declaration attesting to payment.The amount reflects counsel’s candor and corrective measures, but the court noted that federal courts have imposed higher sanctions in similar cases.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/317/Keaau_Development_v._Lawrence_Hawai_USA_May_15_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/317/Keaau_Development_v._Lawrence_Hawai_USA_May_15_2025.pdf

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