Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

without merit, as the statute contains no language terminating jurisdiction in the manner asserted. The petition included four additional inaccurate citations, none of which supported the propositions for which they were cited. The petition’s reliance on non-existent or hallucinated case citations strongly suggests that portions of the filing were generated using artificial intelligence (AI). HFCR Rule 11 requires a party to conduct a “reasonable inquiry” to ensure that a filing is “warranted by existing law.” HFCR Rule 11. When a party submits a filing that contains citations to non-existent cases, this conduct on its own constitutes a violation of HFCR Rule 11. The fake case citation makes clear that the party failed to conduct a reasonable inquiry into the validity of the legal authorities cited. This is because a check of the citation would have revealed that the case did not exist. To satisfy Rule 11’s duty of a “reasonable inquiry,” Petitioner was required to verify that each citation was accurate and that the cited authority supports the proposition asserted. Notably, free on-site access to legal research databases is available at the Hawaiʻi State Law Library. Reliance solely on AI-generated content to produce a case filing is inadequate because such content provides no assurance that the citations produced by it are valid or correctly described.

Authorities cited in the passage: HFCR Rule 11