Skip to content

Courts on AI / Fabricated or misquoted citations

State v. Presti

Intermediate Court of Appeals of Hawaiʻi · State appellate courts · HI · · No. CAAP-24-0000826 · opinion

Fabricated or misquoted citations

The Hawaiʻi Intermediate Court of Appeals affirms a criminal judgment while documenting numerous nonexistent or misidentified cases in Cody Presti’s self-represented opening brief. The court explains sanction authority for fake citations but declines to apply civil Rule 11 procedures in the direct criminal appeal.

Disposition
The court affirmed the judgment and declined to sanction the self-represented criminal appellant for nonexistent citations.
Recorded conduct
Self-represented appellant cited 95 cases; 11 were unlocatable and six had citations leading to different cases, including State v. Alves, State v. Bonds, and State v. Pune. — outcome: warning; actor: litigant in person
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

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

We pause to note that Presti's Opening Brief is just the next example of the alarming rise of citations to fake cases by attorneys and self-represented litigants in this jurisdiction and nationally. See Stewart Yerton, AI in the Courtroom? Complaints About Misuse by Hawaiʻi Lawyers Growing, Honolulu Civ. Beat (July 30, 2025) ...; see generally AI Hallucination Cases, Damien Charlotin, https://www.damiencharlotin.com/hallucinations/ ... (aggregating AI hallucination cases internationally). This court has recently sanctioned attorneys and self-represented appellants in civil cases for citing nonexistent authority...

Authorities cited in the passage: State v. Alves · State v. Pokini, 45 Haw. 295, 367 P.2d 499 (1961) · State v. Bonds · Jackson v. DeWitt, 592 N.W.2d 262 (Wis. Ct. App. 1999) · State v. Pune · State v. Branch, 636 P.2d 421 (Or. Ct. App. 1981)

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub