Courts on AI / Fabricated or misquoted citations
State of Hawaiʻi v. Cody Presti
Intermediate Court of Appeals of Hawaiʻi · State appellate courts · HI · · No. CAAP-24-0000826 · opinion
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 relied on multiple nonexistent or mismatched appellate cases, including State v. Pune and State v. Alves. — 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.
Of the eleven cases this court was unable to locate, six cases include citations that indicate a volume and reporter that correspond with a different case entirely: • On page 8 of the Opening Brief, Presti relies on “State V. Alves, 45. Haw.296,” but that citation leads to an unrelated case, State v. Pokini, 45 Haw. 295, 367 P.2d 499 (1961). • On page 17 of the Opening Brief, Presti relies on “State v. Bonds, 592 N.W.2d 262 (Minn. 1999),” but that citation leads to an unrelated case in another jurisdiction, Jackson v. DeWitt, 592 N.W.2d 262 (Wis. Ct. App. 1999). • On pages 28-29 of the Opening Brief, Presti relies on “State v. Pune, 94 Hawaiʻi 200 (2000),” but that citation leads to a table of fourteen unreported opinions that does not include State v. Pune. A Westlaw search of “State v. Pune” returns zero results in any jurisdiction. ... In these instances, the relied upon authority simply does not exist. 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.
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)