Hawaii · state supreme court · 2026

Bryan v. Child Support Enforcement Agency

Hawaii Supreme Court, 30 March 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Haw.

  1. Court. Hawaii Supreme CourtCOURT
  2. Level. state supreme courtLEVEL
  3. Date. 30 March 2026DATED
  4. Docket. No. SCPW-26-0000169DOCKET
  5. Documents. one document, 4 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, 30 March 2026 · source · PDF · 5 pages

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.

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.

The fake case citation makes clear that the party failed to conduct a reasonable inquiry into the validity of the legal authorities cited. This 3 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.

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. Including fabricated citations not only violates HFCR Rule 11 but also undermines the integrity of the court by introducing false material into a process grounded in truth, verified facts, and actual legal precedent. Such conduct wastes the opposing party’s time and resources in investigating and exposing the inaccuracies, diverting attention from the merits of the case.

What the text mentions

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Where this fits

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More from Hawaii Supreme Court, from Hawaii, or from 2026. 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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