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.