Loading AI Vortex evidence…
Preparing the requested public record.
Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Keaau Development Partnership LLC v. Lawrence
Hawaii ICA · May 15, 2025
HI / stateEditorial impact: mediumfake citationsbar referralcontracttrial
Direct answer
What happened in this matter?
Fabricated: Case Law | Reynolds's memorandum cited a nonexistent case, 'Greenspan v. Greenspan,' to argue against the Forgay Doctrine; the court determined no Hawai‘i appellate decision by that title exists and that the pincites correspond to other cases (Roxas; Madison Capital; City of Boulder). Outcome: Monetary sanction against counsel personally; no disciplinary referral.
- Why the court cared
- The record concerns whether authorities presented to the decision-maker existed and could be verified. The tracked outcome is Monetary sanction against counsel personally; no disciplinary referral; the linked source controls the precise reasoning.
- Why it matters now
- Delegating briefs to per-diem attorneys does not shift the signer's duty to verify every citation before filing.
Why this matter is tracked
Fabricated: Case Law | Reynolds's memorandum cited a nonexistent case, 'Greenspan v. Greenspan,' to argue against the Forgay Doctrine; the court determined no Hawai‘i appellate decision by that title exists and that the pincites correspond to other cases (Roxas; Madison Capital; City of Boulder). Outcome: Monetary sanction against counsel personally; no disciplinary referral.
AI Use
Counsel filed a motion to dismiss appeal that cited “Greenspan v. Greenspan, 121 Hawai‘i 60, 71, 214 P.3d 557, 568 (App. 2009).” The court found that:No Hawai‘i case titled Greenspan v. Greenspan existsThe citations to “121 Hawai‘i 60” and “214 P.3d 568” were in fact to other real cases (Estate of Roxas v. Marcos and Colorado Court of Appeals cases), suggesting a garbled AI-generated fabricationCounsel admitted delegating the brief to a per diem attorney and failing to verify the citation before filing
Ruling/Sanction
$100 sanction imposed on counsel personallyPayment to be made to the Supreme Court Clerk of Hawai‘i within seven daysDiPasquale ordered to file a declaration attesting to payment.The amount reflects counsel’s candor and corrective measures, but the court noted that federal courts have imposed higher sanctions in similar cases.
Operational lesson
Delegating briefs to per-diem attorneys does not shift the signer's duty to verify every citation before filing.
Record details
HawaiiSingle-state evidence scope
CourtHawaii ICA
Jurisdictionstate
Circuit9th Circuit
DateMay 15, 2025
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeMonetary sanction against counsel personally; no disciplinary referral
Known amount$100
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Monetary sanction against counsel personally; no disciplinary referral
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Reynolds's memorandum cited a nonexistent case, 'Greenspan v. Greenspan,' to argue against the Forgay Doctrine; the court determined no Hawai‘i appellate decision by that title exists and that the pincites correspond to other cases (Roxas; Madison Capital; City of Boulder).
Questions this record answers
- What happened in Keaau Development Partnership LLC v. Lawrence?
- Fabricated: Case Law | Reynolds's memorandum cited a nonexistent case, 'Greenspan v. Greenspan,' to argue against the Forgay Doctrine; the court determined no Hawai‘i appellate decision by that title exists and that the pincites correspond to other cases (Roxas; Madison Capital; City of Boulder). Outcome: Monetary sanction against counsel personally; no disciplinary referral.
- Why does Keaau Development Partnership LLC v. Lawrence matter for legal AI risk?
- Delegating briefs to per-diem attorneys does not shift the signer's duty to verify every citation before filing.
- What does the public record establish about Keaau Development Partnership LLC v. Lawrence?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Keaau Development Partnership LLC v. Lawrence summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.