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AI VORTEXLEGAL AI RISK INTELLIGENCE
CASE BRIEF / REVIEW PACKETAV-CB-1AZN52BGenerated September 10, 2026Evidence checked Sep 10, 2026
TRACKED PUBLIC MATTER

Keaau Development Partnership LLC v. Lawrence

Hawaii ICA · May 15, 2025

Jurisdiction
state
Court
Hawaii ICA
Record ID
keaau-development-partnership-llc-v-lawrence-2025-05-15
Observed outcome
The court imposed a $100 monetary sanction against counsel personally, payable to the Supreme Court Clerk, and required a declaration of payment.
Known monetary consequence
$100
ADVISOR READOUT

Why this matter warrants attention

The Hawaii Intermediate Court of Appeals sanctioned attorney James D. DiPasquale $100 for violating HRCP Rule 11 by filing a motion containing a fabricated case citation. The court held that the signing attorney is responsible for verifying the accuracy of all authorities, regardless of whether the drafting was delegated to a subordinate.

Why the decision-maker cared

The court reasoned that under HRCP Rule 11, an attorney must perform a reasonable inquiry into the validity of legal contentions. Citing a nonexistent case without attempting to read it to confirm its holding is not reasonable. The court emphasized that the signing attorney cannot delegate the duty to ensure a filing is factually and legally responsible to subordinates.

Why it matters now

Delegating briefs to per-diem attorneys does not shift the signer's duty to verify every citation before filing.

RECORDED ISSUES

Failure modes and consequences

  • Fake Citations
  • Bar Referral
  • Contract
  • Trial
  • Monetary
AI attribution
Implied
Recorded tool
AI (implied, unspecified)
Known monetary consequence
$100
Procedural posture
Order to show cause and subsequent imposition of sanctions by the Intermediate Court of Appeals of the State of Hawaii.
PRIMARY SOURCE

Damien Charlotin case archive

Publisher document archive. The recorded document is hosted in the upstream publisher archive.

Open underlying source

A recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.

EVIDENCE BOUNDARY

What this record does—and does not—establish

Counsel stated he did not personally use AI, but the court identified the error as a fabricated citation.

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.

Latest evidence review: Primary Document Verified (high confidence).

PRACTICAL REVIEW IMPLICATIONS

Controls suggested by the public record

  1. Verify the existence, citation, court, and precedential status of every authority before filing.
  2. Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
  3. Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
  4. Read the linked source and subsequent docket history before relying on this record for legal work.