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
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.
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.
Delegating briefs to per-diem attorneys does not shift the signer's duty to verify every citation before filing.
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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
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).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.