AI VORTEXLEGAL AI RISK
AI visibilityConsultingSearch free
Public trackerCorpus refreshed Aug 9, 2026 · Latest decision Aug 6, 2026Public incidents are risk signals, not usage-adjusted rates
HomeCasesMegan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi
Evidence review: primary document verified. The linked primary document was extracted and checked with page-level evidence locators.
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passes the current publication gate; that is not a legal-editorial review or a guarantee that every field has been independently verified.
Corpus matter record

Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi

SC Hawaiʻi · Mar 30, 2026

SC / stateEditorial impact: lowpro sefake citationsfamilytrialWarning
Direct answer

What happened in this matter?

The court issued a formal warning to the petitioner regarding the submission of fabricated case citations, which it attributed to the likely use of AI. The court explicitly cautioned that future violations of Hawaiʻi Family Court Rule 11, which mandates reasonable inquiry into legal authorities, may result in monetary sanctions.

Why the court cared
The court reasoned that the petitioner violated HFCR Rule 11 by failing to conduct a reasonable inquiry into the validity of cited authorities. It determined that the inclusion of non-existent cases undermines the integrity of the judicial process and wastes resources, necessitating a formal warning.
Why it matters now
Reporter-number mismatches are the single fastest tell of an AI hallucination — check the volume, not just the name.

Why this matter is tracked

The Supreme Court of Hawaiʻi denied a pro se petition for a writ of mandamus after discovering the petitioner included multiple fabricated case citations. The court identified that the petitioner cited 'State v. Burdett' at 63 Haw. 357, which actually corresponds to 'State v. Masaniai,' a case unrelated to the petitioner's jurisdictional arguments. The court noted that the inclusion of non-existent or hallucinated citations strongly suggests the use of artificial intelligence. The court cautioned the petitioner that such conduct violates Hawaiʻi Family Court Rule 11, which requires reasonable inquiry into the validity of legal authorities. The court warned that future non-compliance with Rule 11 could result in formal sanctions, including the assessment of attorney fees.

Operational lesson

Reporter-number mismatches are the single fastest tell of an AI hallucination — check the volume, not just the name.

Record details

South CarolinaSingle-state evidence scope
Explore SCOpen its source-linked jurisdiction page and related matters.
CourtSC Hawaiʻi
Jurisdictionstate
Circuit4th Circuit
DateMar 30, 2026
AI
AI toolAI (unspecified)
Party typePro Se Litigant
OutcomePetition denied; petitioner issued a formal warning regarding future compliance with Rule 11.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

implied

The court stated the reliance on hallucinated citations suggests the use of AI.

Procedural posture

Original proceeding for a writ of mandamus and emergency motion for stay; petition denied.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

2 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Petitioner cited non-existent 'State v. Burdett' as a 1981 opinion at 63 Haw. 357; the actual case at that citation is State v. Masaniai, 63 Haw. 354, 628 P.2d 1018 (1981), which does not address family court jurisdiction. Court found the citation fabricated and unsupported.
  2. Fabricated: Case Law | Petition included four additional inaccurate or non-existent case citations that did not support the propositions for which they were cited; court characterized these as hallucinated citations.

Questions this record answers

What happened in Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi?
The court issued a formal warning to the petitioner regarding the submission of fabricated case citations, which it attributed to the likely use of AI. The court explicitly cautioned that future violations of Hawaiʻi Family Court Rule 11, which mandates reasonable inquiry into legal authorities, may result in monetary sanctions.
Why does Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi matter for legal AI risk?
Reporter-number mismatches are the single fastest tell of an AI hallucination — check the volume, not just the name.
What does the public record establish about Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi?
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 Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi 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.

Jurkowski v. BerkowitzSC DC · Apr 21, 2026same jurisdiction · pro se + fake citationsNelson L. Bruce v. The United StatesD. South Carolina · Feb 9, 2026same jurisdiction · pro se + fake citationsCherleatha B. v. Frank BisignanoD. South Carolina · Dec 29, 2025same jurisdiction · pro se + fake citationsMohamed Ali v. Saeed OsmanNorth Dakota SC · Aug 6, 2026pro se + fake citations · same recorded tool: AI (implied, unspecified)Morgan v. JonesOhio · Jun 26, 2026pro se + fake citations · same recorded tool: AI (implied, unspecified)Dorothea Bell v. Kelly BellSC Pennsylvania · May 11, 2026pro se + fake citations · same recorded tool: AI (implied, unspecified)