Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi
SC Hawaiʻi · Mar 30, 2026
- Jurisdiction
- state
- Court
- SC Hawaiʻi
- Record ID
- megan-e-bryan-v-child-support-enforcement-agency-state-of-hawaiʻi-2026-03-30
- Observed outcome
- Petition denied; petitioner issued a formal warning regarding future compliance with Rule 11.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Reporter-number mismatches are the single fastest tell of an AI hallucination — check the volume, not just the name.
Failure modes and consequences
- Pro Se
- Fake Citations
- Family
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Original proceeding for a writ of mandamus and emergency motion for stay; petition denied.
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
The court stated the reliance on hallucinated citations suggests the use of AI.
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.
- 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.