State of Hawaii v. Cody Presti
Intermediate Court of Appeals of Hawaii · Aug 31, 2026
What happened in this matter?
Fabricated: Case Law | Opening Brief cited 'Stroud V people (Colo.)'; court's search returned zero appellate opinions from Colorado under that name. Outcome: Arguments supported by nonexistent authority were deemed waived; court declined to impose sanctions in this criminal direct appeal though noted sanctions were available under appellate rules.. The appellant's opening brief cited 95 authorities, of which the court could reliably identify only 41; eleven cited cases could not be located or were demonstrably incorrect/misattributed. The court found multiple citations were to nonexistent opinions or to reporter/volume numbers that corresponded to unrelated cases, treated arguments relying on those authorities as waived, and declined to apply civil Rule 11 sanctions on direct criminal appeal while noting HRAP Rules 30 and 51 could authorize sanctions in other circumstances. The court emphasized that fabricated citations undermine judicial integrity and waste resources.
- Why the court cared
- The structured public record identifies pro se and fake citations and records Arguments supported by nonexistent authority were deemed waived; court declined to impose sanctions in this criminal direct appeal though noted sanctions were available under appellate rules.. The linked source controls the precise reasoning and procedural context.
- Why it matters now
- This matter connects pro se and fake citations with Arguments supported by nonexistent authority were deemed waived; court declined to impose sanctions in this criminal direct appeal though noted sanctions were available under appellate rules. in Intermediate Court of Appeals of Hawaii. It provides a source-linked baseline for verification, supervision, and response controls.
Why this matter is tracked
Fabricated: Case Law | Opening Brief cited 'Stroud V people (Colo.)'; court's search returned zero appellate opinions from Colorado under that name. Outcome: Arguments supported by nonexistent authority were deemed waived; court declined to impose sanctions in this criminal direct appeal though noted sanctions were available under appellate rules.. The appellant's opening brief cited 95 authorities, of which the court could reliably identify only 41; eleven cited cases could not be located or were demonstrably incorrect/misattributed. The court found multiple citations were to nonexistent opinions or to reporter/volume numbers that corresponded to unrelated cases, treated arguments relying on those authorities as waived, and declined to apply civil Rule 11 sanctions on direct criminal appeal while noting HRAP Rules 30 and 51 could authorize sanctions in other circumstances. The court emphasized that fabricated citations undermine judicial integrity and waste resources.
This matter connects pro se and fake citations with Arguments supported by nonexistent authority were deemed waived; court declined to impose sanctions in this criminal direct appeal though noted sanctions were available under appellate rules. in Intermediate Court of Appeals of Hawaii. It provides a source-linked baseline for verification, supervision, and response controls.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Arguments supported by nonexistent authority were deemed waived; court declined to impose sanctions in this criminal direct appeal though noted sanctions were available under appellate rules.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
7 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Opening Brief cited 'Stroud V people (Colo.)'; court's search returned zero appellate opinions from Colorado under that name.
- Fabricated: Case Law | Opening Brief cited 'State v. Pune, 94 Hawaii 200 (2000)'; court found no such published opinion and Westlaw returned zero results for 'State v. Pune.'
- Fabricated: Case Law | Opening Brief cited 'State V. Ah Mook Sang' which Westlaw returned no results; court found no appellate opinion by that name.
- Fabricated: Case Law | Opening Brief cited 'State v. Eichman, 74 Wash. App. 479, 874 P.2d 646 (1994)'; court found the citation pointed to unrelated or different opinions and no matching authority supporting appellant's proposition.
- Fabricated: Case Law | Opening Brief cited 'State v. Washington, 125 Or. App. 406, 865 P.2d 474 (1993)'; court found the citation led to an unrelated case (State v. Nilsen) and the proposition cited contradicted Oregon precedent.
- Fabricated: Case Law | Opening Brief cited 'People v. Babich, 192 Cal. App. 4th 1423 (2011)'; court found the citation corresponded to a different reported sequence (192 Cal. App. 4th 1409) and the referenced proposition did not match.
- Fabricated: Case Law | Opening Brief cited 'State V. Alves, 45. Haw.296' but the reporter/volume corresponds to State v. Pokini, not an Alves opinion; court determined the relied-upon authority did not exist as cited.
Questions this record answers
- What happened in State of Hawaii v. Cody Presti?
- Fabricated: Case Law | Opening Brief cited 'Stroud V people (Colo.)'; court's search returned zero appellate opinions from Colorado under that name. Outcome: Arguments supported by nonexistent authority were deemed waived; court declined to impose sanctions in this criminal direct appeal though noted sanctions were available under appellate rules.. The appellant's opening brief cited 95 authorities, of which the court could reliably identify only 41; eleven cited cases could not be located or were demonstrably incorrect/misattributed. The court found multiple citations were to nonexistent opinions or to reporter/volume numbers that corresponded to unrelated cases, treated arguments relying on those authorities as waived, and declined to apply civil Rule 11 sanctions on direct criminal appeal while noting HRAP Rules 30 and 51 could authorize sanctions in other circumstances. The court emphasized that fabricated citations undermine judicial integrity and waste resources.
- Why does State of Hawaii v. Cody Presti matter for legal AI risk?
- This matter connects pro se and fake citations with Arguments supported by nonexistent authority were deemed waived; court declined to impose sanctions in this criminal direct appeal though noted sanctions were available under appellate rules. in Intermediate Court of Appeals of Hawaii. It provides a source-linked baseline for verification, supervision, and response controls.
- What does the public record establish about State of Hawaii v. Cody Presti?
- 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 State of Hawaii v. Cody Presti 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.
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