AI Disclosure Rules in the District of Hawaii

The District of Hawaii, based in Honolulu, is the sole federal district court for the state. Hawaii's geographic isolation, unique cultural context, and diverse economy -- spanning tourism, military operations, and Native Hawaiian rights litigation -- give this court a distinctive character. Notably, the District of Hawaii is one of the few federal courts that has already taken concrete action on AI disclosure, making it a leader in the Pacific region.

AI Disclosure Rules in the District of Hawaii

The District of Hawaii has an active AI disclosure requirement. Judge Leslie Kobayashi issued a standing order requiring disclosure of AI use in court filings, mirroring the prototype established by Judge Brantley Starr in the Northern District of Texas. This makes Hawaii one of the early adopters of formal AI governance in the federal court system.

Judge Kobayashi's order requires parties to disclose when generative AI was used in preparing court filings and to certify that the content has been verified for accuracy by a human. This is not advisory guidance -- it is a binding requirement for cases before her court.

The March 2026 NYC Bar Association study found that 41.7% of federal courts have no meaningful AI governance. Hawaii is not in that group. While the rule applies to specific judges rather than being a district-wide mandate, its existence puts all Hawaii practitioners on notice that the court takes AI use seriously.

The 9th Circuit, which oversees Hawaii, has been active on technology issues broadly. Several other 9th Circuit districts -- including the Northern District of California -- have judges with individual AI orders. The circuit-wide trajectory is toward greater AI oversight.

Individual Judge Standing Orders

Judge Leslie Kobayashi has a standing order specifically addressing AI use in court filings. The order requires parties to disclose generative AI use and certify that all AI-generated content was reviewed and verified by a human attorney. This order follows the model established by Judge Brantley Starr's 2023 standing order in the Northern District of Texas, which became the national template.

With over 300 federal judges nationwide now maintaining individual AI standing orders, Judge Kobayashi's order positions the District of Hawaii as part of the first wave of courts to formalize AI requirements. For any case assigned to Judge Kobayashi, compliance is mandatory. For cases assigned to other judges in the district, check individual practices carefully -- the presence of one formal order often signals that others are considering similar requirements.

Key AI Cases in DHI

The District of Hawaii has not produced a major AI sanctions case. The landmark precedents come from the mainland: Mata v. Avianca (SDNY, 2023) is the foundational case on AI citation fabrication, and the Couvrette case established the high-water mark with $109,700 in AI-related sanctions.

But Hawaii's proactive approach through Judge Kobayashi's standing order means the district is positioned to enforce consequences quickly if an AI-related issue arises. The order's existence creates a clear standard -- if you fail to disclose AI use or submit unverified content in her courtroom, the path to sanctions is straightforward.

What Attorneys in DHI Should Do

**Comply with Judge Kobayashi's standing order in full.** If your case is assigned to Judge Kobayashi, you must disclose any generative AI use and certify that all content has been human-verified. This is not optional.

**Check every other judge's individual practices.** Even if your case is not before Judge Kobayashi, other Hawaii judges may have similar expectations or may adopt formal orders. Review the court's website before every filing.

**Verify all citations with particular attention to Hawaii-specific law.** Hawaii has unique statutory and common law traditions, including Native Hawaiian rights, land tenure law, and water rights. AI tools trained primarily on mainland case law may produce inaccurate or incomplete citations for Hawaii-specific issues.

**Use enterprise legal AI tools over consumer chatbots.** In a district with an active AI standing order, the distinction between professional legal AI tools and consumer chatbots matters. Enterprise tools that source from verified legal databases reduce (but do not eliminate) the risk of hallucinated citations.

**Build disclosure language into your filing templates.** Since Hawaii has an active AI requirement, create a standard disclosure paragraph or certification that you can include with every filing. Make it part of your process, not an afterthought.

The Bottom Line

The District of Hawaii is ahead of the curve on AI governance. Judge Kobayashi's standing order puts this court among the leaders nationwide, and it signals that Hawaii's bench takes AI accuracy seriously. Practitioners who ignore this requirement risk sanctions in a court that has already drawn the line.

With over $145,000 in AI sanctions imposed in Q1 2026 across federal courts, and the 9th Circuit moving toward greater AI oversight, Hawaii's proactive stance is the future of federal practice. Compliance is not just about following the local rule -- it is about demonstrating the kind of professional competence that the courts are increasingly demanding.