**Judge Jill Otake sits on the U

Judge Jill Otake sits on the U.S. District Court for the District of Hawaii — one of only two federal districts in the country that requires AI disclosure across the entire court. Appointed by President Trump in 2020, she handles federal cases in a district that made an early, comprehensive move on AI regulation. Hawaii's district-wide General Order 23-1 applies to every judge on the bench, including Judge Otake.

What practitioners need to know: if you're filing anything in the District of Hawaii, you must disclose the use of AI in preparing your submission. This isn't an individual judge's standing order — it's a court-wide requirement. Hawaii's approach is one of the most aggressive in the federal system, and the Hawaii Supreme Court's AI Committee issued its final report in December 2025 with recommendations to expand these requirements further.

Hawaii's District-Wide AI Disclosure Requirement: General Order 23-1

On November 14, 2023, the four judges of the U.S. District Court for the District of Hawaii issued General Order 23-1, requiring any counsel or pro se party that submits any filing or submission generated by an AI platform to disclose that fact. Judge Leslie Kobayashi initially led the charge, and the full bench adopted the requirement. This makes Hawaii one of only two federal districts (along with Nebraska) with a court-wide AI disclosure mandate. The order applies to Judge Otake's courtroom automatically — there's no need to check individual standing orders. If AI was used at any stage of preparing your filing, you must disclose it.

The Hawaii Supreme Court AI Committee and Its Impact

The Hawaii Supreme Court established a Committee on Artificial Intelligence and the Courts in 2024, co-chaired by Associate Justice Vladimir Devens and Circuit Judge John Tonaki. The committee's final report, issued December 2025, includes recommendations for expanding AI disclosure requirements. The proposed approach would require any attorney or self-represented party to include a declaration that AI was used, that the party has verified the accuracy of legal authorities cited, and that the filing complies with professional responsibility rules. While these recommendations primarily target state courts, they signal the direction Hawaii's entire judicial system is heading — and create expectations that affect federal practitioners filing before Judge Otake.

Judge Otake's Background and Judicial Profile

Before her appointment, Otake served as a state circuit court judge in Hawaii's First Circuit and worked in private practice. She is the first woman of Japanese descent to serve as a federal district judge in Hawaii. Her docket includes civil rights cases, federal criminal matters, and disputes involving Hawaii's unique legal landscape — including native Hawaiian rights and military-related litigation. The District of Hawaii is a small court with only four active judges, meaning each judge handles a broad range of case types. Practitioners should expect Judge Otake to enforce the district's AI disclosure requirement consistently across all case categories.

Practical Compliance Steps for Filing Before Judge Otake

Step 1: Include an AI disclosure in every filing. Hawaii's General Order 23-1 requires it — no exceptions. If AI was used at any stage, state that fact. If AI was not used, you're not required to make a negative disclosure, but some practitioners do as a precaution. Step 2: Verify every citation through traditional legal research tools. The December 2025 committee report specifically recommends requiring attorneys to verify the accuracy of legal authorities. Step 3: Include a brief statement confirming that a licensed attorney reviewed all AI-generated content. Step 4: Do not input confidential client information into public AI tools. The SDNY Heppner ruling shows these communications may not be privileged. Step 5: Keep records of which AI tools were used and how outputs were verified.

Hawaii vs. Other Districts: Why This Approach Matters

Hawaii's court-wide approach contrasts sharply with districts like N.D. California (judge-by-judge patchwork), SDNY (model certification with individual adoption), and D.D.C. (AI Taskforce still developing rules). By making disclosure mandatory for the entire court, Hawaii eliminated the compliance guesswork that plagues multi-judge districts. The December 2025 committee report suggests Hawaii will go even further — potentially requiring affirmative declarations of AI use and citation verification in every filing. For national practitioners who may appear in Hawaii on a one-off basis, this is a critical difference. Don't assume your home district's rules apply — Hawaii's are stricter.

The Bottom Line: Hawaii has a court-wide AI disclosure requirement — General Order 23-1 applies to every filing before Judge Otake. Disclose AI use, verify all citations, confirm attorney review of AI-generated content, and keep records. This is one of the strictest federal AI compliance environments in the country.