Keaau Development Partnership LLC v. Lawrence
Intermediate Court of Appeals of the State of Hawai'i · Haw. Ct. App. · Hawaii bar guidance
Verified May 1, 2026
- Citation
- Keaau Dev. P'ship LLC v. Lawrence, No. CAAP-24-0000494 (Haw. Ct. App. May 15, 2025)
- Decided
- May 15, 2025
Summary
Attorney James D. DiPasquale, representing appellee Annaleine Melicia Reynolds, filed a motion to dismiss citing Greenspan v. Greenspan, 121 Hawai'i 60, 214 P.3d 557 (App. 2009), a nonexistent decision. The panel (Acting Chief Judge Leonard, Judges Hiraoka and McCullen, with the order authored by Judge Hiraoka) determined the volume and page citations actually corresponded to unrelated Hawai'i and Colorado opinions and that no Hawai'i appellate decision titled Greenspan v. Greenspan exists. DiPasquale stated in a declaration that a per diem attorney drafted the motion and that he had not personally used AI but had failed to verify the citations before signing.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $100
What sanction did the court impose?
$100 sanction imposed personally on DiPasquale under HRCP Rule 11(b)(2), made applicable on appeal by HRAP Rule 2.1(a), payable to the Chief Clerk of the Hawai'i Supreme Court within seven days, with a declaration of payment due within the same period. The order forbids reimbursement from the client and warns of additional sanctions for noncompliance. No disciplinary referral.
Why does Keaau Development Partnership LLC v. Lawrence matter for law firms using AI?
Keaau is the first published Hawai’i appellate sanction for a fabricated citation, and it lands in a jurisdiction whose courts had until now stayed quiet on the AI hallucination issue. The order is notable on two counts: the sanctioned attorney maintained he did not personally use AI, instead blaming a trusted per diem drafter, and the panel rejected delegation as a defense by quoting Pavelic & LeFlore on the signing attorney’s nondelegable duty. Managing partners should read the $100 figure not as leniency but as a deliberately calibrated entry point: the court’s footnote benchmarks federal sanctions in the $1,000 to $5,000 range and signals that Hawai’i’s tariff will rise on repeat conduct.