Valencia / Case Lombardi (1st Cir. Haw.) sanctions matter
First Circuit Court of Hawaii (Honolulu) · Haw. Cir. Ct. · Hawaii bar guidance
Verified May 1, 2026
- Filing date
- December 16, 2025
Summary
Honolulu Civil Beat reported in May, July, and December 2025 that Mark G. Valencia, a partner at Honolulu firm Case Lombardi, supervised an associate (Christilei Hessler) who used a generative AI tool to draft a brief in a civil matter pending before Judge Jordon Kimura in the First Circuit Court of Hawaii. The brief contained fabricated citations. Opposing counsel Bosko Petricevic identified the issue. At hearing, Judge Kimura found a violation of Hawaii Rules of Civil Procedure Rule 11 and indicated he would set sanctions at the conclusion of the underlying civil matter. The underlying case caption and civil number are not disclosed in publicly available coverage; the firm has not posted a public statement.
- AI tool:
- AI (unspecified generative tool)
What is the current procedural posture?
Pending as of 2026-05-01. Judge Kimura found a Rule 11 violation but deferred the sanctions order to the conclusion of the underlying civil matter, so the operative sanctions ruling has not yet issued. The Hawaii Supreme Court Committee on Artificial Intelligence and the Courts' December 16, 2025 final report (SCMF-24-0000305) referenced a Hawaii Circuit Court matter in which sanctions were under consideration; local coverage attributes that reference to this matter. When Judge Kimura's sanctions order issues, it will be the first published Hawaii Circuit Court order resolving an AI-fabricated-citation matter.
Why does Valencia / Case Lombardi (1st Cir. Haw.) sanctions matter matter for law firms using AI?
The Valencia matter is the highest-profile pending Hawaii AI-citation case and the matter most likely referenced in the Hawaii Supreme Court Committee on AI’s December 2025 recommendation that the Court consider adopting a state-court AI-disclosure rule mirroring the federal District of Hawaii’s General Order 23-1. For Hawaii firms, the practical signal is that the supervisory exposure under HRPC Rule 5.3 reaches the partner (Valencia) for the associate’s (Hessler) AI-driven verification failure, and that the Rule 11 finding was made before sanctions were determined, meaning that even a “we’ll see what the sanction is” deferred posture leaves the conduct finding on the public record and citable in subsequent matters and in carrier-renewal disclosures.
Sources
Primary sources
Further reading
- https://www.civilbeat.org/2025/12/hawaii-supreme-court-current-ai-rules-are-enough/
- https://www.civilbeat.org/2025/07/ai-in-the-courtroom-complaints-about-misuse-by-hawaii-lawyers-growing/
- https://www.civilbeat.org/2025/05/ai-hallucination-hawaii-attorney-fake-case/
- https://caselombardi.com/mvalencia.html
- The underlying civil case caption and First Circuit Court civil number have not been located in publicly available sources. The Hawaii eCourt Kokua public-access portal (jimspss1.courts.state.hi.us:8080) and Hoohiki (hoohiki.courts.hawaii.gov) returned ECONNREFUSED from the verification IP on 2026-05-01, consistent with runner-IP blocking; portal access from a residential IP via a browser session may yield the docket. Recheck before publication of any major analytical piece relying on this entry.
- The Hawaii Supreme Court Committee on AI final report PDF (SCMF-24-0000305) was retrieved and locally text-extracted on 2026-05-01; the report references First Circuit and Maui matters but does not name 'Valencia,' 'Case Lombardi,' or 'Kimura' in extracted body text. The attribution of the report's general 'Hawaii Circuit Court matter' reference to this specific matter is reported by Civil Beat and is not confirmable from the report's own text.
- The Hawaii Office of Disciplinary Counsel (odchawaii.com) returned ECONNREFUSED from the verification IP; the Hawaii State Bar Association directory (hsba.org) redirected to a 404. Whether ODC has opened a complaint against Valencia or Hessler is not confirmable from public sources reviewed.
- A separate, related Hawaii AI matter exists at Case Lombardi: attorney Kaʻōnohiokalā J. Aukai IV before Judge Kelsey Kawano in Maui Circuit Court (Civil Beat, Dec 2025). The Aukai matter is not the subject of this entry but is documented in the project's docs/case-audit-2026-04-24.md as a separate Tier 2 candidate.
- Sanctions order pending; update this entry within one week of Judge Kimura's eventual sanctions ruling, including primary-source citation and amount.