Bryan v. Child Support Enforcement Agency

• Court: Hawaii Supreme Court
• Decided: March 30, 2026
• Docket: SCPW-26-0000169
• Status: Published

Opinion

Electronically Filed Supreme Court SCPW-XX-XXXXXXX 30-MAR-2026 11:39 AM Dkt. 12 ODDP

SCPW-XX-XXXXXXX

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI

MEGAN E. BRYAN, Petitioner,

vs.

CHILD SUPPORT ENFORCEMENT AGENCY, STATE OF HAWAIʻI; FAMILY COURT OF THE FIRST CIRCUIT, STATE OF HAWAIʻI, Respondents.

ORIGINAL PROCEEDING (CASE NO. 1UF201006070)

ORDER DENYING PETITION (By: McKenna, Acting C.J., Eddins, Ginoza, and Devens, JJ., and Circuit Judge Morikawa, assigned by reason of vacancy)

On March 9, 2026, Petitioner Megan E. Bryan filed a

“Verified Petition for Writ of Mandamus & Emergency Motion for

Stay of April 1, 2026 Hearing.”

For the reasons set forth below, the court denies the

petition without prejudice to Petitioner seeking relief from the

Family Court. The court also cautions Petitioner that she must

comply with Rule 11 of the Hawaiʻi Family Court Rules (eff. 2022), which requires a party to provide the court with accurate

representations in all submissions.

Rule 11 of the Hawaiʻi Family Court Rules (HFCR) provides,

in pertinent part:

The signature of an attorney or party constitutes a certificate by the signer that the signer has read the pleading, motion, or other document; that to the best of the signer’s knowledge, information, and belief formed after reasonable inquiry it is well grounded in fact and is warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law, and that it is not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation. If a pleading, motion, or other document is not signed, it shall be stricken unless it is signed promptly after the omission is called to the attention of the pleader or movant. If a pleading, motion, or other document is signed in violation of this Rule, the court, upon motion or upon its own initiative, shall impose upon the person who signed it, a represented party, or both, an appropriate sanction, which may include an order to pay to the other party or parties the amount of the reasonable expenses incurred because of the filing of the pleading, motion, or other document, including a reasonable attorney’s fee.

HFCR Rule 11 (emphases added).

The Hawaiʻi Family Court Rules are adopted under the Hawaiʻi

Rules of Appellate Procedure (HRAP) whenever applicable. HRAP

Rule 2.1(a) (eff. 2010). Because Petitioner seeks a writ of

mandamus arising from a Family Court matter, see HRAP Rule 21

(eff. 2010), HFCR Rule 11 governs the filings she has submitted

to this court.

Here, Petitioner’s submissions contained multiple

inaccurate case citations and failed to explain the factual

basis for several assertions. For example, Petitioner cited

2 “State v. Burdett” as a 1981 opinion in Volume 63 of West’s

Hawaiʻi Reports at page 357. Petitioner relied on this citation

to argue that under Hawaiʻi Revised Statutes (HRS) § 576B-205

(2018), the Family Court lacks jurisdiction to enforce a child

support order because her child is now an adult. Petitioner’s

citation to Burdett is incorrect. The actual case appearing at

that citation is State v. Masaniai, 63 Haw. 354, 357, 628 P.2d

1018, 1021 (1981), a case which does not address family court

jurisdictional issues.

Petitioner’s argument under HRS § 576B-205 is likewise

without merit, as the statute contains no language terminating

jurisdiction in the manner asserted. The petition included four

additional inaccurate citations, none of which supported the

propositions for which they were cited.

The petition’s reliance on non-existent or hallucinated

case citations strongly suggests that portions of the filing

were generated using artificial intelligence (AI).

HFCR Rule 11 requires a party to conduct a “reasonable

inquiry” to ensure that a filing is “warranted by existing law.”

HFCR Rule 11. When a party submits a filing that contains

citations to non-existent cases, this conduct on its own

constitutes a violation of HFCR Rule 11. The fake case citation

makes clear that the party failed to conduct a reasonable

inquiry into the validity of the legal authorities cited. This

3 is because a check of the citation would have revealed that the

case did not exist.

To satisfy Rule 11’s duty of a “reasonable inquiry,”

Petitioner was required to verify that each citation was

accurate and that the cited authority supports the proposition

asserted. Notably, free on-site access to legal research

databases is available at the Hawaiʻi State Law Library.

Reliance solely on AI-generated content to produce a case filing

is inadequate because such content provides no assurance that

the citations produced by it are valid or correctly described.

Including fabricated citations not only violates HFCR Rule

11 but also undermines the integrity of the court by introducing

false material into a process grounded in truth, verified facts,

and actual legal precedent. Such conduct wastes the opposing

party’s time and resources in investigating and exposing the

inaccuracies, diverting attention from the merits of the case.

It also wastes judicial resources by requiring judges and court

staff to verify citations and address misconduct, thereby

reducing the time available to address other matters.

Petitioner is advised that any future failure to comply

with HFCR Rule 11 may result in sanctions, including an award of

reasonable attorney fees incurred by the opposing party in

responding to filings containing inaccurate or unsupported

citations.

4 Based on the record, Petitioner has not demonstrated a

clear and indisputable right to relief. See Womble Bond

Dickinson (US) LLP v. Kim, 153 Hawaiʻi 307, 319, 537 P.3d 1154,

1166 (2023). The petition is denied without prejudice to

Petitioner seeking relief from the Family Court. A copy of this

order shall be filed by the clerk in 1UF201006070.

DATED: Honolulu, Hawaiʻi, March 30, 2026.

/s/ Sabrina S. McKenna

/s/ Todd W. Eddins

/s/ Lisa M. Ginoza

/s/ Vladimir P. Devens

/s/ Trish K. Morikawa