What courts said about AI in June 2026

2026-06-26 · Supreme Court of Texas · Court rules adopted by opinion or order

The Texas Supreme Court preliminarily approves amendments to civil and appellate filing rules. Comments explain that the changes address improper AI use by reinforcing attorneys’ and self-represented parties’ obligation to verify authorities, quotations, and holdings before filing.

2026-06-26 · Ohio Court of Appeals, First Appellate District · Fabricated or misquoted citations

The Ohio First District Court of Appeals resolves post-divorce property disputes, denies Victoria Morgan’s request to sanction self-represented Mark Jones, and denies a vexatious-litigant motion. The court says Jones’s two phantom citations bear the hallmarks of AI hallucinations but predate its local AI rule.

2026-06-26 · Alabama Court of Civil Appeals · Fabricated or misquoted citations

The Alabama Court of Civil Appeals grants part of a mother’s mandamus petition. In dissent, Judge Bowden says the petition should be dismissed because the mother relied on AI-generated hallucinations and misrepresented real holdings, warning that granting relief leaves fake citations without repercussions.

2026-06-23 · Supreme Court of New York, Appellate Division, Second Department · Fabricated or misquoted citations

The New York Appellate Division, Second Department sanctions attorney Michael Sanders and Law Offices of Michael S. Lamonsoff, PLLC after an appellate brief used GenAI-assisted research. The court finds nonexistent cases, fictitious Court of Appeals quotations and misstatements, ordering $8,000 and $2,500 sanctions.

2026-06-22 · Court of Appeals of Indiana · Fabricated or misquoted citations

The Indiana Court of Appeals affirms multiple orders in Hoagland Family Limited Partnership’s sewer-system dispute with Clear Lake. While rejecting one appellate argument, the court says a Fox v. Fox citation and quotation did not exist, likely came from generative AI, and reminds counsel of candor duties.

2026-06-19 · U.S. District Court for the District of Columbia · Algorithms in criminal justice

The D.C. district court evaluates STRmix probabilistic-genotyping evidence among extensive pretrial motions in a robbery and carjacking prosecution. The opinion explains the software’s likelihood ratios and rules on admissibility limits for DNA testimony.

2026-06-18 · New York Court of Appeals · Algorithms in criminal justice

The New York Court of Appeals describes forensic software used to identify peer-to-peer CSAM sharing and later computer-forensics evidence. The court’s ineffective-assistance analysis turns on stipulations about digital evidence, possession, and mens rea.

2026-06-17 · Michigan Court of Appeals · Fabricated or misquoted citations

The Michigan Court of Appeals affirms denial of Joyce Barber’s new-trial motion but sanctions her counsel for AI-related citation failures. The court holds that repeated fabricated and unsupported authorities violated Michigan court rules, remands to determine defendant’s actual damages and expenses, and refers counsel for possible investigation.

2026-06-16 · Court of Appeals of Indiana · Fabricated or misquoted citations

The Indiana Court of Appeals affirms a custody order in Holstein v. Holstein and denies Mother’s request for $5,000 in sanctions. The court says Father’s counsel included citations from his client without verification, corrected them promptly, and receives a warning rather than a monetary sanction.

2026-06-15 · United States Court of Appeals for the Tenth Circuit · Fabricated or misquoted citations

On 2026-06-15, in Andria Borsody v. Frontier Heritage Communities, the Tenth Circuit affirmed dismissal and upheld the district court's admonition that the self-represented appellant verify case citations before relying on AI-assisted briefing. A self-represented appellant cited Alford v. City of Canon City even though the court found the authority did not exist.

2026-06-12 · Court of Appeals of Texas · Fabricated or misquoted citations

On 2026-06-12, in Shaddai Harris v. Nadia Lyotard and Mitchell Sadler, Court of Appeals of Texas struck the appellant's original briefs, required an amended brief, and then decided the appeal on the redrawn briefing. A self-represented appellant filed a reply brief using at least four nonexistent or hallucinated authorities and authorities used for propositions they did not support.

2026-06-12 · Supreme Court of New York · Fabricated or misquoted citations

On 2026-06-12, in Vargas v. MTA Bus Co, Supreme Court of New York amended its prior order and declined to attribute the non-existent citations in duplicated opposition papers to appellate counsel. Counsel filed opposition papers using nonexistent or hallucinated authorities.

2026-06-12 · United States District Court for the Southern District of New York · Fabricated or misquoted citations

On 2026-06-12, in Jason Wimberly v. Verizon New York Inc, the Southern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a reply brief using nonexistent or hallucinated authorities.

2026-06-11 · United States District Court for the Eastern District of Texas · Fabricated or misquoted citations

On 2026-06-11, in McCormick v. Texakoma Financial, the Eastern District of Texas publicly reprimanded plaintiff's counsel, imposed $6,000 in sanctions, ordered firmwide citation review, and required AI-focused CLE. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

2026-06-11 · Court of Appeal of California, First Appellate District · Fabricated or misquoted citations

On 2026-06-11, in Quinteros v. Harbor Distributing, LLC, the California First District Court of Appeal imposed $6,000 in sanctions payable to the court and referred counsel to the California State Bar. Counsel filed opposition papers using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

2026-06-11 · Arizona Court of Appeals, Division One · Fabricated or misquoted citations

On 2026-06-11, in Villanueva v. Bowers, Arizona Court of Appeals, Division One awarded $1 in costs or fees caused by the defective legal authorities. A self-represented appellant filed an opening brief using nonexistent or hallucinated authorities. The monetary component was $1.

2026-06-10 · Iowa Court of Appeals · Fabricated or misquoted citations

On 2026-06-10, in State of Iowa ex rel J.G. v. Mynesia A. Anderson, Iowa Court of Appeals dismissed the appeal after the appellant failed to comply with its order addressing fabricated authorities in her briefs. A self-represented appellant filed a petition using quotations that did not appear in the cited source and at least eight nonexistent or hallucinated authorities.

2026-06-10 · United States Bankruptcy Court for the Northern District of Indiana · Fabricated or misquoted citations

On 2026-06-10, in In re Garcia-Martz, the Northern District of Indiana Bankruptcy Court ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.

2026-06-10 · United States District Court for the Northern District of Illinois · Fabricated or misquoted citations

On 2026-06-10, in Ifeoma Delliane Chinedu Obi v. Cook County, Illinois, et al, the Northern District of Illinois struck the latest defective filing and imposed monetary sanctions for repeated AI-hallucinated arguments and cases. A self-represented litigant cited Andrade v. Arby Concessions, 88 F.4th 1014 (7th Cir. 2023) even though the court found the authority did not exist.

2026-06-10 · Court of Appeals of Georgia · Fabricated or misquoted citations

On 2026-06-10, in Henry County Schools et al. v. Grant et al, Court of Appeals of Georgia vacated the order denying dismissal of the Title VII claims and remanded for reconsideration using proper standards and real case law. The trial court's order relied on at least one nonexistent or hallucinated authority and authorities used for propositions they did not support.

2026-06-09 · United States District Court for the Eastern District of Pennsylvania · Fabricated or misquoted citations

On 2026-06-09, in Casey A. Gaddy v. Wood Brothers Bar, Inc., et al, the Eastern District of Pennsylvania admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant filed a motion using record or transcript quotations not found in the record, quotations that did not appear in.

2026-06-09 · United States District Court for the Southern District of New York · Fabricated or misquoted citations

On 2026-06-09, in LiveVideo.AI Corp. v. Redstone, the Southern District of New York awarded more than $85,000 in fees and costs and referred counsel to the district grievance committee. Counsel filed a motion using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.

2026-06-09 · United States District Court for the Middle District of Florida · Fabricated or misquoted citations

On 2026-06-09, in Leafwell, Inc. v. The Doc App, Inc, the Middle District of Florida declined to add new sanctions but warned counsel that the order could support future professional-discipline proceedings. Counsel filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

2026-06-09 · United States District Court for the District of Colorado · Fabricated or misquoted citations

On 2026-06-09, in Tlingit Haida Tribal Business Corporation v. OnePromom, the District of Colorado ordered plaintiff to show cause why the filing was not sanctionable and whether counsel complied with professional obligations. Counsel filed a motion using quotations that did not appear in the cited source.

2026-06-09 · United States District Court for the District of Arizona · Fabricated or misquoted citations

On 2026-06-09, in Perry v. Merrick Bank Corporation, the District of Arizona dismissed the complaint without leave to amend and noted the plaintiff's prior hallucinated citations in related litigation. A self-represented litigant filed a response using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.

2026-06-08 · District Court of Travis County, Texas, 250th Judicial District · Fabricated or misquoted citations

On 2026-06-08, in Erica Whitesock v. Bird Global, Inc., and The City of Austin, the Travis County district court granted the City of Austin's jurisdictional plea, dismissed those claims with prejudice, and awarded $10,000 in attorney fees. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.

2026-06-08 · United States District Court for the Western District of Tennessee · Fabricated or misquoted citations

On 2026-06-08, in Bailey v. Sedgwick Claims Management Services, Inc, the Western District of Tennessee required a corrected motion after counsel disclosed AI-hallucinated citations, but declined to impose sanctions at that point. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

2026-06-08 · United States District Court for the Northern District of Mississippi · Fabricated or misquoted citations

On 2026-06-08, in Withers v. City of Aberdeen, the Northern District of Mississippi revoked pro hac vice admission, disqualified resident counsel, fined counsel $8,000, and referred the matter to bar authorities. Counsel filed opposition papers using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

2026-06-08 · Minnesota Court of Appeals · Fabricated or misquoted citations

On 2026-06-08, in Young v. Young, Minnesota Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a brief using record or transcript quotations not found in the record, quotations that did not appear in.

2026-06-08 · United States District Court for the Northern District of Illinois · Fabricated or misquoted citations

On 2026-06-08, in Allison v. Shutterfly LifeTouch LLC, the Northern District of Illinois warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant cited || Misrepresented: Case Law | Plaintiff characterized Norberg v. Shutterfly as even though the court found the authority did not exist.

2026-06-05 · Kansas Court of Appeals · Fabricated or misquoted citations

On 2026-06-05, in Kendall E. Scheer v. Scheer Farms, LLC, Kansas Court of Appeals affirmed summary judgment, while a concurrence admonished the appellant over fake case citations and quotations in his brief. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.

2026-06-04 · Supreme Court of Oregon · Fabricated or misquoted citations

On 2026-06-04, in Mary McGreevy v. Adam Witkin, Supreme Court of Oregon struck the response to the petition for review, imposed a $500 sanction, and granted judicial notice. A self-represented appellant filed a response using nonexistent or hallucinated authorities. The monetary component was $500.

2026-06-04 · United States District Court for the Eastern District of New York · Fabricated or misquoted citations

On 2026-06-04, in Owens v. Select Portfolio Servicing, Inc, the Eastern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source and at least four nonexistent or hallucinated authorities.

2026-06-04 · Appellate Court of Maryland · Fabricated or misquoted citations

On 2026-06-04, in Lafaye B. Brown v. James E. Clarke, et al, Appellate Court of Maryland affirmed the foreclosure rulings and noted that the appellant's reply brief used a quotation found nowhere in Maryland or other case law. A self-represented appellant filed a reply brief using quotations that did not appear in the cited source.

2026-06-04 · Court of Appeals of Georgia · Fabricated or misquoted citations

On 2026-06-04, in Washington v. Washington, Court of Appeals of Georgia warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.

2026-06-04 · United States District Court for the District of Colorado · Fabricated or misquoted citations

On 2026-06-04, in Y.S. v. John Doe, et al, the District of Colorado warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant submitted a filing using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

2026-06-04 · United States Court of Appeals for the Fifth Circuit · Fabricated or misquoted citations

On 2026-06-04, in Kisha Peters v. Banner Health, the Fifth Circuit struck the defective appellate filings, admonished the appellant, and warned that additional violations could draw sanctions. A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

2026-06-03 · United States District Court for the Western District of North Carolina · Fabricated or misquoted citations

On 2026-06-03, in Wayne K. Smith, Sr. v. Polk County, et al, the Western District of North Carolina ordered plaintiff's counsel to show cause about two fabricated quotations and compliance with the court's AI-use standing order. Counsel filed an opening brief using quotations that did not appear in the cited source.

2026-06-03 · United States District Court for the Western District of Missouri · Fabricated or misquoted citations

On 2026-06-03, in Euphoric, LLC et al. v. Westport Community Improvement District, et al, the Western District of Missouri admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. Counsel filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

2026-06-02 · United States District Court for the Western District of Washington · Fabricated or misquoted citations

On 2026-06-02, in Fadi El Bitar v. Julio Hernandez, the Western District of Washington imposed a $1,000 monetary sanction for the defective legal authorities. Counsel filed a petition using quotations that did not appear in the cited source. The monetary component was $1,000.

2026-06-02 · United States District Court for the Western District of Tennessee · Fabricated or misquoted citations

On 2026-06-02, in Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al, the Western District of Tennessee ordered Reaves Law Firm to pay costs for improper citations and directed counsel to send the order to professional regulators. Counsel cited Press v. Vanderbilt University even though the court found the authority did not exist.

2026-06-02 · United States District Court for the Middle District of North Carolina · Fabricated or misquoted citations

On 2026-06-02, in Anthony Josue Grajales v. Santander Consumer USA Inc., et al, the Middle District of North Carolina sanctioned the plaintiff $120, stayed the case until payment, and required copies of cited authorities with future filings. A self-represented litigant filed a response using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities, and.

2026-06-02 · Missouri Court of Appeals · Fabricated or misquoted citations

On 2026-06-02, in Boatner v. Hickerson, Missouri Court of Appeals imposed a $10,000 monetary sanction for the defective legal authorities. A self-represented appellant cited Davis v. Bess even though the court found the authority did not exist. The monetary component was $10,000.

2026-06-02 · United States District Court for the Eastern District of Michigan · Fabricated or misquoted citations

On 2026-06-02, in Patrick C. Shaltry v. Donna Collins, et al, the Eastern District of Michigan magistrate judge recommended dismissal and noted a false Sixth Circuit citation while denying further relief. A self-represented litigant cited Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016) even though the court found the authority did not exist.

2026-06-01 · United States District Court for the Eastern District of Wisconsin · Fabricated or misquoted citations

On 2026-06-01, in Branden Driver v. CNA Financial Corporation et al, the Eastern District of Wisconsin warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and.

2026-06-01 · Supreme Court of New York · Fabricated or misquoted citations

On 2026-06-01, in Sharei Torah v. Hendel, Supreme Court of New York struck defendants' amended answer and counterclaims and awarded plaintiff costs and fees for responding to unsupported citations. A self-represented litigant cited Ennis v. Lessing even though the court found the authority did not exist.

2026-06-01 · United States District Court for the District of Massachusetts · Fabricated or misquoted citations

On 2026-06-01, in Richard A. Cole v. Midland States Bank, et al, the District of Massachusetts admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant filed a motion using authorities used for propositions they did not support and a nonexistent rule or legal standard.

2026-06-01 · United States Court of Appeals for the Seventh Circuit · Fabricated or misquoted citations

On 2026-06-01, in Heriberto Perez-Castillo v. Todd W. Blanche, the Seventh Circuit sanctioned counsel for appellate expenses, admonished him, and referred the matter for possible discipline. Counsel filed an opening brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and authorities used for propositions they did not support.