Courts on AI / monthly digest
What courts said about AI in July 2026
43 court-authored documents filed this month that substantively discuss generative AI. Fabricated or misquoted citations 34 · Self-represented litigants using AI 5 · Algorithms in criminal justice 2 · AI-generated evidence and authentication 1 · Discovery and AI-assisted review 1.
- In re Mahar
· United States Bankruptcy Court for the Eastern District of Virginia · Fabricated or misquoted citations
The Eastern District of Virginia bankruptcy court dismisses Alicia Mahar’s adversary complaint for lack of jurisdiction. Footnotes note that counsel cited a nonexistent In re Coastal Carolina Fruit Company decision and supplied incorrect court, Westlaw, or date information for three other mortgage cases.
- Higgins v. State
· Texas Court of Appeals, Twelfth District · Fabricated or misquoted citations
The Texas Twelfth Court of Appeals affirms Kevin Higgins’s conviction. The opinion recounts defense counsel’s admission that an AI-produced evidentiary memorandum misstated case holdings because counsel did not read the cited cases, but holds Higgins did not establish Strickland prejudice.
- United States v. Karnezis
· United States District Court for the District of Oregon · Fabricated or misquoted citations
The District of Oregon partially suppresses statements in a criminal case. In resolving the Miranda arguments, the court notes that defense briefing supplied a quotation that does not appear in Smith and admonishes counsel, while recording counsel’s statement that the mistake was not caused by generative AI.
- Santana v. Shook Hardy & Bacon
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
The Southern District of New York compels arbitration and stays a pro se employment case. The opinion separately addresses defendants’ concern that Santana’s opposition used nonexistent case authority attributed to AI, declines sanctions for now, and warns that future inaccurate citations may be sanctioned.
- Al-Ali v. CVS Pharmacy, Inc.
· United States District Court for the Eastern District of Michigan · Fabricated or misquoted citations
The Eastern District of Michigan overrules arbitration-related objections and warns Natashah Al-Ali. The order identifies nonexistent cases and an inaccurate statutory quotation, says the factitious citations appear AI-created, and states that even one future factitious citation may trigger sanctions.
- Matter of The JAAW Group, LLC
· Government Accountability Office · Fabricated or misquoted citations
GAO dismisses JAAW’s bid protest as factually insufficient and separately addresses AI-associated citation problems. The decision notes one nonexistent GAO citation and one irrelevant Federal Circuit citation, declines sanctions because dismissal rests on other grounds, and warns future filings may be sanctioned.
- First Community Credit Union v. Smith
· Wisconsin Court of Appeals, District IV · Fabricated or misquoted citations
The Wisconsin Court of Appeals affirms in a credit-union dispute and denies a frivolous-appeal fee request. A footnote says Ashley Smith’s briefs contain false legal citations, warns against repetition, and cautions that generative AI can hallucinate nonexistent cases or misreport holdings.
- Carey v. Breakell
· United States District Court for the District of Utah · Fabricated or misquoted citations
The District of Utah grants transfer to Arizona and flags possible improper AI use in plaintiff’s opposition. The order says counsel cited two cases the court could not locate on Westlaw, quotes authority condemning fake opinions, and leaves the matter to the receiving judge.
- In the Interest of S.M.T. and S.J.T.
· Texas Court of Appeals, Fourteenth District · Fabricated or misquoted citations
The Fourteenth Court of Appeals affirms a child-custody modification judgment and sanctions Father’s lawyer. The court finds fabricated quotations from Harrison and Swim, unsupported assertions from Lenz and A.S., assumes AI hallucination rather than deliberate deception, and orders three additional hours of AI-focused CLE.
- In the Interest of Q.C. and P.C.
· Texas Court of Appeals, Second District · Fabricated or misquoted citations
The Texas Second Court of Appeals affirms a child-custody modification judgment on rehearing. The opinion notes Mother’s original brief cited a nonexistent case and that her counsel-filed amended brief cited nonexistent case portions and false quotations, but the court resolves the appeal on briefing and merits grounds.
- In re Firestar Diamond, Inc.
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
The Southern District of New York denies Nirav Modi’s motion for leave to appeal a bankruptcy order. The court notes Modi used an outside person and AI tool to format the motion, identifies a false Cohen quotation and unsupported AI-generated citations, and dismisses the action.
- Harris v. Bank of America
· United States District Court for the Northern District of Mississippi · Fabricated or misquoted citations
The Northern District of Mississippi dismisses a pro se FCRA suit without prejudice for lack of standing. A footnote identifies two Northern District opinions that the court could not locate, calls them likely AI-generated fictitious citations, declines immediate sanctions, and warns Harris.
- Cole v. Lee
· Appellate Court of Illinois, First District · Fabricated or misquoted citations
The Illinois First District strikes Tony Cole’s pro se brief and dismisses his appeal. The order identifies authorities that do not support cited propositions and incorrect case citations, says the inaccuracies improperly shifted research burdens to the court, and relies on repeated Rule 341 violations.
- Harding Place Multifamily Partners v. Robinson
· Court of Appeals of Tennessee · Fabricated or misquoted citations
The Tennessee Court of Appeals affirms a landlord-tenant judgment and disregards fabricated or inaccurate parts of Samuel Robinson’s pro se brief. The opinion says the brief bears AI hallmarks, identifies false case and statutory quotations, a fabricated Tennessee Supreme Court case, and unsupported legal assertions.
- Gragston v. Amazon LLC
· United States District Court for the Southern District of Ohio · Fabricated or misquoted citations
The Southern District of Ohio dismisses Gragston’s amended employment complaint but permits a motion for leave to amend. A footnote identifies a purported Sixth Circuit hostile-work-environment citation as AI-hallucinated and formally warns that future reliance may bring monetary sanctions or dismissal with prejudice.
- Mathis v. Mathis
· Florida Fourth District Court of Appeal · Self-represented litigants using AI
The Florida appellate court notes that a self-represented appellee cited two nonexistent cases. Without imposing sanctions, it disregards the phantom authority and reiterates that attorneys and pro se litigants remain responsible for verifying AI-assisted filings.
- Maloit v. Maloit
· United States District Court for the District of Colorado · Fabricated or misquoted citations
The District of Colorado magistrate judge recommends summary judgment and grants discovery-fee sanctions in part. The order separately finds Maloit’s briefs contain misquotations, misstatements, and seven nonexistent cases likely from generative AI, then orders her to show cause about additional sanctions.
- Robinson v. Oglala Sioux Tribe
· United States Court of Appeals for the Tenth Circuit · Fabricated or misquoted citations
The Tenth Circuit affirms dismissal of Shantell Robinson’s claims with prejudice as a Rule 11 sanction. The order describes nonauthentic evidence, at least four filings with nonexistent or misrepresented authority, and a new appellate brief citation to the nonexistent Reynolds v. Smith case.
- Transcontinental Realty Investors, Inc. v. Moos
· United States District Court for the Northern District of Texas · Fabricated or misquoted citations
The Northern District of Texas denies disqualification motions in a commercial dispute. The opinion notes briefing problems, including one nonexistent Northern District citation likely caused by imprudent generative-AI reliance, and admonishes pro hac vice counsel about responsible AI use and Rule 11 obligations.
- Owen v. Askew
· United States District Court for the District of Oregon · Fabricated or misquoted citations
The District of Oregon denies self-represented defendants’ dismissal, transfer, and anti-SLAPP motions. Before reaching the merits, the order records withdrawn and additional false citations in Askew’s briefing and warns all parties that future false or hallucinated citations may be sanctioned.
- McNeil v. Bisignano
· United States District Court for the District of Maine · Fabricated or misquoted citations
The District of Maine grants summary judgment to the Social Security Commissioner and dismisses Alexander McNeil’s amended complaint. A footnote flags several nonexistent or fabricated legal authorities in the pro se pleadings and cautions McNeil to personally verify each future citation.
- Campbell v. TidalHealth, Inc.
· United States District Court for the District of Maryland · Fabricated or misquoted citations
The District of Maryland denies discovery sanctions in a pro se employment case and addresses possible generative-AI misuse. The court says Campbell’s filings do not outright hallucinate cases but misdescribe Aguilar and Mancia, corroborating admitted tool use, and cautions that future errors may draw fees or sanctions.
- Scott v. Illinois Human Rights Commission
· Appellate Court of Illinois, First District · Fabricated or misquoted citations
The Illinois First District affirms dismissal of Kimberly Scott’s discrimination charge and sanctions attorney Mason Cole. The opinion says ChatGPT produced 10 false citations or quotations, fines Cole $15,000 at $1,500 per misstatement, and directs the clerk to send the opinion to the ARDC.
- Ruiz v. Magellan Financial & Insurance Services
· United States District Court for the District of Arizona · Fabricated or misquoted citations
The District of Arizona expands an AI show-cause inquiry against Elizabeth Tate. The order recounts Tate’s Claude AI workflow, finds that list-based cite checking missed false quotations in several filings, criticizes delegating whole-brief drafting to Claude, and requires a supplemental memorandum.
- Ally Bank v. Ngouambe
· Minnesota Court of Appeals · Fabricated or misquoted citations
The Minnesota Court of Appeals affirms summary judgment for Ally Bank. At the end of the opinion, the court defines fabricated authority, identifies three nonexistent citations and many unsupported legal propositions in Ngouambe’s pro se informal brief, and disregards them when evaluating the merits.
- Ponder v. BCG Equities, LLC
· United States District Court for the Eastern District of Michigan · Fabricated or misquoted citations
The Eastern District of Michigan resets a pro se FCRA case by striking pending motions and setting aside default. The order cautions both sides after a brief cites Antoine for a quotation and proposition not found there, warning that generative-AI phantom cases can trigger Rule 11 sanctions.
- In re A.P.
· Ohio Court of Appeals, Twelfth Appellate District · Self-represented litigants using AI
The Ohio appellate court pauses before the merits to address a father’s acknowledged AI-assisted brief. The court identifies erroneous citations, reminds parties that false authorities may lead to sanctions, and applies ordinary appellate standards to the self-represented parent.
- People v. Wright
· New York Supreme Court, Appellate Division, Fourth Department · Algorithms in criminal justice
The New York appellate court affirms a suppression ruling where officers heard a gunshot and then received a ShotSpotter activation. The opinion treats the activation as corroboration supporting reasonable suspicion for the ensuing pursuit and firearm recovery.
- LeDoux v. Outliers, Inc.
· United States District Court for the Western District of Washington · Fabricated or misquoted citations
The Western District of Washington sanctions Jocelyn Stewart in the LeDoux litigation. The order finds Stewart used ChatGPT and Claude without verifying outputs, causing dozens of false citations across briefs and expert reports, and imposes a $3,000 personal sanction plus future citation certifications.
- Graves v. Pacific Gas & Electric Co.
· United States District Court for the Eastern District of California · Fabricated or misquoted citations
The Eastern District of California recommends dismissing Graves’s utility-pole claims with leave to amend and denies e-filing. A footnote identifies two nonexistent California cases, notes that Pierce does not support the cited limitations point, and warns about AI research and Rule 11 sanctions.
- Almeida Porfirio v. Mullin
· United States District Court for the District of Columbia · Fabricated or misquoted citations
The District of Columbia district court transfers Catarina Almeida Porfirio’s visa case to the Northern District of Texas. The court says plaintiff’s opposition brief contains nonexistent quotations, nonexistent cases and misstatements of law bearing the hallmarks of reliance on an AI tool, but leaves any inquiry to the transferee court.
- Sherwin v. State of Iowa, Department of Criminal Investigation
· Iowa Court of Appeals · Self-represented litigants using AI
The Iowa Court of Appeals rejects self-represented plaintiffs’ attempt to strike opposing motions because defendants did not certify whether they used ChatGPT or other AI. The court says no disclosure rule was shown and AI-assisted research or drafting is not inherently improper.
- Gouldy v. Chiasson
· District Court of Appeal of Florida, Fourth District · Fabricated or misquoted citations
The Florida Fourth District Court of Appeal affirms a fee order against Rose Gouldy and separately orders her to show cause why she should not be barred from further pro se filings. The court says her brief uses phantom authority, record misstatements and fabricated quotations likely produced with AI.
- Figueroa Hernandez v. State
· Florida Third District Court of Appeal · Algorithms in criminal justice
The Florida appellate court discusses expert testimony comparing manual DNA interpretation with STRmix probabilistic genotyping. The court affirms after reviewing a Daubert hearing and the defense argument that newer software better suited mixed, low-level DNA profiles.
- Lampinen v. Borer
· Ohio Court of Appeals, Eleventh Appellate District · Self-represented litigants using AI
The Ohio appellate court sees signs that a self-represented brief relied improperly on AI tools, but it declines sanctions. The court cautions that lack of candor may be sanctionable and refuses to construct arguments for the appellant.
- Bryan v. City of Philadelphia
· U.S. Court of Appeals for the Third Circuit · AI-generated evidence and authentication
On 2026-07-17, the Third Circuit affirms dismissal of a civil-rights suit alleging police and prosecutors fabricated or altered body-camera footage with artificial intelligence. The court holds the appeal forfeited and, alternatively, agrees that Heck, limitations, and other grounds bar the claims.
- Webb v. Sullivan County Assessor
· Indiana Tax Court · Fabricated or misquoted citations
The Indiana Tax Court denies Chryshawna and Jeremy Webb’s pro se motion to supplement an administrative tax record. In a note on artificial intelligence, the court says cited rules did not support the Webbs’ propositions, admonishes them for likely generative-AI use, and imposes no further penalties.
- In re Estate of Pangelinan
· Supreme Court of Guam · Self-represented litigants using AI
The Supreme Court of Guam observes that two nonexistent citations in a self-represented probate appellant’s brief may be attributable to generative AI. Considering pro se status and a first appearance, it finds sanctions unwarranted but reiterates final-submission duties.
- Parnell v. Florida Department of Corrections
· United States Court of Appeals for the Eleventh Circuit · Fabricated or misquoted citations
The Eleventh Circuit affirms summary judgment for the Florida Department of Corrections and grants sanctions relief against Parnell’s counsel. The court strikes defective reply-brief material, awards fees for the sanctions motion, and refers counsel after finding two non-existent opinions and at least five non-existent quotations.
- Akerlund v. Atlas Air, Inc.
· United States Court of Appeals for the Eleventh Circuit · Fabricated or misquoted citations
The Eleventh Circuit affirms dismissal of claims against Atlas Air and Flight Services International while referring plaintiffs’ counsel Anthony F. Sabatini for discipline. The court says his opening and proposed reply briefs contained repeated hallucinated case citations and that unverified AI-generated briefing violated duties to clients and the court.
- Hulse-Gibson v. Hulse
· District Court of Appeal of Florida, Second District · Fabricated or misquoted citations
The Florida Second District Court of Appeal affirms orders against Cynthia Hulse-Gibson without comment. The panel separately cautions the self-represented appellant that her briefs contained mismatches among propositions, case names and citations, and warns that unverified generative-AI legal research can expose filers to sanctions.
- Leiske v. Kidd
· Court of Chancery of Delaware · Fabricated or misquoted citations
The Delaware Court of Chancery orders Richard P. Rollo and Richards, Layton & Finger to show cause over GenAI errors in an answering brief. The court says counsel did not verify citations, left fabricated legal synthesis in a corrected filing, and must address Rule 11 and firm-supervision issues.
- Schulte v. LinkedIn Corp.
· U.S. District Court for the Northern District of California · Discovery and AI-assisted review
On 2026-07-01, the Northern District of California resolves discovery disputes over LinkedIn’s use of Relativity aiR. The court permits search-string pre-culling before GenAI review and denies additional audit metrics, finding LinkedIn’s disclosures satisfied the interim ESI order absent a specific deficiency.