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Courts on AI / Fabricated or misquoted citations

Ex parte A.I.F.-H.

Alabama Court of Civil Appeals · State appellate courts · AL · · No. CL-2025-0966 · dissent

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.

Disposition
The court granted mandamus in part and denied it in part; the dissent would have dismissed the petition because of AI hallucinations and unsupported authority.
Recorded conduct
The dissent stated that four of five cases in the mother’s mandamus petition appeared to be AI hallucinations, and that two other real cases were misrepresented. The majority imposed no consequence for that issue. — outcome: noted, no consequence; actor: litigant in person
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

The mother primarily relied on AI-generated hallucinations and misrepresentations of holdings in real cases. Rule 21(a)(1)(F), Ala. R. App. P., requires petitioners to include “[a] statement of the reasons why the writ should issue, with citations to the authorities and the statutes relied on” in a petition for the writ of mandamus. Four of the five cases cited by A.I.F.-H. ("the mother") in her petition appear to be “hallucinations” from an online artificial-intelligence (“AI”) tool and misrepresentations of holdings in real cases. One “case,” cited as “Ex parte Holloway, 992 So. 2d 521, 524 (Ala. 2008),” does not exist -- the reporter citation is to a case styled Display South, Inc. v. Graphics House Sports Promos., Inc., 992 So. 2d 510 (La. Ct. App. 2008), a Louisiana case concerning a class-action lawsuit alleging violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227 et seq. The mother also provides a “quote” from Ex parte Siderius, 144 So. 3d 319 (Ala. 2013), purporting to represent our supreme court's holding in that case; however, the quoted material cannot be found in that case or, to my knowledge, in any other case. Two other cases the mother cited are real cases, but the holdings the mother attributed to them are not accurate representations of the discussion of the issues in those cases. Our supreme court recently dismissed an appeal as a sanction for the widespread, improper use of AI in the plaintiffs' briefs in Ibach v. Stewart, [Ms. SC-2025-0106, Apr. 24, 2026] ___ So. 3d ___, ___ (Ala. 2026).

Authorities cited in the passage: Rule 21(a)(1)(F), Alabama Rules of Appellate Procedure · Ex parte Siderius, 144 So. 3d 319 (Ala. 2013) · Ibach v. Stewart, Ms. SC-2025-0106 (Ala. Apr. 24, 2026)

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