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Courts on AI / Fabricated or misquoted citations

Hampton v. Lofton

Arizona Court of Appeals, Division One · State appellate courts · AZ · · No. 1 CA-CV 25-0650 FC · memorandum opinion

Fabricated or misquoted citations

On 2026-03-31, Arizona Court of Appeals, Division One affirmed and denied costs while noting that both self-represented appellate briefs contained hallucinated or unsupported citations. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities and mischaracterized authorities. The court resolved the merits while identifying the defective legal research.

Disposition
The court affirmed and denied costs while noting that both self-represented appellate briefs contained hallucinated or unsupported citations.
Recorded conduct
The appellate brief used fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — outcome: other; 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.

argument because he has shown no error—neither cumulative nor singular. ¶15 It’s worth noting that though Father urges us to disregard Mother’s brief for failing to include citations to the record or legal authority as required by ARCAP 13, Father’s opening brief contained only minimal citations to the record, some of which were hallucinated, supra ¶ 10, and that both his opening and reply briefs contained legal citations that either do not support his positions or appear to be fictitious. See ARCAP 13(a)(7), (d) (requiring citations of legal authorities and references to the record). As for Father’s request that we award him his costs, we deny his request since Father has not succeeded on appeal. As the successful party on appeal, Mother is awarded her costs upon compliance with ARCAP 21. CONCLUSION ¶16 We affirm. MATTHEW J. MARTIN • Clerk of the Court FILED: JR

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