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Courts on AI / Fabricated or misquoted citations

In the Matter of the Estate of Kuerschner

Court of Appeals of Arizona · State appellate courts · AZ · · 2026 WL 619894 · No. No. 1 CA-CV 25-0491 PB · memorandum opinion

Arizona Court of Appeals on 2026-03-05 in In the Matter of the Estate of Kuerschner found the self-represented party's appellate briefs contained 25 made-up or substantially erroneous citations, including fake quotes and unsupported propositions. The court dismissed the appeal under ARCAP 25 and awarded appellee reasonable attorney fees and costs for repeated fabricated citations.

Disposition
The court dismissed the appeal under ARCAP 25 and awarded appellee reasonable attorney fees and costs for repeated fabricated citations.
Recorded conduct
The self-represented party's appellate briefs contained 25 made-up or substantially erroneous citations, including fake quotes and unsupported propositions. — outcome: costs order; 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.

1,200 documents, many of which are over a hundred pages result. long and were submitted after briefing was completed. We need not assume the duties of an advocate to search the record and support Stefanie's claims. See Adams v. Valley Nat'l Bank CONCLUSION of Ariz., 139 Ariz. 340, 343 (App. 1984). ¶14 We dismiss Stefanie's appeal under ARCAP 25 because ¶11 On top of that, Stefanie's briefs contain 25 citations that she continues to fabricate citations and omit record references are made up or contain substantial errors like fake quotes or despite our prior warning. unsupported propositions. For example: ¶15 Because counsel for James spent time and resources • Stefanie cites “Orlandini v. Crawford (Arizona Court of identifying Stefanie's violations, we award James his Appeals).” After diligent efforts, we cannot locate a case reasonable attorney fees and costs under ARCAP 25 upon bearing this name. compliance with ARCAP 21. See also A.R.S. § 12-349. • Stefanie quotes “Wallace v. Hon. Smith/Miller, 254 Ariz. 59, 61 ¶ 1 (2023)” as saying Rule 7 and § 12-2108 “together provide the exclusive framework for

Authorities cited in the passage: Orlandini v. Crawford (Arizona Court of Appeals) · Meara vacated sanctions; the court noted Takieh actually upheld sanctions and appellant · Orlandini v. Crawford · We need not assume the duties of an advocate to search the record and support Stefanie's claims. See Adams v. Valley Nat'l Bank CONCLUSION of Ariz · Wallace v. Hon. Smith

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