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Courts on AI / Fabricated or misquoted citations

Boettcher v. Boettcher

Arizona Court of Appeals, Division One · State appellate courts · AZ · · No. 1 CA-SA 26-0121 · opinion

Fabricated or misquoted citations

The Arizona Court of Appeals grants partial special-action relief in a contempt dispute and addresses a quotation in Father’s filing. The court says neither cited case contains the quoted jurisdictional rule, it cannot find the language in Arizona law, strikes the false quotation, and declines sanctions.

Disposition
The court accepted special action jurisdiction, granted relief in part, and struck an apparently false quotation.
Recorded conduct
Petitioner’s filing attributed a jurisdictional quotation to two cases, but neither case contained it and the court could not find it in Arizona law. — outcome: other; actor: lawyer
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.

Father contends the superior court both lacked jurisdiction to hold him in contempt and abused its discretion by finding him in contempt. He also contends the court imposed improper sanctions. ... In making his jurisdictional argument, Father said, “Arizona appellate courts have consistently held that a trial court may not hold a party in contempt for violating a parenting plan that was never ordered. Without a valid court order, contempt is legally impossible.” He cited two cases for the quote, neither of which contains that language. And we could not find it in any Arizona case. We strike the apparently false quotation. Matter of Est. of Acciavatti, 1 CA-CV 25-0606 PB, 2026 WL 2041963, at *2, ¶ 9 (App. July 15, 2026). But because we identified no additional citation concerns, and opposing counsel raised none (including this one), we decline to impose sanctions. Id. at *4, ¶ 18 (“citing a hallucinated case in a legal filing is sanctionable conduct.”).

Authorities cited in the passage: Matter of Estate of Acciavatti, 2026 WL 2041963 (Ariz. App. July 15, 2026)

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