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Courts on AI / Fabricated or misquoted citations

Fairrow v. Easten

Arizona Court of Appeals, Division Two · State appellate courts · AZ · · memorandum opinion

Fabricated or misquoted citations

The Arizona Court of Appeals affirms a family-law fee award and notes that self-represented appellant Brently Easten relied on Napp v. Napp, a case the court says does not exist at the cited location. The court suspects Breitbart-Napp was intended and declines appellate-fee sanctions.

Disposition
The court affirmed the fee award and declined to award appellate fees as a sanction.
Recorded conduct
Self-represented appellant cited Napp v. Napp for fee-award review, but the court found no such case at the provided citation. — 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.

One such authority is Napp v. Napp, which Easten cites for the proposition that an award must be supported by a record sufficient to permit meaningful review. But that case does not exist—at least not at the citation provided by Easten. We suspect he intended to cite Breitbart-Napp v. Napp, 216 Ariz. 74 (App. 2007). In that case we vacated the trial court’s fee award because of the stale nature of the financial information upon which it was based and the court’s apparent decision to make the award based upon which party prevailed on the merits, an improper basis under § 25-324. Breitbart-Napp, 216 Ariz. 74, ¶ 39. Neither of those considerations apply here. Appels-Meehan v. Appels, 167 Ariz. 182 (App. 1991), upon which Easten also relies, did not involve a review of a trial court’s award of attorney fees.

Authorities cited in the passage: Napp v. Napp · Breitbart-Napp v. Napp, 216 Ariz. 74 (App. 2007) · A.R.S. § 25-324 · Appels-Meehan v. Appels, 167 Ariz. 182 (App. 1991)

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