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Courts on AI / Fabricated or misquoted citations

WRI Summit REIT LP v. Kuerschner

Arizona Court of Appeals, Division One · State appellate courts · AZ · · No. 1 CA-CV 25-0854 · memorandum opinion

The Arizona Court of Appeals dismisses Stefanie Kuerschner’s appeal and awards appellate fees and costs. The court says her brief lacked record citations, repeatedly misquoted or misstated cases, included one unlocatable case, and repeated citation problems despite earlier warnings about AI-related errors.

Disposition
The court dismissed the appeal under ARCAP 25 and awarded appellees reasonable appellate fees and taxable costs.
Recorded conduct
Self-represented appellant filed briefs with false quotations, unsupported propositions, and an unlocatable Arizona case despite prior warnings. — outcome: dismissal; 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.

Stefanie’s opening brief does not include a single citation to the record. Her opening brief also consistently misquotes cases and cites cases for propositions either not mentioned or directly contradicted by the case. And one case she cites appears not to exist. ... On page 27, the brief quotes State ex rel. Dep’t of Econ. Sec. v. Burton, 205 Ariz. 27, 30, ¶ 14 (App. 2003) as saying that an appellate court will find an abuse of discretion if a ruling was “manifestly unreasonable, or exercised on untenable grounds, or for untenable reasons.” But Burton contains none of that language. ... On page 48, the brief cites Cruz v. Superior Court (Ramirez), 172 Ariz. 462, 464 (App. 1992). We cannot locate a case with this name in the Arizona appellate courts. ... These citation errors are consistent with the misuse of generative AI. ... Dismissal of Stefanie’s appeal is warranted under ARCAP 25 because she continued to violate ARCAP 13 despite receiving repeated warnings about its requirements and of the consequences for failing to comply.

Authorities cited in the passage: State ex rel. Department of Economic Security v. Burton, 205 Ariz. 27 (App. 2003) · Bennett v. Baxter Group, Inc., 223 Ariz. 414 (App. 2010) · Brown v. U.S. Fidelity & Guaranty Co., 194 Ariz. 85 (App. 1998) · Cruz v. Superior Court (Ramirez), 172 Ariz. 462 (App. 1992) · Takieh v. O'Meara, 252 Ariz. 51 (App. 2021) · ARCAP 13 · ARCAP 25 · Matter of Estate of Acciavatti, 2026 WL 2041963 (Ariz. App. July 15, 2026)

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