Courts on AI / Fabricated or misquoted citations

Andria Borsody v. Frontier Heritage Communities

United States Court of Appeals for the Tenth Circuit · Federal courts of appeals · 2026-06-15 · No. 25-3205 · order

On 2026-06-15, in Andria Borsody v. Frontier Heritage Communities, the Tenth Circuit affirmed dismissal and upheld the district court's admonition that the self-represented appellant verify case citations before relying on AI-assisted briefing. A self-represented appellant cited Alford v. City of Canon City even though the court found the authority did not exist.

Disposition: The court affirmed dismissal and upheld the district court's admonition that the self-represented appellant verify case citations before relying on AI-assisted briefing.
Recorded conduct: A self-represented appellant cited Alford v. City of Canon City even though the court found the authority did not exist. — outcome: warning; 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.

As we will discuss, the district court confirmed no such case exists and admonished Ms. Borsody to refrain from using AI when drafting legal documents without confirming the accuracy of citations. We too have confirmed “Alford v. City of Canon City” is not a real case. In October 2025, while Frontier’s motion to dismiss was still pending, Ms. Borsody moved a second time for entry of default under Rule 55(a). In the same motion, she sought Rule 11 sanctions against Frontier for filing “recycled procedural motions” that “clearly serve[d] no purpose but delay.” RI.116. This filing also included argument about the relationship between Frontier and Michaels. Ms. Borsody said her “formal onboarding, payroll, and benefits were handled by Michaels, but [she] physically worked at the Fort Leavenworth property controlled and managed by Frontier[.]” RI.117. Although “daily duties, discipline, and workplace rules were enforced by Frontier Heritage,” Michaels was—at least according to Ms. Borsody— responsible for “benefits and pay[.]” RI.117.

Authorities cited in the passage: Alford v. City of Canon City · Rule 55(a) · Rule 11

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.

United States court documents are public domain; the topic coding, disposition line and summary are SafeLegalAI's reading of the document for comparison, not a finding about any person named in it. This record summarises a public court document or official publication and reports what it says; SafeLegalAI makes no findings of its own. Individuals and organisations are named only as they appear in that public record. Anyone named may send a right of reply, correction or contextual update (for example an appeal, vacatur or later disposition) via /report; we add a dated note where appropriate. Reply or correct this record.

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub