Courts on AI / Fabricated or misquoted citations
Sheerer v. Panas
Court of Appeal of the State of California, First Appellate District, Division Four · State appellate courts · CA · · --- Cal.Rptr.3d ----, 2026 WL 776268 · No. A171804 · opinion
On 2026-03-19, California Court of Appeal, First District reversed the child-support order but declined monetary sanctions after the self-represented respondent admitted AI-caused fake citations and quotations. A self-represented party submitted an appellate brief with two false quotations and fabricated or nonexistent authorities, including In re Marriage of Thomson and Keitel v. Heubel, supra.
- Disposition
- The court reversed and remanded the child-support order and disregarded/struck Panas's respondent's brief and declaration to the extent they relied on fabricated authority.
- Recorded conduct
- Panas's respondent's brief attributed quotes to published cases in which no such quote appears, cited cases that do not exist, and cited real authorities for topics they did not discuss. — outcome: filing struck; 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.
Panas cited at least two cases 1119 [“ ‘Honesty in dealing with the courts is of paramount that do not exist: “In re Marriage of Thomson (1984) 157 importance, and misleading a judge is, regardless of motives, Cal.App.3d 568, 578” and “Marriage of Mendlowitz (2019) a serious offense’ ”].) We further caution that our redress Cal.App.5th 990.” He further fabricated quotes that appear for false and missing citations is not limited to disregarding nowhere in the (real) cases cited. In his declaration “clarifying a brief. “We may impose monetary sanctions pursuant to facts” filed in this Court after Sheerer filed a motion to our own motion for unreasonable violations of the rules strike respondent's brief, Panas explained that his “error” in governing appeals.” (Keitel v. Heubel, supra, 103 Cal.App.4th providing fake quotations and citing nonexistent case law was at p. 340; Noland, supra, 114 Cal.App.5th at p. 442; Rule caused by his use of an AI tool and his failure to verify his 8.276(a)(4).) However, given Panas's admission of his error citations. He averred that he “did not knowingly submit false and considering that it would not be in the
Authorities cited in the passage: In re Marriage of Thomson (1984)
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