Courts on AI / Fabricated or misquoted citations
In re Marriage of Dillon
California Court of Appeal, Fourth Appellate District, Division One · State appellate courts · CA · · No. D085064 · opinion
The California Court of Appeal affirms an order in Marriage of Dillon and addresses three miscited cases in the respondent’s self-represented brief. The court disregards arguments based on the hallucinated citations, declines sanctions because none were sought, and denies prevailing-party costs on appeal.
- Disposition
- The court affirmed the order, declined sanctions, but denied respondent prevailing-party costs because of hallucinated citations.
- Recorded conduct
- Self-represented respondent attributed quotations or propositions to Wilkison, Brown, and Iberti that did not appear in those opinions. — outcome: costs order; 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.
Wife miscited three cases in her respondent’s brief by attributing to them quotations or legal propositions that do not appear in the cited opinions.3 The miscitations appear to be the result of Wife’s use of generative artificial intelligence without sufficient verification. We have disregarded the arguments in Wife’s brief that are based on the miscited authorities.4 Husband “has considered, but chosen not, to seek sanctions for violations of the relevant rules of court.” (See rule 8.204(a)(1)(B) [requiring that assertions of law in a brief be supported by citation to legal authority]; Noland v. Land of the Free, L.P. (2025) 114 Cal.App.5th 426, 445 [“relying on fabricated legal authority is sanctionable”]; Sheerer v. Panas (2026) 119 Cal.App.5th 367, 371 [it is “a requirement of all attorneys and self-represented litigants responsible for briefs filed in this Court” to “verify citations”].) We decline to sanction Wife. We do, however, find it appropriate because of the hallucinated citations to deny her prevailing party costs on appeal.
Authorities cited in the passage: Wilkison v. Wiederkehr, 101 Cal.App.4th 822 (2002) · Brown v. Grimes, 192 Cal.App.4th 265 (2011) · In re Marriage of Iberti, 55 Cal.App.4th 1434 (1997) · Cal. Rules of Court, rule 8.204(a)(1)(B) · Noland v. Land of the Free, L.P., 114 Cal.App.5th 426 (2025) · Sheerer v. Panas, 119 Cal.App.5th 367 (2026) · Cal. Rules of Court, rule 8.278
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