Courts on AI / Fabricated or misquoted citations
In re W.B.
California Court of Appeal, Fifth District · State appellate courts · CA · · No. JD145421-00 · opinion
The California Court of Appeal, Fifth District on 2026-04-29 warned the self-represented mother to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in In re W.B. The self-represented mother filed an opening brief with one fabricated case citation.
- Disposition
- The court warned the self-represented mother to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
- Recorded conduct
- The self-represented mother filed an opening brief with one fabricated case citation. — 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.
DISCUSSION As a preliminary matter, we address mother’s statement in her opening brief that she used “something…on [her] phone” to draft her brief. Given the context of mother’s statement, and the content and style of the brief itself, we infer that mother may be referring to a generative Artificial Intelligence (AI) system. We accept that generative AI is a powerful tool, but advise that using it comes with risks, including that it could provide incorrect information and/or “hallucinated” citations. It appears to us that a substantial portion of mother’s brief may be made up of direct output from an AI system. 8.
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