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Courts on AI / Fabricated or misquoted citations

Broyles v. McNeal

Court of Appeals of Georgia · State appellate courts · GA · · 2026 WL 1263356 · opinion

The Court of Appeals of Georgia on 2026-05-08 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Broyles v. McNeal. The self-represented party filed a brief with one fabricated case citation.

Disposition
The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct
The self-represented party filed a 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.

McNeal's brief argues that Broyles used a chatbot to prepare his brief. While there are incorrect citations in the brief, at least one is a correct citation. We caution parties that the products marketed to them as “artificial intelligence,” like calculators, can be useful tools, but any language-like strings of words or citation-like strings of numbers and letters provided therefrommustbeverifiedagainstactualauthorityandshould not be assumed to exist or be correct propositions of law or fact. That said, McNeal's response brief, which was drafted by a licensed attorney, contains no supporting citation to case law, noteventothestandardofreview,andcontainsonlystatutory authorityinresponsetotheissuesraisedbyBroyles. Theonly case law that McNeal references are those cited in Broyles's brief. The lack of a transcript only creates a presumption of regularity, not a requirement that we affirm if the legal basis is questionable.

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