Skip to content

Courts on AI / Fabricated or misquoted citations

Broyles v. McNeal

Court of Appeals of Georgia · State appellate courts · GA · · 2026 WL 1263356 · No. A26A0384 · 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 judgment was vacated and remanded, the sanctions motion was denied, and the court cautioned parties to verify AI output.
Recorded conduct
McNeal argued Broyles used a chatbot, and the court noted incorrect citations in Broyles’s pro se brief. The court cautioned that AI-generated research must be verified. — 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.

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub