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Courts on AI / Fabricated or misquoted citations

Washington v. Washington

Court of Appeals of Georgia · State appellate courts · GA · · No. A26A0506 · order

Fabricated or misquoted citationsGAI

On 2026-06-04, in Washington v. Washington, Court of Appeals of Georgia warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.

Disposition
The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities. — 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.

As an initial matter, we are troubled by Mother’s citation to fictitious cases and fictitious quotations throughout her appellate brief. “Such ‘hallucinated’ cases are typically a hallmark of the irresponsible use of regenerative artificial intelligence (A.I.)inlegaldrafting.”Slayv.Ross,379Ga.App.1,1(927SE2d 569)(2026).While Motherisprose,sheisnonethelessrequiredtofollowtherulesofthisCourt,andwe caution her that any future filings in this Court containing fictitious cases and/or fictitious quotations may result in the imposition of sanctions against her. See Court of Appeals Rule 7(e)(2) (“The panel of the Court ruling on a case, with or without motion, may by majority vote to impose a penalty not to exceed $10,000 against any party and/or a party’s counsel in any civil case in which there is a direct appeal, application for discretionary appeal, application for interlocutory appeal, or motion thatisdeterminedtobefrivolous.”);Modiv.India-Am.CulturalAss’n,367Ga.App. 572,574(2)(886SE2d378)(2023)(“Although[Appellant]isproceedingprose,[she] isnotrelievedof[her]obligationtoconformtothisCourt’srules.”)(quotationmarks omitted). AswehavejurisdictionofthisappealpursuanttoOCGA§5-6-34(a)(11),we hereby deny the Father’s motion to dismiss. Mother filed a motion to modify custody, and the trial order entered an order on February 13, 2024, which denied her motion to modify custody but modified the parenting plan, which included changing the exchange location for non-school days to both parents’ houses.

Authorities cited in the passage: Rule 7(e)(2)

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