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Courts on AI / Fabricated or misquoted citations

Nisland Asset Investment, LLC v. Carissa Ann Gericke

Iowa Court of Appeals · State appellate courts · IA · · 2026 WL 1162553 · No. 25-0659 · opinion

Fabricated or misquoted citations

The Iowa Court of Appeals on 2026-04-29 deemed issues waived where the appellant relied on nonexistent or irrelevant authorities instead of valid supporting law in Nisland Asset Investment, LLC v. Carissa Ann Gericke. The self-represented appellant filed a brief with two fabricated case citations and one mischaracterized case citation.

Disposition
The court deemed issues waived where the appellant relied on nonexistent or irrelevant authorities instead of valid supporting law.
Recorded conduct
The self-represented appellant filed a brief with two fabricated case citations and one mischaracterized case citation. — outcome: other; 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.

903(2)(a) (8) (requiring for each issue “[a]n argument containing the appellant's contentions and the reasons for them with citations to the authorities relied on” and warning that “[f ]ailure to cite authority in support of an issue may be deemed waiver of that issue”). To the contrary, Gericke repeatedly cited two cases that do not exist. And she cited a third case that does exist but has nothing to do with the proposition for which she cites it or any issue in this case. It thus appears likely that she misused an artificial intelligence tool when preparing her brief. We recognize that Gericke is representing herself. “But we do not have a double standard for those represented by counsel and those who are unrepresented—we expect all to follow our procedures. ” Locher & Davis, PLC v. Ruth F.

Authorities cited in the passage: PLC v. Ruth F.

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