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Courts on AI / Self-represented litigants using AI

In re A.P.

Ohio Court of Appeals, Twelfth Appellate District · State appellate courts · OH · · 2026-Ohio-2862 · No. CA2025-12-011 · opinion

The Ohio appellate court pauses before the merits to address a father’s acknowledged AI-assisted brief. The court identifies erroneous citations, reminds parties that false authorities may lead to sanctions, and applies ordinary appellate standards to the self-represented parent.

Disposition
The court affirmed and warned that erroneous AI-assisted citations may be disregarded or sanctioned.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Before we consider Father's assignments of error, we first address his acknowledged reliance on artificial intelligence in drafting his brief. We note that several case citations in Father's brief were erroneous in that they led to miscited cases and cases that exist but stand for different legal propositions than what is represented. We remind all parties and attorneys who may appear before our court that false citations not only will be disregarded by this court, but may result in sanctions. Chasteen v. Lynch, 2024-Ohio- 5857, ¶ 50 (12th Dist.). App.R. 16(A)(7) requires that an appellant set forth "[a]n argument containing the contentions of the appellant with respect to each assignment of error presented for review and the reasons in support of the contentions, with citations to the authorities, statutes, and parts of the record on which the appellant relies." Father's status as a pro se litigant does not relieve him of his obligation to comply with the appellate rules because it is well established that pro se litigants are held to the same standard as all other litigants.

Authorities cited in the passage: Chasteen v. Lynch, 2024-Ohio-5857 · Ohio Appellate Rule 16(A)(7)

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