Courts on AI / Fabricated or misquoted citations
A.K. v. M.R.
Indiana Court of Appeals · State appellate courts · IN · · 2026 WL 672475 · No. No. 25A-PO-2249 · memorandum opinion
Indiana Court of Appeals on 2026-03-10 in A.K. v. M.R. found the self-represented party's appellate brief contained four citation defects, including 994 N.E.2d 228, 106 N.E.3d 400 and 212 N.E.3d 768, involving nonexistent authorities, mischaracterized authority. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.
- Disposition
- The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.
- Recorded conduct
- The self-represented party's appellate brief contained four citation defects, including 994 N.E.2d 228, 106 N.E.3d 400 and 212 N.E.3d 768, involving nonexistent authorities, mischaracterized authority. — 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.
the vulgar language used by M.R. in her signs, her conduct fails to rise to the level of a “credible threat” to establish names stated in the brief. 8 These errors could be chalked up harassment for the purposes of issuing a protection order. to mere carelessness, but we think it more likely that they are a The camera on M.R.’s house is situated in a place common result of legal research using generative artificial intelligence for a homeowner to be able to see who may be entering (“AI”). upon their property. A.K. did not prove by a preponderance of the evidence that the camera is meant to harass the victim [7] We recently observed that “[c]itations to fictitious, AI- or his family. generated authority is a growing problem nationwide” and that “[c]ourts have sanctioned both attorneys and pro se IT IS THEREFORE ORDERED, ADJUDGED AND litigants for including them in briefs.” Williams v. Kirch, DECREEED by the Court that the Petition for Order for 268 N.E.3d 284, 288 (Ind. Ct. App. 2025). “Judges must be Protection is hereby DENIED. able to rely on the authenticity of the authorities cited by the parties to make just decisions.” Id. Because M.R. does Appealed Order at 1-3. A.K. now appeals, pro se. not request any sanction or relief for this conduct, we deem it sufficient to admonish A.K. for his problematic citations shall grant relief necessary to bring about a cessation of the and caution him “against using AI to conduct legal research violence or threat of violence.” Id. 10 without independently verifying the citations generated.” Id. [11] In reviewing a trial court's judgment regarding a [8] A.K.’s overarching argument is that the trial court erred protective order, “we neither reweigh the evidence nor resolve in denying his petition for a civil protective order against questions of credibility.” N.E. v. L.W., 130 N.E.3d 102, M.R. Civil protective orders are governed by the Civil 107 (Ind. Ct. App. 2019). “We consider only the probative Protection Order Act (“the Act”), Indiana Code Chapter evidence and reasonable inferences that support the trial 34-26-5, which we construe to promote the “protection and court's judgment.” Id. We will reverse the judgment only if safety of all victims of harassment in a fair, prompt, and it is clearly erroneous. Id. “A judgment is clearly erroneous effective manner” and the prevention of future harassment. when a review of the record leaves us with a firm conviction
Authorities cited in the passage: 994 N.E.2d 228 · 106 N.E.3d 400 · 212 N.E.3d 768 · Williams v. Kirch · N.E. v. L.W