Courts on AI / Fabricated or misquoted citations

Kalonji v. State

Court of Appeals of Indiana · State appellate courts · IN · 2026-05-26 · No. 25A-XP-2508 · opinion

On 2026-05-26, in Jean-Paul B. Kalonji v. State of Indiana, Indiana Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant cited Taylor v. State, 133 N.E.3d 708 (Ind. Ct. App. 2019) even though the court found the authority did not exist.

Disposition: The court denied judicial notice, declined to consider constitutional claims based on extra-record material, affirmed denial of expungement relief, and admonished Kalonji about AI-generated authorities.
Recorded conduct: The pro se appellant used a fabricated quotation from Monfort, cited a Taylor citation that did not correspond to the decision, and referenced a nonexistent statute. The court affirmed and admonished him. — 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.

Given Kalonji’s citations to nonexistent legal authorities and to authentic legal authorities for propositions they do not support, we find it likely that Kalonji used generative artificial intelligence (AI) to draft his briefs

Authorities cited in the passage: Supreme Court. Kalonji v. State · Basic v. Amouri, 58 N

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document Official copy not obtained 2026-09-08: Indiana Decisions host timed out while checking robots/search/document API; official document was not fetched (checked public.courts.in.gov). Re-coded from the document 2026-09-08 (independent second read).

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