Courts on AI / Fabricated or misquoted citations
Olbera v. Sykes
Court of Appeals of Indiana · State appellate courts · IN · · 2026 WL 860644 · No. 25A-JP-2005 · opinion
On 2026-03-30, Indiana Court of Appeals reached the merits despite briefing defects and warned that the self-represented brief included an apparently hallucinated Indiana case. A self-represented party submitted a brief with fabricated or nonexistent authorities, including Pavan v. Smith. The warning applied to later filings in the same case.
- Disposition
- The court reversed the trial court's paternity and dissolution rulings in part and remanded with instructions while deciding the appeal on the merits despite issues in Sykes's pro se brief.
- Recorded conduct
- Sykes's pro se appellee brief failed to include record citations in the statement of facts, failed to support arguments with relevant authority, and cited one seemingly hallucinated case, S.S. v. D.M., 150 N.E.3d 663 (Ind. Ct. App. 2020). — outcome: noted, no consequence; 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.
Sykes defends against this appeal pro se. “It is well settled that pro se litigants are held to the same legal standards as licensed attorneys” and must accept the consequences of their failure to follow established rules of procedure. Basic v. Amouri, 58 N.E.3d 980, 983 (Ind. Ct. App. 2016), reh'g denied. Although we've identified multiple issues with Sykes’ brief, such as her failure to include citations to the record in her statement of facts, her failure to support her arguments with citations to relevant authority, and a citation to one seemingly hallucinated case (S.S. v. D.M., 150 N.E.3d 663 (Ind. Ct. App. 2020)), “we prefer to decide issues on the merits” and her noncompliance with our appellate rules has not been “so substantial as to impede our consideration of the issues[.]”