Courts on AI / Fabricated or misquoted citations

Christ Apostolic Temple, Inc. v. Sinegal

Court of Appeals of Iowa · State appellate courts · IA · 2026-05-27 · No. No. 24-1896 · opinion

On 2026-05-27, in Christ Apostolic Temple, Inc., Dwight Reed and Jordan Reed v. Demetrius Sinegal, et al, Iowa Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a reply brief using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Disposition: The court affirmed and reminded Sinegal to verify all authorities if he used generative AI.
Recorded conduct: The self-represented appellant’s appellate and reply briefs cited nonexistent cases and cases that did not support the propositions asserted. The court affirmed and warned him to verify citations. — 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.

Sinegal’s appellate and reply briefs contain citations to cases that do not exist or donotstandforthepropositionforwhichtheyarecited. Thissuggeststhepossibilitythat he used generative artiﬁcial intelligence to prepare his briefs. If that is the case, we again “stress that self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artiﬁcial intelligence tools to prepare trial or appellate court ﬁlings.” Luke v. Dep’t. of Health and Human Servs., 29 N.W.3d 635, 636 (Iowa Ct. App. 2025). When considering whether Sinegal established excusable neglect, relevant considerations include timeliness of Sinegal’s ﬁlings,“whether [he] intendedtodefend,whether[he]assertedameritoriousdefenseingoodfaith, andwhether[he]ignoredorwillfullydeﬁedtherulesof procedure.” Id. The district court’s ruling took these considerations into account, and we agree with its analysis and conclusions. Accordingly, we aﬃrm without further opinion. Iowa Ct. R. 21.26(1)(d)(e) (authorizing memorandum opinions when“[a] full opinion would not augment or clarify existing case law”). AFFIRMED.

Authorities cited in the passage: Luke v. Dep’t. of Health and Human Servs., 29 N

Court document: iowacourts.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
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 located 2026-09-08 at www.iowacourts.gov; quoted passage confirmed. Re-coded from the document 2026-09-08 (independent second read).

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