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Courts on AI / Fabricated or misquoted citations

Christ Apostolic Temple, Inc., Dwight Reed and Jordan Reed v. Demetrius Sinegal, et al.

Iowa Court of Appeals · State appellate courts · IA · · 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 admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.
Recorded conduct
A self-represented appellant filed a reply brief using nonexistent or hallucinated authorities and authorities used for propositions they did not support. — 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

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