Courts on AI / Fabricated or misquoted citations

State of Iowa ex rel J.G. v. Mynesia A. Anderson

Iowa Court of Appeals · State appellate courts · IA · 2026-06-10 · No. 25-1022 · order

On 2026-06-10, in State of Iowa ex rel J.G. v. Mynesia A. Anderson, Iowa Court of Appeals dismissed the appeal after the appellant failed to comply with its order addressing fabricated authorities in her briefs. A self-represented appellant filed a petition using quotations that did not appear in the cited source and at least eight nonexistent or hallucinated authorities.

Disposition: The court dismissed the appeal after the appellant failed to comply with its order addressing fabricated authorities in her briefs.
Recorded conduct: A self-represented appellant filed a petition using quotations that did not appear in the cited source and at least eight nonexistent or hallucinated authorities. — outcome: other; 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.

Her briefs also cited two Iowa cases that do not exist; the reporter citations provided are for other states and cases unrelated to the cited propositions. We have addressed this phenomenon—problematic ﬁlings apparently “written” by artiﬁcial intelligence (AI)—in other cases. See Nisland Asset Inv., LLC v. Gericke, No. 25-0659, 2026 WL 1162553, at *1 (Iowa Ct. App. Apr. 29, 2026); In re W.G., No. 25-1916, 2026 WL 892837, at *2–3 (Iowa Ct. App.Apr.1,2026);InreR.A.,No.24-1629,2025WL2793560,at*2–4(Iowa Ct.App.Oct.1,2025);Lukev.Dep’tofHealth&Hum.Servs.,29N.W.3d635, 636(IowaCt.App. 2025);Turnerv.Garrels,No.24-0895,2025WL2537738, at *1 n.1 (Iowa Ct. App. Sep. 4, 2025). Most pertinent here, using AI in legal matters carries the risk of AI“hallucinating” or fabricating legal authorities thatdonotactuallyexist.SeeThomasA.Mayes,ArtiﬁcialIntelligence,Special Education,and theLaw: Risks,Rewards,and OpportunitiesforLeadership, 20 J. Bus. & Tech. L. ... We have, in the recent past, stricken oﬀending portions of briefs and petitions containing a few AI-generated citations. See, e.g., W.G., 2026 WL 892837, at *3; In re R.A., 2025 WL 2793560, at *4. We decline to follow that path here for two reasons. First, the oﬀending parties in W.G. and R.A. both complied with our order and expressed remorse for submitting fabricated citations;Andersonhasdoneneither.Second,inbothofthosecaseswecould at least arguably sift out the hallucinated authorities and decide what remainedof properlegalargument;wecannotdosoheregiventhedepthand breadthof thefabricated casecitations.SeeNisland,2026WL 1162553,at*1. GivenAnderson’sfailuretocomplywithourorderorsupplyalegalargument upon which we could decide this appeal, we conclude the only available remedy is dismissal. Last, Anderson suggested in her ﬁling that we have ...

Authorities cited in the passage: LLC v. Gericke, No. 25-0659, 2026 WL 1162553, at *1 (Iowa Ct. App. Apr. 29, 2026)

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.

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