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Courts on AI / Fabricated or misquoted citations

Kendall E. Scheer v. Scheer Farms, LLC

Kansas Court of Appeals · State appellate courts · KS · · No. 129,066 · memorandum opinion

Fabricated or misquoted citationsGAI

On 2026-06-05, in Kendall E. Scheer v. Scheer Farms, LLC, Kansas Court of Appeals affirmed summary judgment, while a concurrence admonished the appellant over fake case citations and quotations in his brief. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.

Disposition
The court affirmed summary judgment, while a concurrence admonished the appellant over fake case citations and quotations in his brief.
Recorded conduct
A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple 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.

I would, however, address the appellant's use of several fake case citations in his brief. An appellate brief containing nonexistent case citations or fake legal authority needlessly undermines the validity of a party's arguments. Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 448-49 (S.D.N.Y. 2023). Here, the appellant's brief—as noted by the appellee—contains several fake case citations in support of his arguments. It is unclear whether the fake cases were the result of fabrications on the part of artificial intelligence. See United States v. Hayes, 763 F. Supp. 3d 1054, 1064-65 (E.D. Cal. 2025) (describing characteristics of "hallucinated case" citations generated by artificial intelligence). Regardless, we should disregard any of the appellant's arguments supported by nonexistent cases because "[a] fake opinion is not 'existing law' and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law." Mata, 678 F. Supp. 3d at 461.

Authorities cited in the passage: Mata v. Avianca · See United States v. Hayes, 763 F

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