Courts on AI / Fabricated or misquoted citations

Scheer v. Scheer Farms, LLC

Court of Appeals of the State of Kansas · State appellate courts · KS · 2026-06-05 · No. No. 129,066 · concurrence

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 panel affirmed summary judgment; the concurrence would also affirm based on appellant’s fake citations.
Recorded conduct: The pro se appellant’s brief contained several fake case citations and fake legal authority. The majority affirmed on the merits; the concurrence imposed no sanction. — 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.

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

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
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 not obtained 2026-09-08: court site blocks automated access (checked www.kscourts.gov) (checked www.kscourts.gov). Re-coded from the document 2026-09-08 (independent second read).

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