Courts on AI / Fabricated or misquoted citations
Landmark Development Group, LLC v. Lonnie LuPardus
Kansas Court of Appeals · State appellate courts · KS · · No. No. 128,180 · memorandum opinion
Kansas Court of Appeals on 2026-02-13 in Landmark Development Group, LLC v. Lonnie LuPardus found the self-represented party's expert submission contained three citation defects, including Meadors v. Feltor, Edwards v. Scholtzs and Wilson v. Gutschenritter, involving incorrect statutory or rule text. The court deemed the arguments unsupported or waived because the cited authorities were defective.
- Disposition
- The court affirmed the landlord-tenant judgment and deemed arguments relying on nonexistent or detached authority waived or abandoned.
- Recorded conduct
- LuPardus cited Edwards v. Scholtzs, Meadors v. Feltor, and Wilson v. Gutschenritter, none of which existed in Kansas appellate reports, and misread K.S.A. 58-2564 and other authorities to argue the lease obligations ended after eviction. — outcome: filing struck; 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.
4 Dean, 56 Kan. App. 2d 770, 772-73, 437 P.3d 46 (2018) (citing King v. Stephens, 113 Kan. 558, 560, 215 P. 311 [1923]). If no transcript or adequate substitute is provided, we will not review any action of the trial court requiring us to examine the evidence. In re Marriage of Dean, 56 Kan. App. 2d at 772-73 (citing First Nat'l Bank & Trust Co. v. Lygrisse, 231 Kan. 595, 603, 647 P.2d 1268 [1982]; Osborne v. Fakes, 178 Kan. 373, 376, 286 P.2d 156 [1955]). "Without an objection, this court will presume the district court made all the necessary factual findings to support its judgment, though this court may consider a remand if the lack of specific findings precludes meaningful appellate review." Bicknell v. Kansas Dept. of Revenue, 315 Kan. 451, Syl. ¶ 14, 509 P.3d 1211 (2022). Including documents in an appendix does not make those documents part of the record on appeal; only materials properly designated and filed may be considered. Rodriguez v. U.S.D. No. 500, 302 Kan. 134, 144, 351 P.3d 1243 (2015); Rule 6.02(a)(4)- (5). LuPardus did not designate a transcript for the first day of trial. When an appellant fails to provide a complete record, Kansas law requires the appellate court to presume the district court's factual findings were correct. In re Marriage of Dean, 56 Kan. App. 2d at
Authorities cited in the passage: Meadors v. Feltor · Edwards v. Scholtzs · Wilson v. Gutschenritter · King v. Stephens · First Nat'l Bank & Trust Co. v. Lygrisse · Osborne v. Fakes · Bicknell v. Kansas Dept. of Revenue · Rodriguez v. U.S.D. No. 500