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Courts on AI / Fabricated or misquoted citations

Pamela Blair v. Sanctuary Bluff Homeowners Association, Inc., et al.

Kentucky Court of Appeals · State appellate courts · KY · · 2026 WL 784501 · opinion

Fabricated or misquoted citations

On 2026-03-20, Kentucky Court of Appeals struck the appellant’s brief and allowed refiling after repeated hallucinated precedent and deficient AI certifications. A self-represented party submitted an appellate brief with nine false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Co. v. Thompson, 11.

Disposition
The court struck the appellant’s brief and allowed refiling after repeated hallucinated precedent and deficient AI certifications.
Recorded conduct
The appellate brief used nine false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Co. v. Thompson, 11, which the court found nonexistent, misquoted, or unsupported. — outcome: strike off; 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.

principles. [Goodyear Tire & Rubber Co. v. Thompson, 11 to dismiss the appeal as Blair's latest brief again contained S.W.3d 575, 581 (Ky. 2000).] hallucinated precedent. Blair responded by admitting her brief contained one hallucinated case that was “erroneously ... repeated.” In an abundance of grace, this Court denied the HOA's motion to dismiss. Even so, Blair closed the appellate Consideration of a motion to dismiss under CR 41.02(1) briefing window by submitting a reply brief with yet another requires fact-specific determinations that are left to the hallucinated case12 and absent an AI certification. This sound discretion of the trial court. [Jaroszewski, 297 deliberate disregard for a Court's ruling, and her recalcitrant S.W.3d at 32.] The trial court must base its assessment on approach to litigation has become a pattern and such actions the totality of the circumstances. [See id. at 36.] have likely sabotaged her own litigation. Still, a trial court's discretion is not unfettered and is subject to an important limitation. Our courts have long recognized Nonetheless, we shall address the merits of the matter in order that CR 41.02(1) dismissal with prejudice is an “extreme to bring

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