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Courts on AI / Fabricated or misquoted citations

Sherdena Rocky Ali v. Carlos Efre Idiokitas

Kentucky Court of Appeals · State appellate courts · KY · · No. 2025-CA-1094-ME · opinion

Fabricated or misquoted citations

The Kentucky Court of Appeals on 2026-05-01 warned the self-represented appellant to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Sherdena Rocky Ali v. Carlos Efre Idiokitas. The self-represented appellant filed a brief with two fabricated case citations.

Disposition
The interpersonal protective order denial was affirmed and Ali was warned that future noncompliant filings may bring severe penalties.
Recorded conduct
Ali’s pro se brief cited two hallucinated cases generated by AI. The court warned that future noncompliant filings may result in severe penalties. — outcome: warning; 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.

However, her status as a pro se litigant does not exempt her from following the Kentucky Rules of Appellate Procedure (RAP). Koester v. Koester, 569 S. W. 3d 412, 415 (Ky. App. 2019). Pertinent to the case sub judice, RAP 32(4) mandates an appellant’s argument must have “ample . . . citations of authority pertinent to each issue of law[. ]” It is obvious to this Court that Sherdena used Generative AI to write her brief. Notably, two cases cited therein do not exist or were “hallucinated”: E. D. v. D. T. , 338 S. W. 3d 56 (Ky. App. 2011), and Commonwealth v. Thurman, -8- 691 S. W.

Authorities cited in the passage: Koester v. Koester, 569 S · E. D. v. D. T. , 338 S · Commonwealth v. Thurman

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