Skip to content

Courts on AI / Self-represented litigants using AI

Mitchell v. HIG Realty Credit Fund, LP

Court of Appeals of Georgia · State appellate courts · GA · · No. A26A0854 · opinion

Self-represented litigants using AIgenerative AI

The Georgia Court of Appeals flags fictitious and irrelevant cases in a self-represented appellant’s briefing as suggestive of unchecked generative AI. It declines sanctions because the appellee was not hampered, but warns future filings may be sanctioned.

Disposition
The court affirmed summary judgment and declined sanctions while cautioning Mitchell about future AI-related citation defects.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

As an initial matter, we note that in his appellate briefing, Mitchell cites five cases that are either fictitious or have nothing to do with the propositions for which they are cited.1 These defects suggest that Mitchell’s briefs were “drafted with the use of unchecked generative AI,”2 and his reliance on non-existent law is a clear impediment to the work of this Court.3 We elect not to sanction Mitchell because HIG has not complained and does not appear to have been hampered in responding to Mitchell’s arguments.4 Nevertheless, we caution Mitchell that any future filings in this Court containing citations to fictitious or plainly inapplicable cases may result in the imposition of sanctions.5 1 Mitchell purports to cite Walker v. Pierce, 315 Ga. App. 524 (2012), and Crenshaw v. Ga. Dep’t of Human Resources, 263 Ga. 722 (1994), which do not exist. He also cites Henson v. Columbus Bank & Trust Co., 144 Ga. App. 80 (240 SE2d 284) (1977), and Stamps v. Nelson, 290 Ga. App. 277 (659 SE2d 697) (2008), which do exist, but have nothing to do with the issues raised in this appeal. 2 Slay v. Ross, 379 Ga. App. 1, 1 (927 SE2d 569) (2026). 3 See Shahid v. Essam, 376 Ga. App. 145, 145–50(1) (918 SE2d 198) (2025).

Authorities cited in the passage: Slay v. Ross, 379 Ga. App. 1 (2026) · Shahid v. Essam, 376 Ga. App. 145 (2025)

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub