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Courts on AI / Fabricated or misquoted citations

State v. Davis

Ohio Court of Appeals, Seventh Appellate District · State appellate courts · OH · · 2026-Ohio-2993 · No. 25 CO 0050 · opinion

The Ohio Seventh District affirms Jacob Davis’s speeding conviction. The opinion says Davis disclosed using generative AI for his nonconforming brief, and a cited Sanchez case does not discuss the indefinite-tolling proposition he raised, possibly reflecting an AI hallucination.

Disposition
The court affirmed Davis's speeding conviction and taxed costs against him.
Recorded conduct
Self-represented appellant used AI and cited Sanchez for an indefinite-tolling proposition the opinion did not discuss. — outcome: other; 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.

A further problem on appeal is that Appellant has filed a non-conforming brief, well outside of the limits set by the Rules of Appellate Procedure. The brief is set in a small font, single spaced, and if converted to 12-point font and double-spaced would well exceed 35 pages and 9,000 words (the word count is over 12,000). Appellant has also notified this Court that he used generative Artificial Intelligence (AI) to create his brief. Since Appellant is not an attorney, he cannot determine whether AI has produced viable legal arguments. Since he has not tested most of his arguments at the trial court level, he seeks for this Court to determine the legitimacy of his AI documents and arguments. ... It is not clear what argument Appellant is trying to make regarding the Sanchez case, cited above. The issue in Sanchez was whether the defendant was being held solely on the pending charge. More specifically, the question in that case was whether a detainer filed by the Bureau of Immigration and Customs Enforcement nullified the triple count provision of R.C. 2945.71(E). This is not an issue in the instant matter. Sanchez does not discuss the topic Appellant raises and does not mention indefinite tolling. His citation to this immaterial case may have been as a result of a “hallucination” by Appellant’s AI queries.

Authorities cited in the passage: State v. Sanchez, 2006-Ohio-4478 · R.C. 2945.71(E) · State ex rel. Neil v. French, 2018-Ohio-2692

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