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Courts on AI / Fabricated or misquoted citations

Isaiah Hunter-Bey v. City of Cleveland Law Department

Court of Appeals of Ohio, Eighth District · State appellate courts · OH · · 2026 WL 1434161; 2026-Ohio-1869 · No. No. 115696 · opinion

Fabricated or misquoted citationsGAI

On 2026-05-21, in Isaiah Hunter-Bey v. City of Cleveland Law Department, Court of Appeals of Ohio, Eighth District admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a motion using record or transcript quotations not found in the record and authorities used for propositions they did not support.

Disposition
The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.
Recorded conduct
A self-represented appellant filed a motion using record or transcript quotations not found in the record and authorities used for propositions they did not support. — 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.

Specifically, his brief exhibits all the hallmarks of being generated by artificial intelligence (“AI”) including nonexistent cases, miscited cases, and cases that exist but standfordifferentlegalpropositionsthanwhatisrepresented. See Smith v. Gamble, 2025-Ohio-2381, ¶ 26 (12th Dist.); Gonzalez v. Tex. Taxpayers & Research Assoc., 2025 U.S. Dist. LEXIS 16801 (W.D. Tex. Jan. 29, 2025). App.R. 16(7) requires that an appellant set forth “[a]n argument containing the contentions of the appellant with respect to each assignment of error presented for review and the reasons in support of the contentions, with citations to the authorities, statutes,andpartsoftherecordonwhichtheappellantrelies.” Hunter-Bey's status as a pro se litigant does not relieve him of his obligations to comply with the appellate rules because it is well established that “ ‘pro se litigants are held to the same standard as all other litigants [and] they must accept the consequencesoftheirownmistakes.’”Manningv.Cuyahoga Metro.Hous.Auth.,2025-Ohio-4751,¶17(8thDist.),quoting Bikkaniv.Lee,2008-Ohio-3130,¶29(8thDist.),citingKilroy v. B.H. Lakeshore Co., 111 Ohio App.3d 357, 363 (8th Dist. 1996). Furthermore, App.R. ... Britt, 67 Ohio St.2d 71 (1981), in support of his argument that the trial court must rule on all his pending motions prior to deciding the City's motion to dismiss. His reliance on this case, however, is misguided. Although the case exists, it does not stand for the stated proposition. Similarly, Hunter-Bey cites to “McQueen” without a cite or explanation as to how “McQueen” might apply, and we are unable to decipher which case he is relying upon. *3 {¶ 10} Nevertheless, Hunter-Bay's assertions are mistaken, because “there is no rule of law requiring that a trial court expressly rule on every pretrial motion before it.” N. Star Med. Research, L.L.C. v. Kozlovich, 2025-Ohio-5410, ¶ 26 (8th Dist.).

Authorities cited in the passage: See Smith v. Gamble, 2025-Ohio-2381, ¶ 26 (12th Dist.) · Gonzalez v. Tex. Taxpayers & Research Assoc., 2025 U · L.L.C. v. Kozlovich, 2025-Ohio-5410, ¶ 26 (8th Dist.)

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