Courts on AI / Self-represented litigants using AI
In re Estate of Pangelinan
Supreme Court of Guam · State supreme courts · GU · · 2026 Guam 5 · No. CVA25-007 · opinion
The Supreme Court of Guam observes that two nonexistent citations in a self-represented probate appellant’s brief may be attributable to generative AI. Considering pro se status and a first appearance, it finds sanctions unwarranted but reiterates final-submission duties.
- Disposition
- The court affirmed in part and reversed in part while declining sanctions for two possible AI-attributed citations.
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
In Schacher’s opening brief, two nonexistent citations may be attributed to generative artificial intelligence use. See Appellant’s Am. Br. at 15 (June 30, 2025). We do not find sanctions warranted, considering Schacher’s pro se status and this being his initial appearance before the court. However, we reiterate that “[i]t is the responsibility of attorneys, judges, and self-represented litigants to ensure the integrity of their final submissions.” Re: Adoption of the Judiciary of Guam Policy on Artificial Intelligence, ADM25-001, Ex. A (Admin. Order No. ADM25-001, Apr. 30, 2025).
Authorities cited in the passage: Re: Adoption of the Judiciary of Guam Policy on Artificial Intelligence, ADM25-001
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