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Courts on AI / Fabricated or misquoted citations

In re Estate of Pangelinan

Supreme Court of Guam · State supreme courts · GU · · 2026 Guam 5 · No. CVA25-007 · opinion

Fabricated or misquoted citations

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 Supreme Court of Guam declined sanctions for two possible AI-attributed nonexistent citations and reiterated verification duties.
Recorded conduct
Schacher’s opening brief contained two nonexistent citations that the court said may be attributed to generative artificial intelligence use. — 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.

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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