Courts on AI / Self-represented litigants using AI
Sherwin v. State of Iowa, Department of Criminal Investigation
Iowa Court of Appeals · State appellate courts · IA · · No. 25-0992 · opinion
The Iowa Court of Appeals rejects self-represented plaintiffs’ attempt to strike opposing motions because defendants did not certify whether they used ChatGPT or other AI. The court says no disclosure rule was shown and AI-assisted research or drafting is not inherently improper.
- Disposition
- The court affirmed dismissal and rejected the pro se litigants’ request to require AI-use certification by defendants.
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
the district court properly denied the Sherwins’ request to strike the defendants’ motions to dismiss because they did not certify whether they used “generative artificial intelligence” in their drafting. True, “self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.” Luke v. Dep’t of Health & Hum. Servs., 29 N.W.3d 635, 636 (Iowa Ct. App. 2025). But nothing about the State’s citation to Benskin in its trial brief breached that duty. Even if the citation form was incomplete, the case was neither hallucinated nor “suspicious.” What’s more, the State cited the case for the familiar proposition that “[m]otions to dismiss are disfavored.” Benskin, 952 N.W.2d at 296. Thus, the district court did not act with prejudice by refusing to require the defendants to disclose any use of artificial intelligence.
Authorities cited in the passage: Luke v. Iowa Dep’t of Health & Human Services, 29 N.W.3d 635 (Iowa Ct. App. 2025)
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