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Courts on AI / Fabricated or misquoted citations

Prisbrey v. Prisbrey

Utah Court of Appeals · State appellate courts · UT · · 2026 WL 787382 · No. 20250070 · opinion

On 2026-03-19, Utah Court of Appeals reversed and remanded for a new trial while criticizing counsel’s incorrect Utah citations, misquotations, and authorities made out of whole cloth. Counsel submitted an appellate brief with seven fabricated or nonexistent authorities and mischaracterized authorities.

Disposition
The court reversed and remanded for a new trial while criticizing counsel’s incorrect Utah citations, misquotations, and authorities made out of whole cloth.
Recorded conduct
The appellate brief used seven fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — outcome: other; actor: lawyer
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.

to support his propositions. Of these six citations, four are incorrect for various reasons (e.g., the cited material has nothing to do with the proposition for which the case is cited, the case name is incorrect, or the cited paragraph does not exist). (3) In the argument section, which is just over four pages long, Leona's counsel cites four Utah cases a total of seven times. Only one citation is correct. The others are deficient in various ways (e.g., wrong case name, unrelated in any way to the asserted proposition, cited paragraph of the case does not exist, or misquoted the case). Indeed, some of the citations appear to be made out of whole cloth. We realize attorneys find themselves pulled in many directions, but even in the midst of these pressures, we do expect a modicum of compliance with briefing and citation standards. In a case like this, where any similarity between the citation in the brief and the material cited appears to be purely accidental, we are left perplexed as to what happened in the composition process.

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