Courts on AI / Fabricated or misquoted citations
First Community Credit Union v. Smith
Wisconsin Court of Appeals, District IV · State appellate courts · WI · · No. 2025AP1045 · opinion
The Wisconsin Court of Appeals affirms in a credit-union dispute and denies a frivolous-appeal fee request. A footnote says Ashley Smith’s briefs contain false legal citations, warns against repetition, and cautions that generative AI can hallucinate nonexistent cases or misreport holdings.
- Disposition
- The court affirmed and denied the respondent's frivolous-appeal fee motion, while cautioning Smith about false citations.
- Recorded conduct
- Self-represented appellant filed briefs with false legal citations, including misrepresented case and statutory authorities and irrelevant authorities. — 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.
Smith’s briefs include false legal citations, of which her citation to Gielow is one example. Specifically, and as noted throughout this opinion, some citations misrepresent the content of the cited cases and statutes, and some citations are to legal authorities that exist but are wholly unrelated to the proposition for which they are cited. The inclusion of false legal citations in Smith’s briefing violates WIS. STAT. RULE 809.19(1)(e) and (4)(b). This court cautions Smith not to repeat this violation in any future filings in this or any court. I offer an additional note of caution—if the root of the problem is that Smith used generative AI for legal research and trusted it to provide accurate results, she should be aware that there are many reported instances in which generative AI has hallucinated nonexistent cases and misreported the holdings of existing cases. ... While many if not most of Smith’s arguments are not supported by the record or by citations to relevant authority, I cannot conclude that the entire appeal is frivolous. Accordingly, I deny First Community’s motion.
Authorities cited in the passage: Gielow v. Napiorkowski, 2003 WI App 249 · WIS. STAT. RULE 809.19(1)(e) · WIS. STAT. RULE 809.19(4)(b) · WIS. STAT. RULE 809.25 · Thompson v. Ouellette, 2023 WI App 7
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