Self-represented litigants using AI

2026-09-02 · Iowa Court of Appeals

The Iowa Court of Appeals identifies likely AI misuse in a self-represented divorce appellant’s brief, including nonexistent and mischaracterized authorities. The court still considers discernible claims, affirms the decree, and warns that inaccurate AI-assisted filings waste resources.

During our review of Caroline’s appellate briefing, we discovered that she repeatedly cited an Iowa case that does not exist. And she cited other cases and statutes that do exist but do not stand for the propositions for which she cited them. It thus appears likely that she misused an artificial intelligence tool when preparing …

2026-08-26 · Florida Fourth District Court of Appeal · provisional

The Florida appellate court repeats a prior warning to a self-represented former husband after striking his initial brief with leave to amend. The opinion cautions him about using artificial intelligence in documents filed with the court while resolving contempt issues.

We disagree with the former husband’s proposed remedy. Although the caselaw holds that “substantive changes in the trial court’s [oral] ruling are not ministerial and are considered void” when a disqualified judge issues an order after disqualification, Godin, 275 So. 3d at 701, we disagree that the entire 2025 written contempt order is void. Because …

2026-08-25 · United States District Court for the District of Utah · provisional

The District of Utah adopts a recommendation dismissing Ferm’s case and addresses signs that his objection was drafted with artificial intelligence. The court confines review to one specific objection, describes the remaining pages as AI slop, and cautions the self-represented plaintiff against possible AI-drafted memoranda.

Objection also shows signs of drafting by artificial intelligence. Federal courts often strike briefs that do not comply with local rules, which the Tenth Circuit has upheld. Instead, this order confine review to Mr. Ferm’s one meritorious objection. ... The remainder of Mr. Ferm’s Objection is “too long, too verbose, too vague, and too repetitive” …

2026-08-21 · Superior Court of California, County of Sacramento · provisional

The Sacramento Superior Court rules on a demurrer and addresses Joseph Perez’s unsupported quotation from Adorh Farms. The court says the quotation does not appear in that opinion or any reported case, flags possible generative AI use, declines sanctions, and warns future fabricated authority may be sanctioned.

Plaintiff quotes Adorh Farms, Co. v. Love (1967) 255 Cal.App.2d 366 at p. 371: “The filing of an answer … effected a waiver of the right to demur.” (Opp., at p. 8: 19–21.) This is at best an incomplete statement of law. “A party objecting to a complaint or cross-complaint may demur and answer at …

2026-08-21 · United States District Court for the Eastern District of California · provisional

The Eastern District of California recommends dismissal of Stephen Lohbeck’s claims and considers Amazon’s Rule 11 argument. The magistrate judge finds two quotations in Lohbeck’s sanctions motion do not appear in the cited cases, declines sanctions because he is self-represented, and warns that future false authority may be sanctionable.

Defendant argues Plaintiff has violated Federal Rule of Procedure 11 by misusing generative artificial intelligence (“generative AI”). See Def. Sanctions Opp. at 6-7 (ECF No. 21). Specifically, Defendant argues Plaintiff’s writing contains generative AI hallmarks and that for each case Plaintiff cites with a parenthetical, the quoted language is absent from the cited opinion. ... …

2026-08-20 · United States District Court for the Central District of California · 2026 WL 2447454 · provisional

The Central District of California grants Cecile Kasengela’s remand motion while addressing non-existent quotations in her self-represented briefing. The court reiterates its standing order on AI-generated hallucinated caselaw, rejects her accusation against Kaiser, and says a lawyer would face significant sanctions.

Lastly, the Court underscores its Standing Order to remind Plaintiff that the inclusion of non-existent quotations in Plaintiff's briefing submitted to this Court is unacceptable. (See Opp'n at 3-4; Order Re Amended Civil Case Standing Order, Dkt. No. 65 at 18-20 (“caution[ing] that unqualified reliance on AI-generated content can result in filings that rely on …

2026-08-19 · Iowa Court of Appeals

The Iowa Court of Appeals declines sanctions for a self-represented litigant’s purported generative-AI use because no hallucinated case appears and a nonexistent rule citation might be a typo. The court separately awards attorney fees based on ordinary appellate factors.

In her resistance to Brett’s motion for remand and request for sanctions, Lacey asked our supreme court to impose sanctions on Brett for purported use of generative AI in his briefs. The use of generative AI presents an interesting challenge for modern courts. While Brett is correct that “mere use of [AI] drafting assistance . …

2026-08-19 · Superior Court of Pennsylvania · 2026 PA Super 185 · provisional

The Superior Court of Pennsylvania affirms dismissal of Zoryana Kaspryak’s partition action. The court finds that two citations in her self-represented reply brief are hallucinated, explains that the reporter citations lead to different cases, and concludes her claims are waived for unsupported and fabricated authority.

Specifically, Appellant cites to “General Fin. Co. v. Archetto, 167 A.2d 306 (Pa. Super. 1961)” and “Lowrey v. Eastaff, 860 A.2d 533 (Pa. Super. 2004).” See id. (some formatting altered). These citations are so nonsensical and disconnected from Appellant’s claims that we conclude that they are hallucinated citations. To the extent that Appellant has employed …

2026-08-19 · United States District Court for the District of Nevada · provisional

The District of Nevada dismisses William Lee Kelly’s second amended complaint against FINRA and warns him about AI-generated fake authority. The court finds several false quotes and nonexistent citations in his opposition and explains that future Rule 11 violations may lead to monetary or nonmonetary sanctions.

FINRA states that Kelly’s opposition to its motion to dismiss contains several nonexistent case citations and quotations that do not appear in Kelly’s cited caselaw. I reviewed the citations in the first few pages of Kelly’s opposition and found several quotes that did not appear in the cited cases. These false quotes appear on page …

2026-08-19 · Court of Appeals of Georgia · provisional

The Georgia Court of Appeals flags fictitious and irrelevant cases in a self-represented appellant’s briefing as suggestive of unchecked generative AI. It declines sanctions because the appellee was not hampered, but warns future filings may be sanctioned.

As an initial matter, we note that in his appellate briefing, Mitchell cites five cases that are either fictitious or have nothing to do with the propositions for which they are cited.1 These defects suggest that Mitchell’s briefs were “drafted with the use of unchecked generative AI,”2 and his reliance on non-existent law is a …

2026-08-19 · Court of Appeals of Iowa · provisional

The Court of Appeals of Iowa affirms a custody order and addresses a sanctions request based on alleged AI use. The court finds no hallucinated case, says it cannot determine whether a nonexistent appellate rule citation is a typo or unchecked AI output, and declines AI-use sanctions.

In her resistance to Brett’s motion for remand and request for sanctions, Lacey asked our supreme court to impose sanctions on Brett for purported use of generative AI in his limited-remand motion and briefs. ... The twist is that, absent the presence of a hallucinated case, it is difficult to differentiate poor human drafting from …

2026-08-19 · Court of Appeals of Georgia · provisional

The Court of Appeals of Georgia affirms summary judgment for HIG Realty Credit Fund and warns Trentiss Mitchell about citations in his self-represented appellate briefing. The court identifies two non-existent cases and two unrelated cases, says the defects suggest unchecked generative AI, and declines sanctions.

As an initial matter, we note that in his appellate briefing, Mitchell cites five cases that are either fictitious or have nothing to do with the propositions for which they are cited.1 These defects suggest that Mitchell’s briefs were “drafted with the use of unchecked generative AI,”2 and his reliance on non-existent law is a …

2026-08-19 · California Court of Appeal, Fourth Appellate District, Division One · provisional

The California Court of Appeal affirms an order in Marriage of Dillon and addresses three miscited cases in the respondent’s self-represented brief. The court disregards arguments based on the hallucinated citations, declines sanctions because none were sought, and denies prevailing-party costs on appeal.

Wife miscited three cases in her respondent’s brief by attributing to them quotations or legal propositions that do not appear in the cited opinions.3 The miscitations appear to be the result of Wife’s use of generative artificial intelligence without sufficient verification. We have disregarded the arguments in Wife’s brief that are based on the miscited …

2026-08-18 · Court of Appeals of Texas, First District · provisional

The Texas First Court of Appeals strikes Manny Kourradi’s fourth self-represented brief and dismisses the appeal. The memorandum identifies multiple unlocatable or mismatched Westlaw-style citations, says the errors are at best partially fabricated, and treats the defective briefing as grounds for dismissal.

The brief also included incomplete legal citations accompanied by unintelligible numeric strings (e.g., “2990836”). We again struck Kourradi’s appellate brief and ordered Kourradi to file a corrected brief. We admonished Kourradi to ensure that record references and citations to authorities are accurate. See Campbell v. Campbell, No. 03-25-00388-CV, 2026 WL 179402, at *2 n.3 (Tex. …

2026-08-18 · Appellate Court of Illinois, First District · 2026 IL App (1st) 252264-U · provisional

The Illinois Appellate Court affirms dismissal of Lemna Sani’s complaint and admonishes her about a nonexistent citation in her self-represented opening brief. The court says Helm v. Illinois Central Railroad does not exist and that the reporter citation leads to People v. Hardy, an unrelated criminal case.

We are particularly troubled by the fact that one of her case citations in her opening brief (as IHR notes) does not exist: “Helm v. Illinois Cent. R.R.” does not appear in any reported case in this state, and the precise citation (again, as IHR points out), “142 Ill. App. 3d 108 (1986),” is for …

2026-08-14 · Superior Court of Vermont, Windham Unit · 2026 WL 2479362 · provisional

The Vermont Superior Court grants Brattleboro’s sanctions motion against Jeffrey Rivard and imposes a civil-division prefiling injunction. The order cites Rivard’s prior non-existent authorities, mismatched Vermont Reports citations, spurious record quotations, and repeated warnings that had not changed his filing conduct.

Plaintiff has himself been admonished by the Court for citing non-existent authority. In his brief, plaintiff cited several purported decisions of this Court, including “Slayton v. Willing, 2010 VT 56, ¶ 14, 188 Vt. 216, 4 A.3d 1155,” “Sorrell v. Wigginton, 154 Vt. 301, 303 (1990),” “Morrison v. City of Montpelier, 2011 VT 9, ¶ …

2026-08-14 · United States District Court for the Southern District of Indiana · 2026 WL 2374808 · provisional

The Southern District of Indiana dismisses Darryl Harris’s complaint without prejudice and warns him about an incorrect citation in a service-extension motion. The court says the Walsh docket number linked to a different case, the Westlaw citation led nowhere, and future Rule 11 violations may be sanctioned.

In Harris's motion for extension of time to effect service of process, he cites Walsh v. Kreiger, No. 19-cv-1764, 2020 WL 6325983, at 2 (E.D. Wis. Oct. 28, 2020) (citing United States v. McLaughlin, 470 F.3d 698, 700 (7th Cir. 2006)), for the proposition that “good cause” not the stricter “excusable neglect” standard is the …

2026-08-14 · Court of Appeals of Indiana · provisional

The Court of Appeals of Indiana affirms the denial of David Brankle’s motion to compel and a $1,546 expenses award. The memorandum quotes the trial court’s finding that Brankle cited nonexistent rules and fictitious cases suggesting ChatGPT use, and holds hallucinated authorities cannot substantially justify the motion.

Brankle’s motion is totally without merit. First, Commercial Court Rules are inapplicable to this case[,] and Brankle should not cite to them again. Brankle’s repeated citations to rules that do not exist or fictitious cases leads the Court to opine that Brankle is using ChatGPT or other form of artificial intelligence to prepare his numerous …

2026-08-12 · United States District Court for the Western District of Pennsylvania · provisional

The Western District of Pennsylvania resolves motions in Dyran Davenport’s civil-rights action and warns him about inaccurate filings. The court identifies nonexistent Loder v. City of Philadelphia as an AI-hallucinated citation in his opposition but still accepts his accrual argument based on other relevant authority.

Moreover, the Court acknowledges that Plaintiff’s briefs appear to include at least one AI hallucinated citation. Plaintiff has also made unsupported, and to the extent unsupportable, arguably outrageous allegations about Defendants and their counsel. ... Plaintiff has proffered and the Court has seen no evidence to suggest that either of these allegations is at all …

2026-08-12 · United States District Court for the Middle District of Florida · 2026 WL 2329753 · provisional

The Middle District of Florida partly grants Arts Bonita’s motion about generative AI use. The court finds Julia Rose cited a nonexistent Prousalis case, later withdrew it as incorrect or unverifiable, declines sanctions for a single hallucinated citation, and warns future inaccurate authority may be sanctioned.

In her response to Arts Bonita's motion to dismiss, Rose cited Prousalis v. Bert's Bikes & Fitness, No. 8:18-cv-1234, 2019 WL 13202785 (M.D. Fla. 2019). That case does not exist. Once Arts Bonita caught the error, it asked Rose to join an agreed order on generative AI use. The City signed on, but Rose refused, …

2026-08-11 · United States District Court for the Middle District of Pennsylvania · 2026 WL 2322660 · provisional

The Middle District of Pennsylvania adopts a recommendation to dismiss Courtney Voyton’s complaint with leave to amend and admonishes her AI use. The memorandum says she misrepresented 42 Pa. Cons. Stat. § 5522 and advanced AI-steered ghost arguments unrelated to the report, requiring future AI-use affidavits.

Prior to addressing the merits of the allegations against Skibitsky, plaintiff is admonished for misrepresenting the law. The statute cited by plaintiff in Paragraph 43 has nothing to do with the alleged conduct by Skibitsky. Rather, the statute referenced requires a person to file a formal written notice of their intent to sue a state …

2026-08-11 · Appellate Court of Maryland · 2026 WL 2321382 · provisional

The Appellate Court of Maryland affirms judgment for 72 Barrow St. Realty and taxes costs to Simon Eyong. The per curiam opinion notes earlier orders striking large portions of his self-represented briefs for fictitious legal citations and inaccurate summaries, and leaves a sanctions motion for remand.

72 Barrow has moved for sanctions against Mr. Eyong under Rules 1-341 and 8-504, arguing that his citation to fictional legal authority in his opening brief and his reply brief; the lack of legal authority for his positions; and his failure to prepare a record extract justify an award of reasonable attorneys’ fees and costs. …

2026-08-11 · United States District Court for the Western District of Arkansas · provisional

The Western District of Arkansas sanctions Nicholas Nesbitt in a consumer-credit case by imposing filing restrictions. The court says he relied on AI for legal research and writing, filed at least two motions with fabricated cases, apologized after a Rule 11 show-cause order, and continued filing improper papers.

Since then, Plaintiff has filed numerous replies without leave of Court, repetitive notices and motions, and at least two motions relying on fabricated cases. ... On July 17, 2026, the undersigned ordered Plaintiff to show cause why he should not be sanctioned under Federal Rule of Civil Procedure 11(b) for citing nonexistent case law in …

2026-08-10 · Court of Chancery of the State of Delaware · provisional

The Delaware Court of Chancery master recommends removing Gregory Palumbo as trustee, denying his accounting petition, and shifting fees. The report says the self-represented disbarred attorney cited Kuroda and Koninklijke for propositions they do not support, treated fictitious quotations as an AI hallmark, and found subjective bad faith.

Moreover, many of the cases cited by Respondent in support of his proposition neither expressly state nor even suggest the statements for which he invokes them. Respondent cites Kuroda v. SPJS Holdings, LLC for the proposition that (1) the proper procedural retort to a confusing claim is a Rule 12(e) motion for a more definite …

2026-08-10 · Arizona Court of Appeals, Division One · provisional

The Arizona Court of Appeals dismisses Stefanie Kuerschner’s appeal and awards appellate fees and costs. The court says her brief lacked record citations, repeatedly misquoted or misstated cases, included one unlocatable case, and repeated citation problems despite earlier warnings about AI-related errors.

Stefanie’s opening brief does not include a single citation to the record. Her opening brief also consistently misquotes cases and cites cases for propositions either not mentioned or directly contradicted by the case. And one case she cites appears not to exist. ... On page 27, the brief quotes State ex rel. Dep’t of Econ. …

2026-08-07 · United States District Court for the District of Utah · provisional

The District of Utah addresses Jayne Stephens’s declaration that ChatGPT assisted her filings. The order notes a mischaracterized assertion based on an improperly cited Tenth Circuit case, requires future assistance disclosures, and cautions that GenAI-related Rule 11 violations may be sanctioned.

Ms. Stephens filed the Declaration on August 3, 2026, and declared, under penalty of perjury, that she had used a generative artificial intelligence (“GenAI”) tool known as ChatGPT. She confirms that she utilized ChatGPT “for assistance with research, organization, drafting, editing, and formatting.” Her candor is appreciated, but necessitates a caution. ... Ms. Stephens has …

2026-08-07 · Massachusetts Land Court, Plymouth District · 2026 WL 2295072 · provisional

The Massachusetts Land Court denies Robert Machinsky’s self-represented motion to dismiss in a registered-land proceeding. A footnote documents false statutory quotation, irrelevant recusal authority, Rule 70 cases that do not address Rule 70, and warns about AI-generated hallucinations and false citations.

In addition to this false quotation, a review of other legal citations in defendant's filings uncovered several additional inaccuracies and questionable string citations that may be attributable to use of generative artificial intelligence (“AI”) tools or large language models (“LLMs”). On page 3 of defendant's Motion to Recuse, he writes: “The appearance of bias or …

2026-08-07 · United States District Court for the Northern District of Illinois · provisional

The Northern District of Illinois denies Darren Smith’s § 2255 motion and issues a sanctions show-cause order. The court identifies a nonexistent Johnson case, false quotations from real cases, and nearly a dozen falsified cases or quotations, then orders Smith to explain why monetary sanctions should not issue.

Smith also cites United States v. Jones, 965 F.3d 149 (2d Cir. 2020) as a case that “reversed a sentence,” Smith’s Br. at 2, but Jones both did not involve challenges to the sentence and affirmed the defendant’s conviction, 965 F.3d at 153. In his reply brief, Jones cites “United States v. Johnson, 605 F.3d …

2026-08-06 · Supreme Court of North Dakota · 2026 ND 156 · provisional

The North Dakota Supreme Court affirms and remands in a divorce dispute and separately sanctions self-represented appellant Mojahid Osman. The court says Osman corrected two nonexistent citations but ignored many unrelated authorities, and awards Sara Ali $1,000 for multiple fictitious or nonexistent citation errors.

We conclude Osman’s appeal is not completely frivolous; therefore, we do not sanction under N.D.R.App.P 38 as requested. Nevertheless, while Osman corrected two nonexistent citations, he failed to acknowledge numerous other citations wholly unrelated to the propositions for which they were cited. Under N.D.R.App.P. 28(b)(2) and (7), a party’s brief must provide citations to authorities, …

2026-08-05 · United States District Court for the Northern District of New York · 2026 WL 2253803 · provisional

The Northern District of New York grants Waste Management’s dismissal motion, allows limited amendment, and warns self-represented plaintiff Mary-Rose Calenzo. The court identifies at least four nonexistent opinions in her opposition and directs her to stop using hallucinated or fabricated case law.

As a final matter, the undersigned has been unable to locate or verify several of the cases cited by Plaintiff in support of her opposition to Defendant's motion to dismiss. Specifically, Plaintiff's opposition includes citations to at least four nonexistent judicial opinions: LPD New York, LLC v. Adidas Am., Inc., 2020 WL 1501881 (S.D.N.Y. Mar. …

2026-08-05 · United States District Court for the District of Connecticut · provisional

The District of Connecticut admonishes self-represented debtor Ulish Booker in a bankruptcy appeal. After a show-cause hearing, the court finds his briefs contained fabricated cases, erroneous citations, and incorrect quotations produced with Gemini Pro, Perplexity, Cetient Legal AI, and ChatGPT.

On June 25, 2026, this Court issued an Order to Show Cause after discovering that Booker III’s briefs were riddled with cases that do not exist, incorrect quotes, and erroneous citations. Specifically, in its Show-Cause Order, the Court identified the following hallucinations: ... BCB Contracting Services, LLC v. United States, 104 B.R. 771, 775 (S.D. …

2026-08-04 · Missouri Court of Appeals, Western District · provisional

The Missouri Court of Appeals dismisses self-represented father Zackery Moore’s family-access appeal because he did not supply the record needed for review. A footnote says his brief also contained two nonexistent reporter citations and one misrepresented holding, independently supporting dismissal.

Therefore, we dismiss Father’s appeal for failure to provide this Court with the required record on appeal necessary to resolve the questions raised in his appeal. ... There are numerous other briefing deficiencies with Father’s appellate brief that would also independently support dismissal of Father’s appeal. ... Father’s brief includes two citations to cases that …

2026-08-03 · United States District Court for the Western District of Texas · provisional

The Western District of Texas adopts an R&R and dismisses the remaining defendant without prejudice. The order catalogs repeated invented quotations, unsupported case descriptions, and possible AI use, then warns the self-represented plaintiffs to verify all authorities and quotations in future filings.

They are the latest installment in a sustained series of filings marked by misstatements of law, mischaracterizations of the record, fabricated quotations, and demands untethered to any rule of procedure. ... Although Plaintiffs certified that they verified each citation contained in those objections (Doc. 76 at 26), the Court identified multiple instances in which Plaintiff …

2026-08-03 · Superior Court of Pennsylvania · provisional

The Superior Court of Pennsylvania affirms summary judgment in a medical-malpractice appeal. A footnote identifies three cited cases that do not exist, reminds the self-represented appellants that authority must be pertinent, and warns that substantial brief defects can justify dismissal.

Appellants cite to two cases—one which is non-existent—for the rules that summary judgment may not be entered where discovery is incomplete or credibility issues remain. See id. at 40 (citing Gibson v. Bicknell, 668 A.2d 1370 (Pa. Super. 1995), and Washington v. Baxter, 719 A.2d 733 (Pa. 1998)). ... This cited case does not exist.Elsewhere …

2026-08-03 · Ohio Court of Appeals, Seventh Appellate District · 2026-Ohio-2993 · provisional

The Ohio Seventh District affirms Jacob Davis’s speeding conviction. The opinion says Davis disclosed using generative AI for his nonconforming brief, and a cited Sanchez case does not discuss the indefinite-tolling proposition he raised, possibly reflecting an AI hallucination.

A further problem on appeal is that Appellant has filed a non-conforming brief, well outside of the limits set by the Rules of Appellate Procedure. The brief is set in a small font, single spaced, and if converted to 12-point font and double-spaced would well exceed 35 pages and 9,000 words (the word count is …

2026-08-03 · United States District Court for the Central District of California · 2026 WL 2227350 · provisional

The Central District of California manages a transferred pro se case by striking improper filings and imposing filing limits. The court says Jabbari’s papers contain AI hallmarks and fabricated legal authorities, then orders him to show cause why Rule 11 or inherent-authority sanctions should not issue.

The court also ORDERS Plaintiff to Show Cause (“OSC”) in writing, on or before August 17, 2026, why sanctions should not be imposed under Federal Rule of Civil Procedure Rule 11 and the court's inherent authority, for Plaintiff's submission of frivolous and vexatious filings and/or false and fabricated legal citations. ... Plaintiff's filings bear hallmarks …

2026-08-03 · United States District Court for the Northern District of Alabama · provisional

The Northern District of Alabama dismisses Domeneque Perry’s Social Security claim without prejudice and denies TRO and amendment motions. The court notes the Commissioner raised fabricated citations and misrepresentations in Perry’s TRO motion and warns this is Perry’s only warning before sanctions.

The SSA raised an issue of “fabricated citations” and misrepresentations in Ms. Perry’s motion for a temporary restraining order. See Doc. 30; Doc. 33 at 23–24. The court is aware that Ms. Perry has been warned by another court against such practices. The court warns Ms. Perry that fabricated citations and misrepresentations will not be …

2026-07-31 · United States District Court for the Southern District of New York · 2026 WL 2212887 · provisional

The Southern District of New York compels arbitration and stays a pro se employment case. The opinion separately addresses defendants’ concern that Santana’s opposition used nonexistent case authority attributed to AI, declines sanctions for now, and warns that future inaccurate citations may be sanctioned.

As a final matter, the Court addresses Defendants’ concern that Plaintiff's opposition brief contained citations and quotations to non-existent case authority, which they attribute to his use of artificial intelligence (“AI”). Dkt. No. 55 (“Forrest Defs. Repl.”) at 1–2; Dkt. No. 58 (“Shook Defs. Repl.”) at 1. The Shook Defendants urge the Court to sanction …

2026-07-31 · United States District Court for the Eastern District of Michigan · 2026 WL 2211604 · provisional

The Eastern District of Michigan overrules arbitration-related objections and warns Natashah Al-Ali. The order identifies nonexistent cases and an inaccurate statutory quotation, says the factitious citations appear AI-created, and states that even one future factitious citation may trigger sanctions.

First, Plaintiff's objections contain numerous factitious citations. For example, Plaintiff quotes 9 U.S.C. § 5, but the quote is inaccurate. Additionally, Plaintiff purportedly cites cases such as “Cottman Transmission Sys., Inc. v. Metro. Pontiac GMC, Inc., 351 F. Supp. 2d 343, 347 (E.D. Pa. 2004)” and “McMahon v. RMS Electronics, Inc., 951 F. Supp. 923, …

2026-07-30 · Wisconsin Court of Appeals, District IV · provisional

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.

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 …

2026-07-30 · United States District Court for the Southern District of New York · provisional

The Southern District of New York denies Nirav Modi’s motion for leave to appeal a bankruptcy order. The court notes Modi used an outside person and AI tool to format the motion, identifies a false Cohen quotation and unsupported AI-generated citations, and dismisses the action.

[H]e claims that because he has no access to a computer or typing facilities in prison, he first wrote “the entire document by hand” and then had “a person outside the prison type[] [his] handwritten notes and input[] them into an [artificial intelligence (‘AI’)] tool to help format the document properly.” Id. at 2. The …

2026-07-30 · United States District Court for the Northern District of Mississippi · provisional

The Northern District of Mississippi dismisses a pro se FCRA suit without prejudice for lack of standing. A footnote identifies two Northern District opinions that the court could not locate, calls them likely AI-generated fictitious citations, declines immediate sanctions, and warns Harris.

While not touched on by the current opinion due to lack of standing, the Court will note that Mr. Harris cited “Allen v. Equifax Info. Services, LLC, 2020 WL 2155673, at 3 (N.D. Miss. Apr. 1, 2020) and LeBlanc v. TransUnion, LLC, 2021 WL 1243659, at 5 (N.D. Miss. Mar. 19, 2021)” to support his …

2026-07-30 · Appellate Court of Illinois, First District · 2026 IL App (1st) 252223-U · provisional

The Illinois First District strikes Tony Cole’s pro se brief and dismisses his appeal. The order identifies authorities that do not support cited propositions and incorrect case citations, says the inaccuracies improperly shifted research burdens to the court, and relies on repeated Rule 341 violations.

Before we can consider the merits of Cole’s contentions, we observe that several of his citations to authorities are incorrect, including attributing propositions to authorities that those authorities simply do not support. For example, citing to Avery v. State Farm Mutual Automobile Insurance Co., 216 Ill. 2d 100 (2005), Cole asserts that claims under the …

2026-07-29 · Court of Appeals of Tennessee · provisional

The Tennessee Court of Appeals affirms a landlord-tenant judgment and disregards fabricated or inaccurate parts of Samuel Robinson’s pro se brief. The opinion says the brief bears AI hallmarks, identifies false case and statutory quotations, a fabricated Tennessee Supreme Court case, and unsupported legal assertions.

Unfortunately, Mr. Robinson’s brief fails to comply with this rule as it contains numerous false quotations from case law and statutes and, in some instances, outright fake citations. In this way, Mr. Robinson’s brief bears all the hallmarks of an artificial intelligence-generated brief, filled with what has been referred to as “hallucinations.” ... Mr. Robinson’s …

2026-07-29 · United States District Court for the Southern District of Ohio · 2026 WL 2184981 · provisional

The Southern District of Ohio dismisses Gragston’s amended employment complaint but permits a motion for leave to amend. A footnote identifies a purported Sixth Circuit hostile-work-environment citation as AI-hallucinated and formally warns that future reliance may bring monetary sanctions or dismissal with prejudice.

As Amazon suggests (but does not expressly state), Gragston seems to rely on AI-hallucinated caselaw in support of this point. (See Doc. 28, #141 n.2). The Court's independent review suggests the same. Gragston cites a case that he refers to as “Latham v. Off. of Att'y Gen. of Ohio, No. 20-4089, 2021 WL 1324065 (6th …

2026-07-29 · Florida Fourth District Court of Appeal

The Florida appellate court notes that a self-represented appellee cited two nonexistent cases. Without imposing sanctions, it disregards the phantom authority and reiterates that attorneys and pro se litigants remain responsible for verifying AI-assisted filings.

In his answer brief, the husband cites two cases which do not exist. As we recently explained: Such phantom authority cannot assist any litigant and must be expressly disregarded by this court. Attorneys and those, like appellee, who proceed pro se are responsible for the content of their submissions to the court. Those who use …

2026-07-29 · United States District Court for the District of Colorado · provisional

The District of Colorado magistrate judge recommends summary judgment and grants discovery-fee sanctions in part. The order separately finds Maloit’s briefs contain misquotations, misstatements, and seven nonexistent cases likely from generative AI, then orders her to show cause about additional sanctions.

Finally, it has come to the Court’s attention that Plaintiff’s Response briefs in opposition to the instant Motion for Summary Judgment [#91] and Motion for Sanctions [#87] contain defective citations to case law. These defects include (1) misattributed or inaccurately quoted language from cases, (2) misrepresentations of legal concepts associated with the cited cases, and, …

2026-07-29 · United States Court of Appeals for the Tenth Circuit · provisional

The Tenth Circuit affirms dismissal of Shantell Robinson’s claims with prejudice as a Rule 11 sanction. The order describes nonauthentic evidence, at least four filings with nonexistent or misrepresented authority, and a new appellate brief citation to the nonexistent Reynolds v. Smith case.

The district court’s order detailed the clear and convincing evidence it relied on to determine that Ms. Robinson’s conduct was sanctionable. The court noted that despite her claims that her emergency motion was “grounded in fact,” Ms. Robinson submitted “no evidence to support the veracity of the purported intercepted statements” about Mr. Raines following her, …

2026-07-28 · United States District Court for the District of Oregon · provisional

The District of Oregon denies self-represented defendants’ dismissal, transfer, and anti-SLAPP motions. Before reaching the merits, the order records withdrawn and additional false citations in Askew’s briefing and warns all parties that future false or hallucinated citations may be sanctioned.

In the course of briefing her motion to dismiss and in response to Plaintiff’s filings, Ms. Askew acknowledged that she relied on a false citation, “Young v. Maciorca, 69 F.4th 1099, 1106 (9th Cir. 2023).” ECF No. 92. Ms. Askew subsequently withdrew her references to “Young v. Maciorca,” which is not a Ninth Circuit decision. …

2026-07-28 · United States District Court for the District of Maine · provisional

The District of Maine grants summary judgment to the Social Security Commissioner and dismisses Alexander McNeil’s amended complaint. A footnote flags several nonexistent or fabricated legal authorities in the pro se pleadings and cautions McNeil to personally verify each future citation.

The Court notes the presence of several citations to nonexistent or fabricated legal authority in Plaintiff's pleadings. “Although courts are solicitous toward pro se litigants, there are reasonable limits”—“a pro se litigant must not provide the Court with erroneous and factitious citations and has an obligation to review documents filed with the Court to make …

2026-07-28 · United States District Court for the District of Maryland · provisional

The District of Maryland denies discovery sanctions in a pro se employment case and addresses possible generative-AI misuse. The court says Campbell’s filings do not outright hallucinate cases but misdescribe Aguilar and Mancia, corroborating admitted tool use, and cautions that future errors may draw fees or sanctions.

One other consideration worth discussing is the potential misuse of generative artificial intelligence. The parties dedicate a substantial portion of their respective filings to whether Campbell’s motions involve improper use of or reliance on generative artificial intelligence, including whether she misstates legal authority or she uploaded confidential documents into a generative artificial intelligence program. ... …

2026-07-27 · Minnesota Court of Appeals · provisional

The Minnesota Court of Appeals affirms summary judgment for Ally Bank. At the end of the opinion, the court defines fabricated authority, identifies three nonexistent citations and many unsupported legal propositions in Ngouambe’s pro se informal brief, and disregards them when evaluating the merits.

We conclude by addressing fabricated authority in Ngouambe’s brief to this court. Fabricated authority includes citations to authority that do not exist, quotations that do not appear in the cited authority, and asserted propositions of law not reasonably attributable to the cited authority. Ngouambe’s informal brief contains fabricated authority in the form of three citations …

2026-07-27 · United States District Court for the Eastern District of Michigan · provisional

The Eastern District of Michigan resets a pro se FCRA case by striking pending motions and setting aside default. The order cautions both sides after a brief cites Antoine for a quotation and proposition not found there, warning that generative-AI phantom cases can trigger Rule 11 sanctions.

Finally, the Court issues a caution about the use of generative artificial intelligence (“AI”). It appears from the briefing that one or both parties may be utilizing AI to draft their briefs. (See, e.g., ECF No. 20, PageID.71 (citing Antoine v. Atlas Turner, Inc., 66 F.3d 105, 110 (6th Cir. 1995) for a quotation and …

2026-07-27 · Ohio Court of Appeals, Twelfth Appellate District · 2026-Ohio-2862

The Ohio appellate court pauses before the merits to address a father’s acknowledged AI-assisted brief. The court identifies erroneous citations, reminds parties that false authorities may lead to sanctions, and applies ordinary appellate standards to the self-represented parent.

Before we consider Father's assignments of error, we first address his acknowledged reliance on artificial intelligence in drafting his brief. We note that several case citations in Father's brief were erroneous in that they led to miscited cases and cases that exist but stand for different legal propositions than what is represented. We remind all …

2026-07-24 · United States District Court for the Eastern District of California · 2026 WL 2138081 · provisional

The Eastern District of California recommends dismissing Graves’s utility-pole claims with leave to amend and denies e-filing. A footnote identifies two nonexistent California cases, notes that Pierce does not support the cited limitations point, and warns about AI research and Rule 11 sanctions.

Plaintiff cites to Boling v. Pub. Utils. Comm'n, 105 Cal.App.3d 805 (1980) and Loving v. Cnty. of Stanislaus, 33 Cal.App.5th 444 (2019), which are not real cases. Plaintiff also cites to Pierce v. Cnty. of Orange, 526 F.3d 1190 (9th Cir. 2008), which does not discuss statute of limitations or continuing violation issues. At the …

2026-07-22 · Iowa Court of Appeals

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.

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 …

2026-07-20 · Ohio Court of Appeals, Eleventh Appellate District · 2026-Ohio-2769

The Ohio appellate court sees signs that a self-represented brief relied improperly on AI tools, but it declines sanctions. The court cautions that lack of candor may be sanctionable and refuses to construct arguments for the appellant.

Such a practice is suggestive of an improper reliance on artificial intelligence tools and does not represent a good-faith effort to make a coherent argument. {¶21} This court has previously found the imposition of sanctions to be warranted for the misuse of artificial intelligence. See generally State v. Coleman, 2026-Ohio-965 (11th Dist.). However, recognizing that …

2026-07-16 · Indiana Tax Court

The Indiana Tax Court denies Chryshawna and Jeremy Webb’s pro se motion to supplement an administrative tax record. In a note on artificial intelligence, the court says cited rules did not support the Webbs’ propositions, admonishes them for likely generative-AI use, and imposes no further penalties.

NOTE ON THE USE OF ARTIFICIAL INTELLIGENCE The Webbs refer to various court rules in their motion to support their request to supplement the record. While the rules the Webbs cite do exist, they plainly do not stand for any of the propositions that the Webbs advance. This leads the Court to believe that the …

2026-07-15 · Supreme Court of Guam · 2026 Guam 5

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.

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, …

2026-07-08 · District Court of Appeal of Florida, Second District

The Florida Second District Court of Appeal affirms orders against Cynthia Hulse-Gibson without comment. The panel separately cautions the self-represented appellant that her briefs contained mismatches among propositions, case names and citations, and warns that unverified generative-AI legal research can expose filers to sanctions.

We affirm the orders on appeal without comment. We write, however, to caution Cynthia Hulse-Gibson about using generative AI in any future pro se filings without verifying the accuracy of the results. Hulse-Gibson's briefs here are replete with mismatches involving the purported legal proposition, the case name, and the reporter citation. See Fletcher v. Experian …

2026-06-26 · Ohio Court of Appeals, First Appellate District · 2026-Ohio-2432

The Ohio First District Court of Appeals resolves post-divorce property disputes, denies Victoria Morgan’s request to sanction self-represented Mark Jones, and denies a vexatious-litigant motion. The court says Jones’s two phantom citations bear the hallmarks of AI hallucinations but predate its local AI rule.

Morgan suggests that these phantom cases may be artifacts from the use of generative artificial-intelligence (“AI”) software drawing upon large language models. Appellate courts across Ohio and the country have experienced a surge of filings with such “hallucinations”—i.e., false citations proffered as true by generative AI. Jones neither confirms nor denies the allegation that he …