Self-represented litigants using AI

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

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

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” …

2026-08-19 · 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 · 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

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 …

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

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.

Further, the Court notes that it entered a supplemental notice to pro se litigants regarding the use of artificial intelligence on June 24, 2026. Dkt. 7. This notice and the Practices and Procedures of this Court require all litigants to tell the Court if they used artificial intelligence (AI) to help write their complaint, a …

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 · United States District Court for the Western District of Arkansas

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 …

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

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 …

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

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 · 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 …

2026-07-30 · 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 …

2026-07-29 · 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 …

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

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 · 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

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 · provisional

The Indiana Tax Court suspects self-represented taxpayers used generative AI in a motion citing real rules for incorrect propositions. The court recognizes benefits for self-represented parties but warns that all litigants must verify sources and holdings.

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 Webbs used generative AI in producing their …

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 · Court of Appeals of Ohio, 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 …

2026-06-09 · United States District Court for the Eastern District of Pennsylvania

On 2026-06-09, in Casey A. Gaddy v. Wood Brothers Bar, Inc., et al, the Eastern District of Pennsylvania admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant filed a motion using record or transcript quotations not found in the record, quotations that did not appear in.

He speculates about Gillespie’s motives and saturates his briefing with immaterial and misrepresented facts, apparently hallucinated by artificial intelligence. The record shows Gillespie fired Gaddy because he concluded after investigating that Gaddy fudged the customers’ tips. The Court grants defendants’ motion. I Customers and staff at Woody’s and Voyeur are mostly gay, bisexual or queer …

2026-06-01 · United States District Court for the District of Massachusetts · provisional

On 2026-06-01, in Richard A. Cole v. Midland States Bank, et al, the District of Massachusetts admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant filed a motion using authorities used for propositions they did not support and a nonexistent rule or legal standard.

his opposition to the motion to dismiss ... relies on the output of generative artificial intelligence (“AI”) to support his contention that he is a “consumer” under the EFTA.

2026-05-12 · United States District Court for the Eastern District of California

The Eastern District of California on 2026-05-12 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Pyle v. Glenn County Sheriff's Department. The self-represented plaintiff filed a submission with one fabricated or AI-like submission item and one fabricated factual or other assertion, including Sheriff Owens.

, 559 F. 3d 1061, 1071 (9th Cir. 2009). The Court notes that Plaintiff’s SAC appears to have been drafted with the help of generative artificial intelligence (“GenAI”) or similar tools because it contains apparent GenAI responses to prompts. See SAC at 2:19-21, 3:26-28, 4:25-28, 6:22-24, 7:11-13. Of particular concern is an apparent reference to …

2026-04-29 · California Court of Appeal, Fifth Appellate District

The California Court of Appeal, Fifth District on 2026-04-29 warned the self-represented mother to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in In re W.B. The self-represented mother filed an opening brief with one fabricated case citation.

DISCUSSION As a preliminary matter, we address mother’s statement in her opening brief that she used “something…on [her] phone” to draft her brief. Given the context of mother’s statement, and the content and style of the brief itself, we infer that mother may be referring to a generative Artificial Intelligence (AI) system. We accept that …

2026-04-27 · United States District Court for the Southern District of New York · provisional

The Southern District of New York on 2026-04-27 allowed refiling but warned the self-represented plaintiff after AI-like placeholders and repeated nonsensical text appeared in Rhonda L. H.-B. v. Commissioner of Social Security. The self-represented plaintiff filed an opposition with two fabricated or AI-like submission items.

and • a 179-page "Memorandum of Law in Opposition to Defendant's Motion to Dismiss and in Support of Emergency Relief, Mandamus, and Judicial Enforcement. " (Dkt. 40 at 3. ) As discussed in more detail below, portions of plaintiff's papers appear to constitute the unedited output of a generative artificial intelligence (AI) tool. Plaintiff's Motions …

2026-04-16 · United States District Court for the Eastern District of Texas, Sherman Division · 2026 WL 1040383 · provisional

The Eastern District of Texas on 2026-04-16 admonished the self-represented plaintiff about inaccuracies in a joint discovery report caused by generative-AI reliance. The order required future disclosures identifying any generative-AI use and certifications that the filer reviewed AI work product for accuracy and relevance.

LAUD ESSANDOH v. United States District Court, E. D. Texas, Sherman Division. LAUD ESSANDOH v. CAPITAL ONE BANK NA NO. ORDER ON DISCLOSURE AND CERTIFICATION REQUIREMENTS FOR USE OF GENERATIVE ARTIFICIAL INTELLIGENCE Bill Davis United States Magistrate Judge *1 Today, the court held a discovery hearing based on the parties' joint report, Dkt. 25, following …

2026-03-30 · United States District Court for the District of Massachusetts

On 2026-03-30, U.S. District Court for the District of Massachusetts dismissed the complaint. A self-represented party submitted an opposition brief with multiple fabricated or nonexistent authorities, including Mata v. Avianca, Inc., No. 22-cv-1461 and Allbaugh v. U. of Scranton, No. 3:24-CV-2237.

United States District Judge It is apparent to the Court that Plaintiff relied on generative AI in multiple instances to create his filings. [See e.g. ECF No. 8 at 4 (multiple instances where it appears the generative AI program is speaking directly to Plaintiff, using terms like “you” and “your” to refer to Plaintiff, and …

2026-03-10 · United States District Court for the Southern District of Illinois

Southern District of Illinois on 2026-03-10 in Tina Rose v. City of West Frankfort et al. found the self-represented party's filing contained one citation defect involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

“A person commits a hate crime when, by reason of the actual or perceived . . . physical or mental disability . . . of another individual or group of individuals, regardless of the existence 3 The Court believes that Plaintiff may be using generative AI platforms, such as ChatGPT, to draft her filings. Plaintiff …

2026-03-10 · United States District Court for the District of Arizona

District of Arizona on 2026-03-10 in Hunter v. TForce Freight Incorporated found the self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

10 Arizona law recognizes for a viable wrongful termination claim. And he must identify 11 when the defamatory statement was made, who made it, and how it was conveyed to a third 12 party. 13 Finally, some of Hunter’s filings suggest he may be using generative artificial 14 intelligence (“generative AI”).3 The court has a …

2026-03-06 · United States District Court for the District of Massachusetts

District of Massachusetts on 2026-03-06 in Gregory J. Van Etten v. Stephanie K. Fattman, et al. found the self-represented party's motion contained three citation defects, including Ankenbrandt v. Richards and Seminole Tribe v. Florida, involving mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

[ECF No. 139 at 2]. This objection reflects a fundamental misunderstanding of the statutory framework governing reports and recommendations and is without merit. 1 Under 28 U.S.C. § 1 It appears to the Court that Plaintiff relies on generative AI to make statements of law. However, the Court warns Plaintiff that generative AI does not …