Court rules adopted by opinion or order

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 …

2026-08-03 · 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 · 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 …

2026-07-31 · 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, …

2026-07-31 · Government Accountability Office · provisional

GAO dismisses JAAW’s bid protest as factually insufficient and separately addresses AI-associated citation problems. The decision notes one nonexistent GAO citation and one irrelevant Federal Circuit citation, declines sanctions because dismissal rests on other grounds, and warns future filings may be sanctioned.

In addition to the factual inaccuracies discussed above, JAAW offered, in support of its protest arguments, citations to five bid protest decisions--two decisions of our Office and three decisions of the U.S. Court of Appeals for the Federal Circuit. ... Based on these inaccurate legal citations, the Army posited that JAAW’s protest “bears indicia consistent …

2026-07-30 · Texas Court of Appeals, Fourteenth District · provisional

The Fourteenth Court of Appeals affirms a child-custody modification judgment and sanctions Father’s lawyer. The court finds fabricated quotations from Harrison and Swim, unsupported assertions from Lenz and A.S., assumes AI hallucination rather than deliberate deception, and orders three additional hours of AI-focused CLE.

Finally, some discussion of appellant’s brief is warranted. As previously mentioned, appellant’s brief is disjointed and difficult to follow. However, that is not the only shortcoming of appellant’s briefing. It is obvious that appellant’s brief was either (1) the result of using artificial intelligence yielding hallucination citations or (2) a deliberate attempt to mislead this …

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 · 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 …

2026-07-28 · 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 · Appellate Court of Illinois, First District · 2026 IL App (1st) 251462

The Illinois First District affirms dismissal of Kimberly Scott’s discrimination charge and sanctions attorney Mason Cole. The opinion says ChatGPT produced 10 false citations or quotations, fines Cole $15,000 at $1,500 per misstatement, and directs the clerk to send the opinion to the ARDC.

We also sanction petitioner’s attorney Mason Cole for submitting briefs containing false citations and quotations that are the product of artificial intelligence (AI) hallucinations. ... Petitioner’s briefs also contain false case citations. One such case, “Harris v. Illinois Human Rights Comm’n, 2022 IL App (1st) 210454,” does not exist at all. The citation 2022 IL …

2026-07-28 · United States District Court for the District of Arizona · 2026 WL 2167989 · provisional

The District of Arizona expands an AI show-cause inquiry against Elizabeth Tate. The order recounts Tate’s Claude AI workflow, finds that list-based cite checking missed false quotations in several filings, criticizes delegating whole-brief drafting to Claude, and requires a supplemental memorandum.

On July 8, 2026, the Court issued an order to show cause (“OSC”) requiring Plaintiff's counsel, Elizabeth Tate, to show cause why she should not be sanctioned or disciplined for including, in Plaintiff's response to Defendant's motion for attorneys’ fees, two false quotations from Ninth Circuit cases. ... Ms. Tate utilized Claude AI to help …

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 …

2026-06-26 · Supreme Court of Texas · Misc. Docket No. 26-9054 · provisional

The Texas Supreme Court preliminarily approves amendments to civil and appellate filing rules. Comments explain that the changes address improper AI use by reinforcing attorneys’ and self-represented parties’ obligation to verify authorities, quotations, and holdings before filing.

Rule 13 has been rewritten to modernize the rule and reinforce the obligation of attorneys and self-represented parties to verify documents filed with the court. Paragraphs (a) and (b) incorporate the requirements in current Rule 57. Paragraph (c)(1) is adopted principally to address concerns about the improper use of artificial intelligence in filings, which increases …

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 …

2026-02-18 · Oklahoma Court of Criminal Appeals · 2026 OK CR 7 · provisional

The Oklahoma Court of Criminal Appeals adopts a procedural rule for generative-AI use in filings. Rule 1.17 requires parties or counsel to verify AI-generated or AI-modified content for accuracy and makes noncompliant filings subject to sanctions.

Recognizing the novel and rapid development of generative artificial intelligence ("generative AI") and its use in the practice of law, as well as its potential to produce misinformation or even to hallucinate, Rules of the Oklahoma Court of Criminal Appeals, Title 22, Ch.18, App. (2026), set forth as follows: Section I. GENERAL RULES OF THE …

2025-12-11 · Supreme Court of Arkansas · 2025 Ark. 221

The Arkansas Supreme Court adopts professional-conduct amendments addressing lawyers’ use of artificial intelligence and other nonhuman assistance. The amendments say AI use is not barred but does not excuse rule violations, and Rule 5.3 supervision includes generative-AI platforms.

On June 5, 2025, we published proposed amendments to the Arkansas Rules of Professional Conduct addressing the impact of the expansion of artificial intelligence for the legal practice in Arkansas. See In re Amends. to the Ark. Rules of Prof’l Conduct, 2025 Ark. 115 (per curiam). The amendments add a paragraph to the Preamble and …

2025-12-11 · Supreme Court of Arkansas · 2025 Ark. 220

The Arkansas Supreme Court adopts Administrative Order No. 25 after a comment period with no substantive comments. The new order requires court participants to consider confidentiality and data-retention risks before entering court or client data into generative-AI systems.

On June 5, 2025, we published for comment a proposed Administrative Order No. 25: Artificial Intelligence. It specifically addressed the use of generative artificial intelligence with confidential court data. See In re Creation of Ark. Sup. Ct. Admin. Order No. 25, 2025 Ark. 117 (per curiam). The comment period closed without substantive comments. The court …

2025-06-05 · Supreme Court of Arkansas · 2025 Ark. 117

The Arkansas Supreme Court proposes Administrative Order No. 25, a court-system AI rule focused first on generative-AI use with confidential court data. The opinion invites comments while warning that lawyers, court personnel, and the public may use AI intentionally or inadvertently.

The use of AI has become increasingly prominent. Members of the public, attorneys, and personnel who interact in the State’s justice system may be using it intentionally, or even unintentionally. We now publish for comment the proposed new Administrative Order No. 25: Artificial Intelligence. It begins by specifically addressing the use of generative artificial intelligence …

2025-06-05 · Supreme Court of Arkansas · 2025 Ark. 115

The Arkansas Supreme Court publishes for comment professional-conduct amendments responding to artificial intelligence in legal practice. The per curiam order describes joint study by court and bar committees and proposes changes clarifying lawyers’ duties when using nonhuman assistance.

In response to the growing use of artificial intelligence, the Supreme Court of Arkansas Committee on Automation created a subcommittee to study the use of artificial intelligence in courts. Likewise, the Arkansas Bar Association formed the Task Force on Artificial Intelligence. The two have worked together to review how the expansion of artificial intelligence impacts …

2025-01-01 · Supreme Court of Illinois

The Illinois Supreme Court policy authorizes responsible AI use by court users, lawyers, judges, and staff while stressing accuracy, bias, confidentiality, and accountability. It states that AI use should not be discouraged and generally should not require pleading disclosure.

Embracing the advancements of artificial intelligence (AI), the Illinois Supreme Court remains steadfast in its commitment to upholding the highest ethical standards in the administration of justice. We acknowledge the rapid development of generative AI technologies capable of producing human-like text, images, video, audio, and other content. The integration of AI with the courts is …

2024-10-21 · Supreme Court of Delaware

The Delaware Supreme Court adopts an interim policy governing generative-AI use by judicial officers and court personnel. The order emphasizes that GenAI may assist official work only under a policy designed to protect judicial, legal, and professional judgment.

WHEREAS, the DCLT has recommended adoption of the attached interim policy for the use of Generative Artificial Intelligence (“GenAI”) by judicial officers and court personnel; WHEREAS, the Interim Policy is intended to ensure the safe and appropriate use of GenAI by judicial officers and court personnel, but not be used as a substitute for judicial, …