Incident Tracker
39 verified incidents · as of 2026-09-05
2026-09-03Regulatory referral
Douglas v. Deutsche Bank National Trust Co.In the District of Columbia Court of Appeals, Deutsche Bank's appellee brief cited four nonexistent authorities after counsel used Google's generative AI search tool without verification. The court struck the brief, referred the matter to the Office of Disciplinary Counsel and sent the sanctions-authority question to its Rules Committee.
2026-08-31Warning
State v. PrestiOn a Hawaii criminal appeal, self-represented appellant Cody Presti filed an opening brief citing 95 cases, 11 of which the court could not locate; six citations pointed to unrelated decisions. The Intermediate Court of Appeals treated arguments supported by nonexistent authority as waived, affirmed the conviction and warned that similar filings can trigger sanctions.
2026-08-28Warning
Noble v. WMC Mortgage Corp., 2026 IL App (1st) 251168-UIn Illinois, self-represented litigant Sanja Noble's mortgage appeal brief included a hallucinated citation to Ferguson v. Georges for the standard of review. The Appellate Court found the citation actually led to People v. Mott, declined to strike the brief, disregarded unsupported assertions and affirmed denial of her petition.
2026-08-27Warning
Kiser v. DeSimone Auto GroupIn Pennsylvania, counsel for Paige and Ty Kiser cited a non-existent Superior Court decision, Com. v. Reid, for an appellate issue in a consumer dispute. The Superior Court called the authority counterfeit, suggested chatbot use as an explanation, treated the issue as waived for underdevelopment, and affirmed judgment for the auto-dealer defendants.
2026-08-27Warning
Salloum v. Department of TransportationIn Colorado, self-represented appellant Ayman Salloum filed an opening brief citing three authorities the Court of Appeals could not verify, including one dated in the future. Applying Al-Hamim's warning on generative-AI hallucinations, the court declined sanctions but cautioned that future filings with unverified AI-generated authority may be sanctioned.
2026-08-27Sanctions
Varma v. The Bank of New York MellonThe California Court of Appeal sanctioned self-represented appellants in Varma after their opening brief used nonexistent cases, false quotations and unsupported propositions the court attributed to generative AI hallmarks. The court ordered them to pay respondent's appellate fees in an amount to be set by the trial court and sent the opinion to the State Bar.
2026-08-25Warning
Benjamin v. StateIn Maryland, appellate counsel filed a criminal brief with multiple inaccurate citations. The Appellate Court compared the problem to Mezu, said fake AI-generated cases are improper, accepted counsel's corrective efforts, declined to refer counsel to the Attorney Grievance Commission and warned lawyers to verify all AI-generated citations before filing.
2026-08-25Sanctions
LPC Commercial Services, LLC v. Ar-Razzaaq Properties, LLC, Record No. 1407-25-4 (Va. Ct. App.)In Virginia, appellee's counsel in LPC Commercial Services filed a brief with 25 phantom quotations attributed to Virginia cases, which the Court of Appeals attributed to unchecked computer-assisted research. The court affirmed the judgment, ordered counsel to complete AI or appellate-practice CLE within six months, and noted that no monetary losses were claimed or established.
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