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Incident Tracker / United States (state)

Al-Hamim v. Star Hearthstone, LLC, 2024 COA 128

·Colorado Court of Appeals·US-STATEWarning

In the Colorado Court of Appeals, a self-represented appellant's brief contained generative-AI hallucinated citations. On this novel question for Colorado, the division declined to impose sanctions on these facts but formally put lawyers and self-represented parties on notice that future filings containing AI-generated hallucinations may be sanctioned.

Court
Colorado Court of Appeals
Date
2024-12-26
Who used the AI
Not recorded
AI tool
Not identified in the record
Conduct
A self-represented appellant filed a brief peppered with generative-AI-generated citations that did not exist. On a novel question for Colorado, the division declined to impose sanctions on these facts but issued a formal warning for the future.
Outcome
Warning
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • Beck v. Tibbetts, 967 P.2d 150 (Colo. 1998) — fake case
  • Jankowski v. Cross, 672 P.2d 1178 (Colo. App. 1983) — fake case
  • L&M Inv. Co. v. Morrison, 469 P.2d 516 (Colo. App. 1970) — fake case
  • Jaramillo v. Cowen, 768 P.2d 1378 (Colo. App. 1989) — fake case
  • In re Estate of Henry, 2012 COA 169, 301 P.3d 107 (Colo. App. 2012) — fake case
  • Jaramillo v. Steiner, 212 P.3d 1188 (Colo. App. 2009) — fake case
  • Rojas v. Lindsay Mfg. Co., 108 Cal. App. 4th 530 (2003) — fake case
  • Robinson v. Lennox Hill Hospital, 513 N.Y.S.2d 607 (App. Div. 1987) — fake case

What the court said

“But these citations may be fictitious. Case names and citations that a GAI tool makes up are known as “hallucinations.””
Colorado Court of Appeals, [2]
“Al-Hamim’s opening brief contains citations to the following fake cases:”
Colorado Court of Appeals, [25]
“In his response to our show cause order, Al-Hamim admitted that he relied on AI “to assist his preparation” of his opening brief, confirmed that the citations were hallucinations, and that he “failed to inspect the brief.””
Colorado Court of Appeals, [26]
“A lawyer’s or a self-represented party’s future filing in this court containing GAI-generated hallucinations may result in sanctions.”
Colorado Court of Appeals, [41]

Timeline

  1. Al-Hamim filed his opening brief more than a year after national reporting on Mata v. Avianca.
  2. Colorado Court of Appeals announced its opinion and affirmed dismissal of the landlord-tenant claims.
  3. Court identified eight fake cases, declined sanctions, and warned future GAI-generated hallucinations may be sanctioned.

Why this case matters

Al-Hamim is the Colorado appellate counterpart to Kruse v. Karlen, but with the opposite sanction result. Kruse involved twenty-two fictitious citations and ended with dismissal plus a $10,000 award. Here, the division held that a self-represented appellant’s hallucinated citations violated C.A.R. 28(a)(7)(B), yet declined sanctions because the issue was novel in Colorado, Al-Hamim accepted responsibility, and the appellees had not requested fees. The warning made future Colorado appellate filings with GAI hallucinations sanctionable for both lawyers and self-represented parties.

Practice note

Do not cite a case from a general-purpose AI answer until the full opinion has been found in an official reporter, court site, or trusted legal database. For a Colorado appeal, the opening brief must contain real authorities that support the argument under C.A.R. 28(a)(7)(B). If a citation cannot be located, remove it before filing rather than asking to amend after a show-cause order.

Primary sources for this incident

Related regulation records for this incident

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  • Noble v. WMC Mortgage Corp., 2026 IL App (1st) 251168-U2026-08-28 · Appellate Court of Illinois, First District · WarningIn 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 Peopl…
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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Al-Hamim v. Star Hearthstone, LLC, 2024 COA 128”, safelegalai.com/tracker/al-hamim-v-star-hearthstone (accessed 2026-09-16). Data: CC BY 4.0.

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