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Incident Tracker / United States (state)

An v. Archblock, Inc. (Del. Ch. 2025)

·Delaware Court of Chancery·US-STATEOther

In the Delaware Court of Chancery, a self-represented litigant's motion to compel relied on false citations produced by generative AI. Vice Chancellor Lori Will denied the motion and issued an order requiring litigants to certify their use of generative AI in future filings, warning that failure to comply may lead to sanctions.

Court
Delaware Court of Chancery
Date
2025-04-04
Who used the AI
Not recorded
AI tool
generative AI (unspecified; court cited ChatGPT, Gemini, Copilot, CoCounsel as examples)
Conduct
A self-represented petitioner's motion to compel cited false and miscited legal authority attributable to his use of generative AI. Vice Chancellor Lori Will denied the motion and, addressing the fabricated citations, entered a standing order for the litigation.
Outcome
Other
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

  • Motion to compel discovery (Dkt. 25) — cited false legal authority and/or miscited legal authority; the certification order did not list the citations

What the court said

“the petitioner filed a motion to compel discovery (Dkt. 25; the “Motion”) that cites false legal authority and/or miscites legal authority;”
Delaware Court of Chancery, p. 1
“the Motion was denied because the petitioner put forward false citations, presumably due to his use of generative artificial intelligence (“GenAI”) in preparing the Motion;”
Delaware Court of Chancery, p. 1
“Any future court filings in this case by the petitioner that are prepared using GenAI must be accompanied by a certification, with a sworn statement by the petitioner,”
Delaware Court of Chancery, p. 2
“Failure to abide by this Order may lead to the issuance of sanctions.”
Delaware Court of Chancery, p. 2

Timeline

  1. Court issued a letter opinion denying the motion to compel because An put forward false citations.
  2. Certification order denied the motion to compel discovery.
  3. Order required future GenAI-assisted filings to disclose tool, sections, and human review.
  4. Order warned non-compliance may lead to sanctions.

Why this case matters

An v. Archblock is not a monetary-sanctions record. Its significance is procedural: a Delaware Chancery judge responded to a self-represented litigant’s false citations by creating a case-specific GenAI certification regime. Unlike Al-Hamim and Williams, which warned future litigants after affirming the underlying judgments, this order imposed a forward-looking disclosure and verification condition inside the same case. It also named common tools, including ChatGPT, Gemini, Copilot, Meta AI, and CoCounsel, without treating use of those tools as misconduct by itself.

Practice note

If a Delaware Chancery filing uses GenAI, file a sworn certification with it. The certification should identify the tool, model, or platform; the pages or sections made with GenAI; and the human review performed. The reviewer must confirm that every cited authority exists and supports the proposition before the filing is served.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “An v. Archblock, Inc. (Del. Ch. 2025)”, safelegalai.com/tracker/an-v-archblock (accessed 2026-09-16). Data: CC BY 4.0.

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