Incident Tracker / United States (state)
Sheerer v. Panas
On 2026-03-19, California Court of Appeal, First District reversed the child-support order but declined monetary sanctions after the self-represented respondent admitted AI-caused fake citations and quotations. A self-represented party submitted an appellate brief with two false quotations and fabricated or nonexistent authorities, including In re Marriage of Thomson and Keitel v. Heubel, supra.
- Court
- Court of Appeal of the State of California, First Appellate District, Division Four
- Date
- 2026-03-19
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Panas's respondent's brief attributed quotes to published cases in which no such quote appears, cited cases that do not exist, and cited real authorities for topics they did not discuss.
- Outcome
- Filing struck
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-08
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Similar incidents on the record
- Shannon v. Shannon, 322 Neb. 451 (2026), No. S-25-5462026-10-02 · Nebraska Supreme Court · Filing struckIn Nebraska, the state Supreme Court struck a self-represented divorce litigant's appellate brief for fictitious citations produced by his admitted AI use. Extending Prososki v. Regan to unrepresented parties, it held s…
- Tapscott v. Fariss, No. 25-1666 (Iowa Ct. App. 2026)2026-10-07 · Court of Appeals of Iowa · DismissalIn the Court of Appeals of Iowa, a self-represented appellant's final brief in a protective-order appeal contained multiple hallucinated case citations. After two earlier briefs were struck and the appellant failed to a…
- Washington v. Justice, No. 2D2025-2678 (Fla. 2d DCA 2026)2026-10-07 · District Court of Appeal of Florida, Second District · DismissalIn Florida's Second District Court of Appeal, self-represented appellants filed a brief citing eleven cases the court could not find and likely generated by AI. After an unavailing show-cause response and a pattern of f…
- R. M. v. Mohr, 353 Or App 182 (2026), A1880922026-09-23 · Oregon Court of Appeals · FineIn Oregon, the Court of Appeals ordered a self-represented restraining-order appellant to pay $250 after his brief cited three fabricated cases he admitted came from AI. The court had threatened $1,500, at $500 per fake…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Sheerer v. Panas”, safelegalai.com/tracker/anna-sheerer-v-thomas-panas (accessed 2026-10-07). Data: CC BY 4.0.