Skip to content

Incident Tracker / United States (state)

Brankle v. Schmell

·Court of Appeals of Indiana·US-STATECosts orderprovisional

The Court of Appeals of Indiana affirms the denial of David Brankle’s motion to compel and a $1,546 expenses award. The memorandum quotes the trial court’s finding that Brankle cited nonexistent rules and fictitious cases suggesting ChatGPT use, and holds hallucinated authorities cannot substantially justify the motion.

Court
Court of Appeals of Indiana
Date
2026-08-14
Who used the AI
Litigant in person
AI tool
ChatGPT or other form of artificial intelligence
Conduct
Self-represented litigant cited nonexistent Commercial Court Rules and fictitious cases in a motion to compel and related filings.
Outcome
Costs order
Penalty
US$1,546
Regulatory outcome
No separate regulatory disposition recorded
Status
Provisional — written by the court-decisions pipeline, awaiting the editor
Last checked
2026-09-07

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

  • State v. Presti, No. CAAP-24-0000826 (Haw. Ct. App.)2026-08-31 · Hawaii Intermediate Court of Appeals · WarningOn 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…
  • 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…
  • Salloum v. Department of Transportation, No. 25CA1748 (Colo. App.)2026-08-27 · Colorado Court of Appeals · WarningIn 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-A…
  • Varma v. The Bank of New York Mellon, No. E085566 (Cal. Ct. App.)2026-08-27 · California Court of Appeal, Fourth Appellate District, Division Two · SanctionsThe 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 hallma…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Brankle v. Schmell”, safelegalai.com/tracker/brankle-v-schmell (accessed 2026-09-08). Data: CC BY 4.0.

Report an issue with this record →