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Incident Tracker / United States (state)

Bethany Cingel v. Gregory Ferreri (Ind. Ct. App. 2025), No. 25A-DC-00500

·Court of Appeals of Indiana·US-STATEWarning

The Indiana Court of Appeals affirmed against a self-represented appellant in a domestic-relations appeal whose brief cited 23 authorities, 14 of them nonexistent, finding she had likely used generative AI. The court cautioned her about relying on unverified AI output but imposed no sanction, the opposing party having sought none.

Court
Court of Appeals of Indiana
Date
2025-09-19
Who used the AI
Not recorded
AI tool
generative AI (suspected)
Conduct
A self-represented appellant's brief cited 23 authorities, 14 of them nonexistent. The court found she had likely used generative artificial intelligence, affirmed the decision below, and cautioned her but imposed no sanction.
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

  • Fourteen of the twenty-three authorities in the Argument did not exist; the court said they included eleven cases, two statutes and one trial rule but did not list all names
  • In re Marriage of Dunston, 989 N.E.2d 830, 835 (Ind. Ct. App. 2013) — appears to not exist
  • Indiana Code § 31-17-2.5-1 — does not exist
  • McCain v. State, 924 N.E.2d 56, 60 (Ind. 2009) — appears to not exist
  • Indiana Code § 31-17-2.2-23(a) — no such statute exists
  • Trial Rule 60.1 and Trial Rule 60.1(A) — do not exist
  • Bowman v. Bowman, 682 N.E.2d 23, 28 (Ind. Ct. App. 1997) — reporter citation led to an Ohio case and real Bowman did not support the stated point
  • Indiana Code § 31-17-2.2-1(a) — misdescribed as a sixty-day notice rule
  • Indiana Code § 31-17-2.2-1(b) — misdescribed as burden-of-proof and relocation-factor authority
  • Trial Rule 59(G) — cited for written orders or hearings on motions to correct error, but the rule concerns cross errors

What the court said

“Cingel cites 23 legal authorities in her Argument: 12 Indiana cases, 6 Indiana statutes, and 5 Indiana rules. Of those 23 legal authorities, 14 do not exist.”
Court of Appeals of Indiana, [9]
“Indiana Code section “31-17-2.5-1” does not exist; the applicable statute is Indiana Code section 31-17-2-8.”
Court of Appeals of Indiana, [10]
“Given Cingel’s citations to nonexistent legal authorities and to real legal authorities that have nothing to do with the propositions they purport to support, it is likely that Cingel used generative artificial intelligence to draft her brief, either in whole or in part.”
Court of Appeals of Indiana, [15]
“We caution attorneys and pro se litigants alike against using AI to conduct legal research without independently verifying the citations generated.”
Court of Appeals of Indiana, [15]

Timeline

  1. Cingel and Ferreri married.
  2. Cingel filed a petition to dissolve the marriage.
  3. Trial court awarded joint legal custody, primary physical custody to Ferreri and denied relocation.
  4. Court of Appeals affirmed and cautioned against unverified AI-generated citations.

Why this case matters

Cingel follows Williams v Kirch in the Indiana Court of Appeals but concerns a domestic-relations brief by a self-represented party. The court counted the problem rather than naming every authority: 14 of 23 cited authorities did not exist, and six of the remaining nine were wrong or misdescribed. Unlike Shahid v Esaam or Noland v Land of the Free, no sanction was imposed because the appellee did not ask for one; the practical consequence was waiver and affirmance.

Practice note

A pro se appellant must meet the same citation rules as a lawyer. Before filing, check each case, statute and rule in an official Indiana source, confirm the reporter citation leads to the named authority, and remove any generated text that cannot be tied to the record. If AI is used, it should be treated as a draft, not as legal research.

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

  • Kurt Williams v. Karin Kirch (Ind. Ct. App. 2025), No. 25A-SC-001962025-08-18 · Court of Appeals of Indiana · WarningThe Indiana Court of Appeals admonished a self-represented appellant who cited fictitious authorities the court found were likely produced by generative AI. Because the opposing party sought no sanction, the court impos…
  • 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…
  • Kiser v. DeSimone Auto Group, No. 2428 EDA 2025 (Pa. Super. Ct.)2026-08-27 · Superior Court of Pennsylvania · WarningIn 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 ch…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Bethany Cingel v. Gregory Ferreri (Ind. Ct. App. 2025), No. 25A-DC-00500”, safelegalai.com/tracker/cingel-v-ferreri (accessed 2026-09-16). Data: CC BY 4.0.

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