Incident Tracker

Dineen/Shibata v. Kotchka, No. 1 CA-CV 25-0606 PB (Ariz. Ct. App.)

sanctions

The Arizona Court of Appeals affirmed a probate ruling and sanctioned self-represented appellant Jeffrey Kotchka, whose opening brief cited hallucinated and misrepresented authorities produced by generative AI. Holding that self-represented litigants must abide by the same rules, the court awarded appellee Kim Dineen the attorneys' fees and costs caused by the fake citations under A.R.S. §12-349 and ARCAP 25.

Date of decision/order

2026-07-15

Court

Arizona Court of Appeals, Division One

Jurisdiction

US-STATE

AI tool

Not identified in the record

Conduct

Self-represented appellant Jeffrey Kotchka's opening brief, challenging a probate ruling, cited hallucinated legal authorities and misrepresented case citations that he obtained through generative AI ('Gen-AI') and did nothing to verify. After the appellee identified the fabrications and after a show-cause hearing, Kotchka neither moved to amend his brief nor withdrew the appeal, continuing to maintain claims unsupported by any valid authority.

Consequence

See outcome