Incident Tracker / United States (state)
Estate of Claxton
·Arizona Court of Appeals·US-STATEOtherprovisional
On 2026-05-18, in Estate of Claxton, Arizona Court of Appeals affirmed and declined to find waiver despite several fictitious or inaccurate citations in the appellant's brief. A self-represented appellant filed a brief using several nonexistent or hallucinated authorities. The document links the problem to GAI.
- Court
- Arizona Court of Appeals
- Date
- 2026-05-18
- Who used the AI
- Litigant in person
- AI tool
- GAI
- Conduct
- A self-represented appellant filed a brief using several nonexistent or hallucinated authorities.
- Outcome
- Other
- 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
- 2026-09-07
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
- Elliott v. New York Bariatric Group, LLC, No. AAN-CV-25-6066141-S (Conn. Super. Ct.)2026-08-06 · Connecticut Superior Court, Judicial District of Ansonia-Milford · OtherIn what commentators describe as the first documented prompt-injection attempt aimed at a US court, a Connecticut Superior Court judge found that a self-represented plaintiff had hidden white-on-white instructions telli…
- 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…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Estate of Claxton”, safelegalai.com/tracker/estate-of-claxton (accessed 2026-09-08). Data: CC BY 4.0.