Incident Tracker

Guerin v O'Doherty, [2026] IECA 48

dismissal

In the Irish Court of Appeal, self-represented appellant Gemma O'Doherty filed AI-prepared submissions citing authorities that did not exist and never disclosed her use of AI. Costello P dismissed her appeal and issued Ireland's first appellate guidance on AI in litigation: five principles requiring responsible use, disclosure of AI use, and independent verification of every authority.

Date of decision/order

2026-03-26

Court

Court of Appeal (Ireland)

Jurisdiction

IRELAND

AI tool

Not identified in the record

Conduct

A self-represented appellant used AI to prepare her written submissions, which cited authorities that did not exist — described by the court as hallucinations generated by the AI system — and did not tell the opposing solicitors or the court that she had used AI. Counsel wasted time trying to locate the fabricated cases.

Consequence

See outcome