Incident Tracker / United States (state)
In re Estate of Pangelinan
·Supreme Court of Guam·US-STATEWarningprovisional
The Supreme Court of Guam observes that two nonexistent citations in a self-represented probate appellant’s brief may be attributable to generative AI. Considering pro se status and a first appearance, it finds sanctions unwarranted but reiterates final-submission duties. Docket CVA25-007.
- Court
- Supreme Court of Guam
- Date
- 2026-07-15
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Schacher’s opening brief contained two nonexistent citations that the court said may be attributed to generative artificial intelligence use.
- Outcome
- Warning
- 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.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “In re Estate of Pangelinan”, safelegalai.com/tracker/in-re-estate-of-pangelinan (accessed 2026-09-11). Data: CC BY 4.0.