Incident Tracker / United States (federal)
Lichfield v. Kubler; Netflix, Inc., No. 25-4135 (10th Cir.)
·US Court of Appeals for the Tenth Circuit·US-FEDWarning
Affirming dismissal of a defamation suit over a Netflix documentary, the US Court of Appeals for the Tenth Circuit noted that the appellant's brief cited a case that does not exist and misdescribed two others. Assuming generative AI was responsible, the court issued a published admonishment but stopped short of the sanctions it imposed in Amarsingh v. Frontier Airlines.
- Court
- US Court of Appeals for the Tenth Circuit
- Date
- 2026-07-27
- Who used the AI
- Lawyer
- AI tool
- Not identified in the record
- Conduct
- Appellant's counsel from Hepworth Legal of Bountiful, Utah, cited a nonexistent authority and mischaracterised two real cases in the opening brief of a defamation appeal concerning a Netflix documentary. The court assumed generative AI was responsible.
- Outcome
- Warning
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Lichfield v. Kubler; Netflix, Inc., No. 25-4135 (10th Cir.)”, safelegalai.com/tracker/lichfield-v-kubler (accessed 2026-09-04). Data: CC BY 4.0.