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Incident Tracker / United States (state)

Salloum v. Department of Transportation, No. 25CA1748 (Colo. App.)

·Colorado Court of Appeals·US-STATEWarning

In 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-AI hallucinations, the court declined sanctions but cautioned that future filings with unverified AI-generated authority may be sanctioned.

Court
Colorado Court of Appeals
Date
2026-08-27
Who used the AI
Litigant in person
AI tool
Not identified in the record
Conduct
Self-represented appellant Ayman Salloum cited three authorities the court could not verify, including one purported appellate decision dated in the future. The court said the brief appeared to reflect generative-AI drafting, applied Al-Hamim, declined sanctions, and warned that future AI-caused errors may be sanctioned.
Outcome
Warning
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • Lawrence v. School District No. 1, 201 P.3d 1124 (Colo. App. 2008) — court said it did not appear to exist
  • St. John’s Regional Medical Center v. Department of Labor, 832 P.2d 103 (Colo. App. 1992) — court said it did not appear to exist
  • Pierce v. Douglas County School District, 2029 COA 149 — purported to be from three years in the future

What the court said

“because he is self-represented, we exercise our discretion to address Salloum’s arguments to the extent that we understand them”
Colorado Court of Appeals, ¶ 14
“This suggests that portions of Salloum’s brief may have been drafted with the use of generative artificial intelligence (GAI).”
Colorado Court of Appeals, ¶ 16
“errors caused by GAI in future filings may result in sanctions”
Colorado Court of Appeals, ¶ 18

Timeline

  1. Salloum asked to work from home rather than attend the next day’s event.
  2. Environmental unit’s optional holiday party was scheduled.
  3. Colorado Court of Appeals affirmed and warned about future GAI errors.

Why this case matters

Salloum is a direct follow-on to Al-Hamim in the same appellate court. Al-Hamim warned that future GAI-caused citation errors could lead to sanctions; Salloum applied that warning to another self-represented brief but again chose notice rather than a penalty. The opinion is useful because it lists the defective authorities and shows how the court handled them without avoiding the merits of the employment appeal. It also treats a future-dated Colorado appellate citation as an obvious verification failure.

Practice note

A Colorado appellate filer should run every case name and reporter cite through an official source before filing, then check the date and court. A future-dated decision or unmatched reporter cite should be deleted unless it can be verified. Self-represented status does not remove the duty to comply with C.A.R. 28.

Primary sources for this incident

Related regulation records for this incident

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  • 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…
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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Salloum v. Department of Transportation, No. 25CA1748 (Colo. App.)”, safelegalai.com/tracker/salloum-v-department-of-transportation (accessed 2026-10-07). Data: CC BY 4.0.

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