Incident Tracker / United States (state)
Shannon v. Shannon, 322 Neb. 451 (2026), No. S-25-546
·Nebraska Supreme Court·US-STATEFiling struck
In Nebraska, the state Supreme Court struck a self-represented divorce litigant's appellate brief for fictitious citations produced by his admitted AI use. Extending Prososki v. Regan to unrepresented parties, it held such briefs sanctionable, reviewed only for plain error, affirmed, and warned that future appeals may be dismissed outright.
- Court
- Nebraska Supreme Court
- Date
- 2026-10-02
- Who used the AI
- Litigant in person
- AI tool
- Generative AI (admitted; tool unnamed)
- Conduct
- A self-represented appellant challenging a civil contempt order and 90-day jail sanction in a divorce case filed a brief containing citations to fictitious cases, fabricated quotations and misstatements of law, which the court said resulted from his admitted use of generative AI.
- Outcome
- Filing struck
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-10-05
What was fabricated or misused
- Citations to fictitious cases and fabricated quotations in the appellant's brief
- Misstatements of Nebraska law supporting the challenge to the contempt finding
What the court said
“his brief contains numerous citations to fictitious cases and misstatements of law, which are the result of his admitted use of generative artificial intelligence (AI).”
“regardless of whether a party is represented or self‑represented, submission of a brief that contains misstatements of law or relies upon nonexistent legal authority is an abuse of the judicial process worthy of sanctions.”
“However, in future cases, dismissal of the appeal in lieu of plain error review may follow.”
Timeline
- Nebraska Supreme Court struck the appellant's brief, reviewed for plain error and affirmed.
Why this case matters
In Prososki v. Regan earlier in 2026 the Nebraska Supreme Court struck a lawyer's brief, dismissed the appeal and referred the lawyer for discipline. Shannon applies the same standard to self-represented parties for the first time in Nebraska. The court stopped short of dismissal because the rule for unrepresented litigants was new, and gave notice that dismissal may follow in future cases.
Practice note
Self-represented appellants in Nebraska are held to the same citation standard as lawyers, and a brief with AI-generated fake authority can be struck. After this opinion, dismissal of the appeal is a stated risk. Every case and quotation in an appellate brief should be checked against the published opinion before filing.
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, “Shannon v. Shannon, 322 Neb. 451 (2026), No. S-25-546”, safelegalai.com/tracker/shannon-v-shannon (accessed 2026-10-05). Data: CC BY 4.0.