Incident Tracker / United States (state)
Tapscott v. Fariss, No. 25-1666 (Iowa Ct. App. 2026)
·Court of Appeals of Iowa·US-STATEDismissal
In the Court of Appeals of Iowa, a self-represented appellant's final brief in a protective-order appeal contained multiple hallucinated case citations. After two earlier briefs were struck and the appellant failed to answer the court's order to produce or explain the suspect citations, the court dismissed the appeal.
- Court
- Court of Appeals of Iowa
- Date
- 2026-10-07
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- The self-represented appellant's final brief contained multiple hallucinated citations after two earlier briefs had been struck for non-compliance with the appellate rules. The court issued an order asking him to produce the cases he relied on or explain the citations; he did not respond, and the court dismissed the appeal.
- Outcome
- Dismissal
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-10-07
What was fabricated or misused
- Multiple hallucinated case citations in the appellant's final brief; the appellant did not provide the cases or explain them when ordered
What the court said
“Tapscott has repeatedly failed to follow our rules of appellate procedure and failed to respond to our order regarding suspected hallucinated case citations, so we dismiss his appeal.”
“When Tapscott submitted his final brief, we discovered multiple hallucinated citations in Tapscott's appellant's brief. Although we issued an order asking Tapscott to provide the cases he relied on or to explain the citations, Tapscott did not respond to our order.”
Timeline
- Court dismissed the appeal for repeated rule non-compliance and failure to respond to the order on suspected hallucinated citations.
Why this case matters
Iowa's appellate court treated unanswered hallucinated citations as part of a wider failure to comply with its orders and dismissed on that combined basis, citing In re R.A. (Iowa Ct. App. 2025), where it had struck a brief as a sanction for hallucinated caselaw. The case shows how a litigant in person who ignores a court's inquiry into fake citations loses the appeal without a separate monetary sanction.
Practice note
When a court flags suspected hallucinated citations and orders a party to produce or explain them, silence makes dismissal more likely. A self-represented litigant should answer such an order directly, provide the authorities relied on, and withdraw any that cannot be verified in an official reporter or database.
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, “Tapscott v. Fariss, No. 25-1666 (Iowa Ct. App. 2026)”, safelegalai.com/tracker/tapscott-v-fariss (accessed 2026-10-07). Data: CC BY 4.0.