Von Geitz v Kelly & Ors; Von Geitz v Robertson & Ors, [2026] IECA 29
·Court of Appeal (Ireland)·IEDismissal
In the Irish Court of Appeal, Allen J found self-represented plaintiff Juerg Von Geitz's submissions across two appeals contained unsupported propositions, wrong citations and 'a few non-existent cases' suggested to be AI hallucinations. He dismissed both appeals, affirmed the High Court's strike-out and Isaac Wunder orders, and stressed the litigant's own duty to verify AI output.
- Court
- Court of Appeal (Ireland)
- Date
- 2026-03-16
- Who used the AI
- Not recorded
- AI tool
- Not identified in the record
- Conduct
- A self-represented plaintiff's written submissions across two appeals were, per Allen J, 'littered with' unsupported propositions, wrong citations 'and a few non-existent cases'. At the appeal hearing it was suggested the non-existent cases were hallucinations generated by AI; the court stressed that verifying them remained the litigant's responsibility.
- Outcome
- Dismissal
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- Not separately recorded
What was fabricated or misused
- Sheehan v. Talos Capital Ltd. [2023] IEHC 454 — citation in notice of appeal was obviously wrong and may have been another hallucination; Court treated it as Sheehan v. Talos Capital Ltd. [2021] IECA 316
- Article 40.3 of the Constitution or Article 6 of the ECHR fair-hearing submission about Flynn O’Driscoll LLP representing itself — appeared to be a hallucination which may have been generated by AI
- Plaintiff's written submissions contained wrong citations and a few non-existent cases; the Court did not list the case names
What the court said
“The citation in the notice of appeal is obviously wrong – it may be another hallucination – but I take the ground as referring to the judgment of this Court in Sheehan v. Talos Capital Ltd. [2021] IECA 316.”
“The suggestion that the fact that the firm represented itself infringed the principle of nemo judex in cause sua or the plaintiff’s right to a fair hearing under Article 40.3 of the Constitution or Article 6 of the ECHR appears to be a hallucination which may have been generated by AI.”
“The plaintiff’s written submissions are littered with propositions of law in quotation marks which are unsupported by authority; reference to authorities which have nothing to do with the asserted propositions of law; wrong citations; and a few non-existent cases.”
“it was nevertheless the responsibility of the plaintiff – as it is of every litigant – to check whatever may have been thrown up by whatever tool he used to ensure in the short term that his opponents were not sent on a wild goose chase and ultimately that the Court was not presented with rubbish.”
Timeline
- High Court delivered judgment striking out the two actions.
- High Court orders restrained further proceedings without leave.
- Plaintiff filed notice of appeal in the Kelly action.
- Plaintiff filed notice of appeal in the Robertson action.
- Court of Appeal dismissed both appeals and affirmed the orders.
Why this case matters
Von Geitz is the companion Irish appellate record to Guerin. It came first, but it was narrower: Allen J identified suspected AI hallucinations while deciding strike-out and Isaac Wunder appeals, without issuing the five principles later set out in Guerin. The case is useful because it treats a self-represented litigant's written submissions as his responsibility even when a tool may have generated the bad material. It also shows that AI-suspected errors can appear inside wider abusive-litigation findings rather than as a standalone sanctions dispute.
Practice note
A self-represented appellant should keep a table of authorities with the source, citation and exact proposition for each case. Any AI-suggested case should be opened and checked before service. If the citation is wrong, the case is unrelated, or no judgment can be found, the argument should be removed instead of leaving the opponent and court to resolve it.
Primary sources for this incident
Related regulation records for this incident
Similar incidents on the record
- Guerin v O'Doherty, [2026] IECA 482026-03-26 · Court of Appeal (Ireland) · DismissalIn the Irish Court of Appeal, self-represented appellant Gemma O'Doherty filed AI-prepared submissions citing authorities that did not exist and never disclosed her use of AI. Costello P dismissed her appeal and issued…
- Ferko v Beyond Reach Ltd t/a Car Wash Crew, ADJ-000606222026-03-02 · Workplace Relations Commission · DismissalBefore Ireland's Workplace Relations Commission, complainant Imrich Ferko's complaint form was prepared by his sister using AI, and he admitted not verifying it before submission. Adjudication Officer Christina Ryan gav…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Von Geitz v Kelly & Ors; Von Geitz v Robertson & Ors, [2026] IECA 29”, safelegalai.com/tracker/von-geitz-v-kelly (accessed 2026-09-16). Data: CC BY 4.0.