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Incident Tracker / United States (state)

Kurt Williams v. Karin Kirch (Ind. Ct. App. 2025), No. 25A-SC-00196

·Court of Appeals of Indiana·US-STATEWarning

The Indiana Court of Appeals admonished a self-represented appellant who cited fictitious authorities the court found were likely produced by generative AI. Because the opposing party sought no sanction, the court imposed none, using the decision to warn litigants about relying on unverified AI output.

Court
Court of Appeals of Indiana
Date
2025-08-18
Who used the AI
Not recorded
AI tool
generative AI (suspected)
Conduct
A self-represented appellant cited fictitious authorities the court found were likely generated by AI. The opposing party sought no sanction, so the court admonished him without imposing a penalty.
Outcome
Warning
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

  • Davis v. United States, 569 U.S. 764 (2013) — cited in opening brief; does not exist
  • Bourne v. Scarborough (IN 2014) — cited in opening brief; does not exist
  • In re Marriage of Nigh, 2016 IL App (5th) 150274 — cited in opening brief; does not exist

What the court said

“Generative AI can produce citations to non-existent authorities, and we caution litigants to verify citations before including them in briefs.”
Court of Appeals of Indiana, [2]
“We must address a troubling aspect of Williams’s brief. He cites several “cases” in his opening brief that do not exist.”
Court of Appeals of Indiana, [11]
“But because Kirch does not request any sanction or relief for this conduct, we find it sufficient to admonish Williams for citing fictitious cases in his brief.”
Court of Appeals of Indiana, [12]
“Judges must be able to rely on the authenticity of the authorities cited by the parties to make just decisions.”
Court of Appeals of Indiana, [12]

Timeline

  1. Court of Appeals filed its opinion affirming the small-claims judgment and $650 fee award.
  2. Opinion identified three nonexistent cases in Williams’s opening brief.
  3. Because Kirch requested no sanction, court admonished Williams and warned litigants to verify AI citations.

Why this case matters

Williams applies the AI-citation warning pattern to a small-claims appeal with a self-represented appellant. Like Al-Hamim, the appellate court declined sanctions after finding fictitious citations. The reason was narrower: the appellee did not ask for relief for the citation problem. The opinion still named the false authorities and made the citation check a duty of both lawyers and pro se litigants. That makes the record useful for lower-value civil disputes where AI research tools may appear attractive because paying for legal research is disproportionate.

Practice note

Before filing an Indiana appellate brief, verify every cited case in an official reporter, the Indiana courts site, CourtListener, Westlaw, Lexis, or another reliable database. A pro se party should not treat an AI answer as authority. If the opposing party identifies nonexistent cases, the reply brief should explain and correct them, not leave the issue unanswered.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

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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…
  • Noble v. WMC Mortgage Corp., 2026 IL App (1st) 251168-U2026-08-28 · Appellate Court of Illinois, First District · WarningIn Illinois, self-represented litigant Sanja Noble's mortgage appeal brief included a hallucinated citation to Ferguson v. Georges for the standard of review. The Appellate Court found the citation actually led to Peopl…
  • Kiser v. DeSimone Auto Group, No. 2428 EDA 2025 (Pa. Super. Ct.)2026-08-27 · Superior Court of Pennsylvania · WarningIn Pennsylvania, counsel for Paige and Ty Kiser cited a non-existent Superior Court decision, Com. v. Reid, for an appellate issue in a consumer dispute. The Superior Court called the authority counterfeit, suggested ch…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Kurt Williams v. Karin Kirch (Ind. Ct. App. 2025), No. 25A-SC-00196”, safelegalai.com/tracker/williams-v-kirch (accessed 2026-09-16). Data: CC BY 4.0.

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