Arizona appeals court strikes a self-represented appellant's AI-hallucinated citations, rejects his probate appeal and orders him to pay fees as a sanction
In a published opinion of July 2026, the Arizona Court of Appeals found that a self-represented appellant's opening brief in a probate dispute contained eight citations, six of them deficient, including two cases that do not exist. In a written explanation and at a hearing on the false citations he acknowledged relying on generative AI to write the brief and said he did nothing to verify the citations. The court struck the inaccurate and false citations, rejected the appeal because no supportive authority remained, held that citing a hallucinated case is sanctionable whether or not it is intended, and ordered him to pay the share of the other party's attorney's fees traceable to the fake citations. Because he said he did not intend to deceive and is not legally trained, the court chose this narrow sanction over contempt or fines. It described the opinion as the first published Arizona ruling on generative AI hallucinations in filings.
- AI system
- Unidentified AI drafting tool
- Occurred
- 15 Jul 2026
- Reported
- 19 July 2026
- Event location
- United States
- What the AI did
- Communicated with the person · Informed a human decision about the person
- Reported harm
- Legal HarmFinancial Loss
- Whose AI use
- Their own AI use
- Setting
- Justice
- Evidence
- AI involvement supported · Causal attribution established · 1 source
- 4 claims: 4 reported. 2 open questions
- People reported harmed
- 1 person
AI system as recorded: Generative AI, not identified in the report, that the appellant said he relied on to write his opening brief, which cited two nonexistent cases and misstated others
What Happened
The appeal. A probate dispute followed a woman's death in 2023; a Maricopa County judge appointed one of her children as personal representative in July 2025, and her son, representing himself, appealed. According to the Arizona Mirror report, his opening brief made eight citations, six of which the court found deficient: some pointed to wrong pages, some attributed rules or facts to cases that did not contain them, and two cases did not exist.
The AI use. In a written explanation and at a hearing on the false citations, he acknowledged relying on generative AI to write the brief, conceded he had not used the court's guidance for self-represented litigants, which includes warnings about AI tools, and testified that he did nothing to verify the citations.
The ruling. The court held that citing a hallucinated case is sanctionable regardless of intent. Because he said he did not intend to deceive and is not legally trained, it imposed a narrow sanction: payment of the share of the other party's attorney's fees traceable to the fake citations. With the false and inaccurate citations struck, the appeal was rejected for lack of supporting authority. The court also said generative AI holds promise for people who cannot afford a lawyer if the signer checks every citation.
Reported harm
According to the court, the appellant's AI-drafted brief cited nonexistent cases; the citations were struck, the appeal was rejected and he was ordered to pay the share of the other party's attorney's fees caused by the fake citations.
Outcome
ResolvedArizona Court of Appeals, Division One, published opinion filed 15 July 2026 (Judge Brian Furuya writing for a unanimous panel): inaccurate and false citations struck; the trial court's order appointing a personal representative affirmed; the appellant ordered to pay the portion of the appellee's reasonable attorney's fees incurred because of the hallucinated and misrepresented citations, the amount depending on the appellee's fee documentation.
What remains unknown
- Which generative AI tool the appellant used.
- The amount of the fee award, which depended on the other party's documentation.
What the evidence supports
AI involvement: supported. The appellant acknowledged in a written explanation and at a hearing on the false citations that he relied on generative AI to write his opening brief, which the court found cited two nonexistent cases and misstated others; the AI-generated text reached him (communicated_with), and the court read the fabricated citations, struck them, rejected the appeal for want of authority and imposed a fee sanction for them (informed_decision_about). The tool is not named.
4 claims: 4 reported. What the statuses mean
Reported The self-represented appellant's opening brief made eight citations; the court found six deficient, including two cases that do not exist.
Causal attribution. The court's findings as reported by the Arizona Mirror.
- kiowacountypress.net(opens in new tab) supports · English
In his opening brief with the Court of Appeals, he made eight citations. The court found that six of them were deficient; two were cases that “simply do not exist.”
Reported In a written explanation and at a hearing on the false citations he acknowledged relying on generative AI to write the brief and admitted doing nothing to verify the citations.
Causal attribution. The appellant's own acknowledgement, recorded in the opinion and reported by the Arizona Mirror.
- kiowacountypress.net(opens in new tab) supports · English
readily acknowledged that he relied on generative AI to write his brief; he admitted he did nothing to independently verify the citations
Reported The court held that citing a hallucinated case is sanctionable regardless of intent, ordered him to pay the portion of the other party's attorney's fees traceable to the fake citations, and rejected the appeal because no supportive authority remained once the citations were struck.
Causal attribution. The court's ruling as reported.
- kiowacountypress.net(opens in new tab) supports · English
Accordingly, citing a hallucinated case in a legal filing is sanctionable conduct; traceable to dealing with the fake citations; appeal was also rejected because there were no supportive legal authorities for his claims once the inaccurate and false citations were stricken
Reported The court chose this narrow sanction over contempt or fines because he said he did not intend to deceive and is not a trained legal professional.
Causal attribution. The court's reasoning as reported.
- kiowacountypress.net(opens in new tab) supports · English
The three-judge panel noted that court rules allow for more severe sanctions, including contempt charges and monetary fines.; isn’t a trained legal professional, it opted to narrowly sanction him
Sources
1 source inspected. Sources that repeat one account do not corroborate each other.
- Arizona Mirror (States Newsroom), republished by Kiowa County Press, July 2026: Arizona Court of Appeals on sanctions for fake AI-generated cases(opens in new tab)
s1 · kiowacountypress.net · News · English · Inspected · 19 July 2026 · Primary
How the sources were read, and where the events happened
Read in full in English by the research agent (an AI) on 2026-10-18 (HTTP 200); no translation was needed. Republication of the Arizona Mirror (States Newsroom) report. Applies to s1.
Event countries: United States. Affected-person countries: Unknown. Court countries: United States.
The brief was filed in, and the sanction imposed by, the Arizona Court of Appeals in a Maricopa County probate appeal. Residence is not used.
Reviewed for publication 2026-10-18: Published on the Arizona Mirror's report of the Court of Appeals opinion of 15 July 2026: a self-represented appellant acknowledged relying on generative AI to write a brief that cited nonexistent cases, and the court struck the citations, rejected the appeal and ordered him to pay the fees they caused. The parties are private persons and are not named.
People described
A self-represented appellant in an Arizona probate dispute whose brief citations were struck, whose appeal was rejected and who was ordered to pay part of the other party's fees; a private person, not named here.
People reported harmed in this case
1 person
1 AI participant · 0 other people harmed
One person: the self-represented appellant who used generative AI and was sanctioned.
Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.
Cite this case
Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.
APA
NOPE. (2026). Arizona appeals court strikes a self-represented appellant's AI-hallucinated citations, rejects his probate appeal and orders him to pay fees as a sanction. AI incidents. https://nope.net/incidents/2026-arizona-appeals-court-strikes-self-represented-appellants-ai-hallucinated-citations-orders-fees-sanction
BibTeX
@misc{2026_arizona_appeals_court_strikes_self_represented_appellants_ai_hallucinated_citations_orders_fees_sanction,
title = {Arizona appeals court strikes a self-represented appellant's AI-hallucinated citations, rejects his probate appeal and orders him to pay fees as a sanction},
author = {NOPE},
year = {2026},
howpublished = {AI incidents},
url = {https://nope.net/incidents/2026-arizona-appeals-court-strikes-self-represented-appellants-ai-hallucinated-citations-orders-fees-sanction}
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