{"meta":{"exportedAt":"2026-10-18T06:51:25.679Z","formatVersion":2,"selection":{"q":"self-represented-litigant","system":"","harm":"","context":"","country":"","role":"","relation":"contextual","evidence":"","year":"","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":1,"coverage":{"cases":1,"countries":1,"languages":1,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":1,"minors":0,"coreRelations":1,"contextualRelations":1,"mixedRelations":1,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2026-arizona-appeals-court-strikes-self-represented-appellants-ai-hallucinated-citations-orders-fees-sanction","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"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.”","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c2","status":"reported","evidence":[{"locator":"readily acknowledged that he relied on generative AI to write his brief; he admitted he did nothing to independently verify the citations","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c3","status":"reported","evidence":[{"locator":"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","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c4","status":"reported","evidence":[{"locator":"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","relation":"supports","source_id":"s1"}],"assertion":"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."}],"effects":[{"label":"brief citations struck, appeal rejected and fee sanction ordered","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://kiowacountypress.net/content/arizona-court-appeals-citing-fake-ai-generated-cases-can-get-you-sanctioned-no-matter-your","kind":"news","access":"read","language":"en","translation_note":"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.","independence_group":"arizona-mirror-report-jul-2026"}],"version":1,"ai_roles":["own_use"],"contexts":["justice"],"unknowns":["Which generative AI tool the appellant used.","The amount of the fee award, which depended on the other party's documentation."],"geography":{"basis":"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.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"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.","reviewed_on":"2026-10-18"},"ai_involvement":{"basis":"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.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"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","summary":"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.","incidentDate":"2026-07-15","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"single_interaction","reportedDate":"2026-07-19","aiSystem":"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","aiProduct":"Unidentified AI drafting tool","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","financial_loss"],"harmOutcomeSummary":"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.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the self-represented appellant who used generative AI and was sanctioned.","victimAgeRange":"adult","jurisdiction":"US-AZ","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://kiowacountypress.net/content/arizona-court-appeals-citing-fake-ai-generated-cases-can-get-you-sanctioned-no-matter-your","primarySourceLabel":"Arizona Mirror (States Newsroom), republished by Kiowa County Press, July 2026: Arizona Court of Appeals on sanctions for fake AI-generated cases","firstPublishedAt":"2026-10-18T03:14:48.762612+00:00","updatedAt":"2026-10-18T03:14:48.762612+00:00","scopeVersion":"facts-v3","tags":["hallucinated-citations","self-represented-litigant","appeal","sanction","attorney-fees","arizona"]}]}