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 involvement supported · Causal attribution established · 1 source · Added 18/10/2026