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WF-UR2SM2

Purportedly AI-Generated False Citations in Arizona Probate Appeal Reportedly Led to Sanctions Against Self-Represented Appellant

Self-represented appellant Jeffrey Kotchka reportedly used purported AI tools to prepare an opening brief in a probate dispute involving his late mother's estate. The Arizona Court of Appeals found six of its eight citations deficient, including two nonexistent cases, and said Kotchka had made no effort to verify them. The court affirmed the appointment of his sister, Kim Dineen, as personal representative, ordering Kotchka to pay her attorney fees attributable to addressing the false citations.

Date it happened
2025-09-11
Organisation involved
Jeffrey Kotchka, Pro se litigants, Litigants
Product, system or model
Large language models, AI-assisted legal research systems
Where this came from
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Attribution

This incident was imported from AI Incident Database and is used under CC BY-SA 4.0. Our additions to it — the structured fields, the translation, the checks against other reports — are published under the same licence.

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