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Indiana · state appellate court · 2025

Kurt Williams v. Karin Kirch

Indiana Court of Appeals, 18 August 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Ind. Ct. App.

  1. Court. Indiana Court of AppealsCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 18 August 2025DATED
  4. Docket. No. 25A-SC-00196DOCKET
  5. Judge. Tavitas, Vaidik, FelixJUDGE
  6. Documents. one document, 5 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 18 August 2025 · source · PDF · 7 pages

[2] We also take this opportunity to remind pro se litigants and attorneys of the dangers of using artificial intelligence (AI) to conduct legal research. Generative AI can produce citations to non-existent authorities, and we caution litigants to verify citations before including them in briefs. Facts and Procedural History [3] In 2024, Williams, pro se, brought a small-claims action against Kirch, his ex- girlfriend.

Warning regarding AI-generated citations [11] We must address a troubling aspect of Williams’s brief. He cites several “cases” in his opening brief that do not exist. See Appellant’s Br. pp.

Scarborough (IN 2014)”), 17 (“In re Marriage of Nigh, 2016 IL App (5th) 150274”). As Kirch suggests, this may be the result of the use of “generative artificial intelligence,” which can produce fictitious case citations. See Mid Cent.

May 28, 2025). Despite Kirch identifying these nonexistent citations, Williams provides no explanation for them in his reply brief. [12] Citations to fictitious, AI-generated authority is a growing problem nationwide.

2024), reh’g denied, trans. denied. 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. We caution attorneys and pro se litigants alike against using AI to conduct legal research without independently verifying the citations generated.

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More from Indiana Court of Appeals, from Indiana, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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