Published opinion, 10 June 2026 · source · PDF · 3 pages
In reviewing the briefs, we discovered Anderson’s filings included what purported to be direct quotations from at least eight appellate decisions, but those quotes did not actually appear in the decisions. Her briefs also cited two Iowa cases that do not exist; the reporter citations provided are for other states and cases unrelated to the cited propositions. We have addressed this phenomenon—problematic filings apparently “written” by artificial intelligence (AI)—in other cases.
4, 2025). Most pertinent here, using AI in legal matters carries the risk of AI “hallucinating” or fabricating legal authorities that do not actually exist. See Thomas A.
L. 115, 121–22 (2025) (“[AI] may ʻsometimes even make up facts.’ This includes fabricating case citations, even if the proposition it is citing the case for is correct or misstating the holding of a case that exists.” (footnotes omitted)). With this backdrop, we ordered Anderson to either (1) file copies of the ten decisions with the portions she relied on highlighted; or (2) submit “a statement indicating whether the appellant’s brief or reply brief were prepared using generative artificial intelligence tools.” 3 Anderson filed a response, but it was neither of the permitted options.
We decline to follow that path here for two reasons. First, the offending parties in W .G. and R.A. both complied with our order and expressed remorse for submitting fabricated citations; Anderson has done neither. Second, in both of those cases we could at least arguably sift out the hallucinated authorities and decide what remained of proper legal argument; we cannot do so here given the depth and breadth of the fabricated case citations.