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LLMMedium

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

Occurred
Sep 11, 2025
Published
Jul 16, 2026
Source
AI Incident Database

Summary

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.

Developers

  • Large language model developers

Deployers

  • Jeffrey Kotchka
  • Pro se litigants
  • Litigants

Harmed parties

  • Jeffrey Kotchka
  • Kim Dineen
  • Pro se litigants
  • Judicial integrity
  • Epistemic integrity
  • Arizona Court of Appeals
  • Litigants

Classification

Category confidence: 90%
Severity confidence: 85%

Rationale: AI-generated false citations caused legal sanctions, representing a notable failure with financial harm but no physical injury.

Classifier: Qwen/Qwen3.5-35B-A3B-FP8

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