A.K. v. M.R.
CA Indiana · Mar 10, 2026
- Jurisdiction
- state
- Court
- CA Indiana
- Record ID
- ak-v-mr-2026-03-10
- Observed outcome
- The court affirmed the trial court's denial of the protective order and issued an admonishment to the appellant regarding his use of AI for legal research.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Indiana Court of Appeals admonished a pro se litigant for submitting an appellate brief containing fabricated and mischaracterized case law. The court identified that the appellant likely used generative AI to conduct research without verifying the generated citations, which linked to unrelated out-of-state cases rather than the Indiana authorities claimed.
The court reasoned that the appellant's failure to provide accurate citations and cogent arguments impeded appellate review. It concluded that the errors were a common result of using generative AI without independent verification, necessitating an admonishment to ensure future compliance with appellate rules.
This case illustrates judicial scrutiny of AI-generated research in pro se filings. It reinforces that courts expect all litigants, regardless of representation status, to independently verify the accuracy of legal citations and the relevance of authorities before submission.
Failure modes and consequences
- Fabricated_case_law
- Misrepresented_authority
- Lack_of_verification
- Pro Se
- Fake Citations
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- generative artificial intelligence
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a trial court's denial of a petition for a civil protective order.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court identified the errors as a likely result of using generative artificial intelligence.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.