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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Al-Hamim v. Star Hearthstone
Colorado · Dec 26, 2024
CO / stateEditorial impact: lowpro sefake citationscontracttrial
Direct answer
What happened in this matter?
Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. Outcome: No Sanction (due to pro se, contrition, etc.); Warning of future sanctions..
- Why the court cared
- Factors against sanctions included Al-Hamim's pro se status, his contrition, lack of prior appellate violations, the absence of published Colorado precedent on sanctions for this issue, and the fact that opposing counsel did not raise the issue or request sanctions. However, the court issued a clear and strong warning to "the bar, and self-represented litigants" that future filings containing AI-generated hallucinations "may result in sanctions". The court emphasized the need for diligence, regardless of representation status
- Why it matters now
- Pro-se filer; log as volume data point.
Why this matter is tracked
Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. Outcome: No Sanction (due to pro se, contrition, etc.); Warning of future sanctions..
AI Use
Alim Al-Hamim, appearing pro se (self-represented), used a generative AI tool to prepare his opening brief appealing the dismissal of his claims against his landlords. He had also submitted a document with fabricated citations in the lower court.
Hallucination Details
The appellate brief contained eight fictitious case citations alongside legitimate ones. The court could not locate the cases and issued an order to show cause.
Ruling/Sanction
Al-Hamim admitted relying on AI, confirmed the citations were hallucinations, stated he failed to inspect the brief, apologized, and accepted responsibility. The court affirmed the dismissal of his claims on the merits. While finding his submission violated Colorado Appellate Rules (C.A.R. 28(a)(7)(B)), the court exercised its discretion and declined to impose sanctions.
Key Judicial Reasoning
Factors against sanctions included Al-Hamim's pro se status, his contrition, lack of prior appellate violations, the absence of published Colorado precedent on sanctions for this issue, and the fact that opposing counsel did not raise the issue or request sanctions. However, the court issued a clear and strong warning to "the bar, and self-represented litigants" that future filings containing AI-generated hallucinations "may result in sanctions". The court emphasized the need for diligence, regardless of representation status.
Operational lesson
Pro-se filer; log as volume data point.
Record details
ColoradoSingle-state evidence scope
CourtColorado
Jurisdictionstate
Circuit10th Circuit
DateDec 26, 2024
UN
AI toolUnidentified
Party typePro Se Litigant
OutcomeNo Sanction (due to pro se, contrition, etc.); Warning of future sanctions.
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
not established
The current record does not establish a specific AI tool. Do not infer AI use beyond the source.
Procedural posture
No Sanction (due to pro se, contrition, etc.); Warning of future sanctions.
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
8 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
Questions this record answers
- What happened in Al-Hamim v. Star Hearthstone?
- Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. Outcome: No Sanction (due to pro se, contrition, etc.); Warning of future sanctions..
- Why does Al-Hamim v. Star Hearthstone matter for legal AI risk?
- Pro-se filer; log as volume data point.
- What does the public record establish about Al-Hamim v. Star Hearthstone?
- The record summarizes the outcome described in the linked public source. The recorded link is hosted by a court or government source. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Al-Hamim v. Star Hearthstone summary?
- The recorded source is coloradojudicial.gov. It is classified as official court or government source; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.