Barari v. Burgess
CA Arizona (1d) · Jun 26, 2026
- Jurisdiction
- state
- Court
- CA Arizona (1d)
- Record ID
- barari-v-burgess-2026-06-26
- Observed outcome
- The court affirmed the lower court's decree, denied the appellant's motion to amend her brief, and struck all inaccurate and false legal citations as a sanction.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Arizona Court of Appeals sanctioned a pro se appellant by striking inaccurate and false legal citations from her opening brief after determining she used generative AI to draft the document. The court found the appellant's explanations for the errors not credible, deemed her arguments waived for lack of supportive authority, and affirmed the underlying judgment.
The court reasoned that the appellant's citation errors—specifically the inclusion of a hallucinated case and the combination of unrelated reporters and pin citations—were consistent with the abuse of generative AI. The court found the appellant's testimony denying AI use not credible and determined that the submission of false citations warranted sanctions under ARCAP 25 to discourage similar future conduct.
This case illustrates judicial intolerance for AI-generated hallucinations in appellate filings. It highlights that courts will conduct show-cause hearings to investigate suspected AI misuse and will impose sanctions, such as striking portions of a brief, when litigants provide evasive or implausible explanations for citation errors.
Failure modes and consequences
- Pro Se
- Fake Citations
- Misrepresented Authority
- Family
- Appellate
- Struck Filing
- AI attribution
- Implied
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Appeal from the Superior Court in Maricopa County; the Court of Appeals affirmed the lower court's decree and sanctioned the appellant by striking false citations from her opening brief.
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 use of generative AI but did not name a specific tool.
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
- Implement mandatory verification protocols for all legal citations generated or assisted by AI tools.
- Ensure that all legal research is conducted using reliable, primary-source databases rather than relying solely on generative AI outputs.
- Review all filings for compliance with local appellate rules regarding record citations and authority support before submission.
- Maintain transparency with the court regarding the use of AI tools in legal drafting to avoid credibility issues during judicial inquiry.