Cingel v. Ferreri
CA Indiana · Sep 19, 2025
What happened in this matter?
The court issued a warning regarding the appellant's use of generative AI for legal research after finding that the appellant's appellate brief contained 14 nonexistent legal authorities and multiple mischaracterized statutes. The court affirmed the trial court's decision, noting that the appellant's significant noncompliance with appellate rules and reliance on fabricated authority impeded the court's review.
- Why the court cared
- The court reasoned that the appellant's reliance on nonexistent and mischaracterized authorities significantly impeded its ability to review the claims, violating appellate rules requiring cogent reasoning and accurate citations. The court explicitly cautioned against using AI for legal research without independent verification, stating that judicial decision-making depends on the authenticity of cited authorities.
- Why it matters now
- This case highlights the risks of pro se litigants using generative AI to draft appellate briefs without verification. It serves as a judicial warning that courts will not tolerate the submission of fabricated legal authorities, regardless of the research method employed.
Why this matter is tracked
In this family law appeal, the pro se appellant submitted a brief containing numerous fabricated legal authorities and mischaracterized statutes and rules. The Court of Appeals of Indiana identified 14 nonexistent legal authorities out of 23 cited, including non-existent case law and trial rules. The court noted that the appellant's reliance on these sources significantly impeded appellate review and suggested the appellant likely used generative artificial intelligence to draft the brief without independent verification. The court cautioned litigants against using AI for legal research without verification, emphasizing that judges must rely on the authenticity of cited authorities. Ultimately, the court found the appellant's claims waived due to significant noncompliance with appellate rules and, alternatively, meritless, affirming the trial court's decision.
This case highlights the risks of pro se litigants using generative AI to draft appellate briefs without verification. It serves as a judicial warning that courts will not tolerate the submission of fabricated legal authorities, regardless of the research method employed.
Record details
What the record establishes about AI use
The court stated it is likely the appellant used generative AI.
Appeal from the Kosciusko Superior Court to the Court of Appeals of Indiana, resulting in an affirmation of the trial court's custody and relocation orders.
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 'In re Marriage of Dunston, 989 N.E.2d 830, 835 (Ind. Ct. App. 2013)' to support abuse-of-discretion review; court found no such case and reporter citation pointed to unrelated decisions.
- Fabricated: Case Law | Appellant cited 'McCain v. State, 924 N.E.2d 56, 60 (Ind. 2009)' for a custody proposition; court determined that citation does not exist as given.
- Fabricated: Legal Norm | Appellant relied on 'Indiana Code § 31-17-2.5-1' as the custody statute; court found no such statutory section (correct statute is 31-17-2-8).
- Fabricated: Legal Norm | Appellant cited and purported to quote 'Indiana Code § 31-17-2.2-23(a)'; court noted no such statutory provision exists.
- Fabricated: Legal Norm | Appellant cited 'Trial Rule 60.1' and 'Trial Rule 60.1(A)' to support procedural requirements for custody modifications; court found no such trial rule.
- Misrepresented: Legal Norm | Appellant cited 'Trial Rule 59(G)' as requiring written orders or hearings on motions to correct error; court explained Rule 59(G) concerns cross errors and was misapplied.
- Misrepresented: Case Law | Appellant cited 'Bowman v. Bowman, 682 N.E.2d 23, 28 (Ind. Ct. App. 1997)' for multiple propositions; court observed the correct Bowman citation is different (686 N.E.2d 921) and the cited reporter/pincite pointed to unrelated authority, and the asserted propositions were inaccurate.
- Misrepresented: Legal Norm | Appellant relied on subsections 'Indiana Code § 31-17-2.2-1(a)' and '(b)' for notice timing and burden of proof on relocation; court found those subsections were mischaracterized (they address filing location and exceptions) and pointed to the correct provisions (31-17-2.2-3 and 31-17-2.2-5).
Questions this record answers
- What happened in Cingel v. Ferreri?
- The court issued a warning regarding the appellant's use of generative AI for legal research after finding that the appellant's appellate brief contained 14 nonexistent legal authorities and multiple mischaracterized statutes. The court affirmed the trial court's decision, noting that the appellant's significant noncompliance with appellate rules and reliance on fabricated authority impeded the court's review.
- Why does Cingel v. Ferreri matter for legal AI risk?
- This case highlights the risks of pro se litigants using generative AI to draft appellate briefs without verification. It serves as a judicial warning that courts will not tolerate the submission of fabricated legal authorities, regardless of the research method employed.
- What does the public record establish about Cingel v. Ferreri?
- 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.
- Which source supports this Cingel v. Ferreri summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
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