Dineen/Shibata v. Kotchka
CA Arizona (1d) · Jul 15, 2026
- Jurisdiction
- state
- Court
- CA Arizona (1d)
- Record ID
- dineen-shibata-v-kotchka-2026-07-15
- Observed outcome
- The court affirmed the lower court's order and imposed sanctions against the appellant, awarding the appellee reasonable attorneys' fees and costs.
- Known monetary consequence
- $0
Why this matter warrants attention
The court sanctioned the pro se appellant for submitting an appellate brief containing hallucinated and misrepresented case law generated by AI. The court affirmed the lower court's order and awarded the appellee attorneys' fees and costs as a sanction for the appellant's failure to verify the accuracy of his legal citations.
The court reasoned that all litigants, including pro se parties, have a non-delegable duty to ensure the accuracy of their filings. Because the appellant admitted to using Gen-AI without any independent verification, his reliance on hallucinated authorities rendered his claims objectively groundless and demonstrated a reckless indifference to the truth, satisfying the requirements for sanctions under A.R.S. § 12-349 and ARCAP 25.
This case establishes that Arizona courts will hold pro se litigants to the same standards as attorneys regarding the verification of AI-generated content. It confirms that 'hallucination' is not a defense to sanctions when a litigant fails to exercise reasonable diligence in verifying legal authorities.
Failure modes and consequences
- Pro Se
- Fake Citations
- Misrepresented Authority
- Other
- Appellate
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $0
- Procedural posture
- Appellate review of a superior court order for formal probate and appointment of a personal representative, resulting in an affirmed judgment and a sanctions 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 appellant admitted to using generative artificial intelligence tools.
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, regardless of the research method used.
- Prohibit the submission of any legal filing that has not been independently verified against a trusted legal database.
- Maintain a record of the verification process for all citations included in court filings.
- Ensure that all litigants, including pro se parties, are informed of their duty to verify the accuracy of AI-generated work product.