Donovan v. Clark County Assessor
Indiana Tax Court · Dec 22, 2025
What happened in this matter?
The Indiana Tax Court issued a formal warning to pro se litigants for submitting AI-generated fabricated case law and false quotations in their briefs. The court admonished the petitioners for failing to independently verify the authenticity of their cited authorities but declined to impose additional monetary or professional sanctions.
- Why the court cared
- Fabricated: Case Law | Pro se litigants cited a non-existent case 'Rawles v. Monroe Cnty. Ass'r, 48T10-1705-TA-00014, slip op. at 5–6 (Ind. Tax Ct. May 13, 2019)'; court could not locate the case and concluded it was an AI hallucination (petitioner admitted using AI). || False Quotes: Case Law | Reply brief quoted language attributed to Piotrowski, O'Donnell, and Westfield Golf that the court found not present in those opinions; court treated these as inaccurate/misgenerated quotations likely produced by AI.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in Indiana Tax Court, with the listed outcome: Warning.
Why this matter is tracked
In an appeal before the Indiana Tax Court, pro se litigants Linda and William Donovan challenged a property tax assessment. During the proceedings, the petitioners submitted briefs containing a non-existent case citation ('Rawles v. Monroe Cnty. Ass'r') and fabricated quotations attributed to three other Indiana Tax Court opinions. The court identified these as AI-generated hallucinations after the petitioners admitted to using artificial intelligence to assist in drafting their filings. While the court admonished the litigants for failing to verify the authenticity of their cited authorities, it imposed no further penalties beyond the warning. The court affirmed the underlying administrative board's determination regarding the property's tax value, noting that the petitioners failed to accurately apply Indiana law or demonstrate that the evidence compelled a different result.
This record documents a Pro Se Litigant filing issue in Indiana Tax Court, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The petitioners admitted to using AI, but the specific tool was not named.
Judicial review of an Indiana Board of Tax Review final determination regarding a property tax assessment.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Pro se litigants cited a non-existent case 'Rawles v. Monroe Cnty. Ass'r, 48T10-1705-TA-00014, slip op. at 5–6 (Ind. Tax Ct. May 13, 2019)'; court could not locate the case and concluded it was an AI hallucination (petitioner admitted using AI).
- False Quotes: Case Law | Reply brief quoted language attributed to Piotrowski, O'Donnell, and Westfield Golf that the court found not present in those opinions; court treated these as inaccurate/misgenerated quotations likely produced by AI.
Questions this record answers
- What happened in Donovan v. Clark County Assessor?
- The Indiana Tax Court issued a formal warning to pro se litigants for submitting AI-generated fabricated case law and false quotations in their briefs. The court admonished the petitioners for failing to independently verify the authenticity of their cited authorities but declined to impose additional monetary or professional sanctions.
- Why does Donovan v. Clark County Assessor matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in Indiana Tax Court, with the listed outcome: Warning.
- What does the public record establish about Donovan v. Clark County Assessor?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Donovan v. Clark County Assessor 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
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.