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HomeCasesDonovan v. Clark County Assessor
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Corpus matter record

Donovan v. Clark County Assessor

Indiana Tax Court · Dec 22, 2025

Direct answer

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.

Operational lesson

This record documents a Pro Se Litigant filing issue in Indiana Tax Court, with the listed outcome: Warning.

Record details

IndianaSingle-state evidence scope
Explore INOpen its source-linked jurisdiction page and related matters.
CourtIndiana Tax Court
Jurisdictionfederal
Circuit7th Circuit
DateDec 22, 2025
UN
AI toolUnidentified
Party typePro Se Litigant
OutcomeThe court affirmed the administrative board's decision and issued a formal warning to the petitioners regarding their use of AI-generated citations.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

admitted

The petitioners admitted to using AI, but the specific tool was not named.

Procedural posture

Judicial review of an Indiana Board of Tax Review final determination regarding a property tax assessment.

Correction behavior

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.

  1. 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).
  2. 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.