Donovan v. Clark County Assessor
Indiana Tax Court · Dec 22, 2025
- Jurisdiction
- federal
- Court
- Indiana Tax Court
- Record ID
- donovan-v-clark-county-assessor-2025-12-22
- Observed outcome
- The court affirmed the administrative board's decision and issued a formal warning to the petitioners regarding their use of AI-generated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in Indiana Tax Court, with the listed outcome: Warning.
Failure modes and consequences
- Hallucinated_case_law
- Fabricated_quotations
- Pro Se
- Fake Citations
- Fabricated Quotes
- Administrative
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Judicial review of an Indiana Board of Tax Review final determination regarding a property tax assessment.
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 petitioners admitted to using AI, but the specific tool was not named.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.