Holstein v. Holstein
CA Indiana · Jun 16, 2026
- Jurisdiction
- state
- Court
- CA Indiana
- Record ID
- holstein-v-holstein-2026-06-16
- Observed outcome
- The Court affirmed the trial court's custody judgment and denied the appellee's request for monetary sanctions.
- Known monetary consequence
- $0
Why this matter warrants attention
The Court of Appeals of Indiana denied the appellee's request for monetary sanctions against the appellant's counsel. While the Court emphasized the duty of candor and the risks of using AI-generated research without verification, it found that counsel's voluntary disclosure and correction of the fabricated citations mitigated the need for formal sanctions.
The Court reasoned that sanctions were not warranted because counsel proactively notified the Court of the errors, sought leave to amend the brief, and the appellee failed to demonstrate prejudice or identify the errors in their initial response.
This case illustrates judicial expectations for attorney due diligence when using AI-assisted research. It highlights that while courts are increasingly vigilant regarding fabricated citations, prompt self-correction and a lack of prejudice can mitigate the risk of monetary sanctions.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Family
- Appellate
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- $0
- Procedural posture
- Appeal from the Johnson Superior Court to the Court of Appeals of Indiana; the Court affirmed the trial court's custody order and denied the appellee's motion for sanctions.
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 opinion references the risks of using AI in litigation.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.