In re Marriage of Haibt
Colorado CA · Jul 10, 2025
What happened in this matter?
The Colorado Court of Appeals issued a warning regarding the use of generative AI in legal filings after the pro se appellant included a fictitious case citation in his briefs. The court deemed the appeal frivolous, affirmed the underlying judgment, and remanded the matter to the trial court to determine the amount of appellate attorney fees owed to the appellee.
- Why the court cared
- The court determined the appeal was frivolous because the appellant's briefs lacked supporting legal authority, failed to provide record citations, and included a fictitious case citation, which the court characterized as a 'hallucination' produced by generative AI.
- Why it matters now
- This case illustrates judicial scrutiny of pro se filings containing AI-generated hallucinations. It serves as a reminder that courts will impose procedural consequences, such as findings of frivolousness and fee shifting, when litigants fail to verify the accuracy of cited authority.
Why this matter is tracked
In this domestic relations appeal, the Colorado Court of Appeals affirmed the trial court's judgment and remanded for a determination of appellate attorney fees. The appellate court found the husband's appeal frivolous, noting that his briefs frequently cited legal authority that did not support his arguments and, in one instance, included a fictitious case citation, Kendall v. Kendall. The court explicitly warned against the use of generative AI to produce such 'hallucinations' in filings. The court rejected the husband's claims of judicial bias and procedural error, concluding that his arguments were insufficiently developed, lacked record support, or relied on waived issues. The court granted the wife's request for appellate fees and costs due to the frivolous nature of the appeal.
This case illustrates judicial scrutiny of pro se filings containing AI-generated hallucinations. It serves as a reminder that courts will impose procedural consequences, such as findings of frivolousness and fee shifting, when litigants fail to verify the accuracy of cited authority.
Record details
What the record establishes about AI use
The court referenced hallucinations produced by generative artificial intelligence.
Appellate review of a domestic relations judgment; the court affirmed the judgment and remanded for a determination of appellate attorney fees.
Correction behavior is not separately verified in the current record.
Questions this record answers
- What happened in In re Marriage of Haibt?
- The Colorado Court of Appeals issued a warning regarding the use of generative AI in legal filings after the pro se appellant included a fictitious case citation in his briefs. The court deemed the appeal frivolous, affirmed the underlying judgment, and remanded the matter to the trial court to determine the amount of appellate attorney fees owed to the appellee.
- Why does In re Marriage of Haibt matter for legal AI risk?
- This case illustrates judicial scrutiny of pro se filings containing AI-generated hallucinations. It serves as a reminder that courts will impose procedural consequences, such as findings of frivolousness and fee shifting, when litigants fail to verify the accuracy of cited authority.
- What does the public record establish about In re Marriage of Haibt?
- 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.
- Which source supports this In re Marriage of Haibt 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.