In re the Marriage of Cristina Anderson and Edward Allyn Volovlek
CA Colorado · Jun 18, 2026
- Jurisdiction
- state
- Court
- CA Colorado
- Record ID
- in-re-the-marriage-of-cristina-anderson-and-edward-allyn-volovlek-2026-06-18
- Observed outcome
- The court affirmed the underlying remedial contempt order and issued a formal warning to the appellant regarding the use of GAI and the inclusion of fabricated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to a pro se litigant after discovering that his appellate brief included three non-existent case citations, which the court attributed to the use of generative artificial intelligence. The court explicitly cautioned that future reliance on GAI-generated hallucinations in filings may result in sanctions, such as the striking of briefs or dismissal of the appeal.
The court reasoned that the inclusion of non-existent case citations in the appellant's brief indicated the use of generative artificial intelligence. It emphasized that self-represented litigants must exercise caution because GAI tools can confidently provide erroneous or fabricated legal information. The court placed the litigant on notice that future noncompliance with appellate rules or the inclusion of GAI-generated errors could lead to sanctions, including the striking of the brief or dismissal of the appeal.
This case illustrates how appellate courts are proactively identifying and addressing GAI-induced hallucinations in pro se filings. It serves as a reminder that courts are increasingly scrutinizing the accuracy of citations and are prepared to impose procedural sanctions for AI-generated errors.
Failure modes and consequences
- Hallucinated_case_law
- Pro Se
- Fake Citations
- Family
- Appellate
- Warning
- AI attribution
- Implied
- Recorded tool
- generative artificial intelligence (GAI)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a district court's remedial contempt order.
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 court identified the use of generative artificial intelligence.
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
- Implement mandatory verification protocols for all case law citations, regardless of the research tool used.
- Review all AI-generated drafts for accuracy and verify the existence of every cited authority against official legal databases.
- Ensure that pro se litigants and junior practitioners are aware of the risks associated with GAI-generated hallucinations and the potential for court-imposed sanctions.