Jean-Paul B. Kalonji v. State of Indiana
CA Indiana · May 26, 2026
- Jurisdiction
- state
- Court
- CA Indiana
- Record ID
- jean-paul-b-kalonji-v-state-of-indiana-2026-05-26
- Observed outcome
- The court affirmed the trial court's denial of the expungement petition and issued a formal admonishment to the appellant regarding his use of AI-generated or unverified legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Indiana Court of Appeals admonished the pro se appellant for citing nonexistent legal authorities and mischaracterizing case law in his appellate briefs. The court attributed these errors to the likely use of generative AI and cautioned the litigant against using such tools without independently verifying the accuracy of the generated citations and legal propositions.
The court reasoned that pro se litigants are bound by the same standards as licensed attorneys, including the duty to present authentic authority. It determined that the appellant's reliance on ghost citations and mischaracterized holdings impeded appellate consideration, justifying an admonishment.
This case illustrates the judiciary's increasing scrutiny of pro se filings for AI-generated hallucinations. It reinforces the principle that all litigants, regardless of representation status, bear personal responsibility for the accuracy of their research and the authenticity of their cited authorities.
Failure modes and consequences
- Fabricated Case Law
- Nonexistent Statutory Citations
- Mischaracterization Of Legal Holdings
- Failure To Verify Research
- Pro Se
- Fake Citations
- AI attribution
- Implied
- Recorded tool
- Generative artificial intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appeal from the trial court's denial of a motion to correct error concerning the summary denial of an expungement petition.
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 stated it is likely the appellant used generative AI.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.