Kevin Lee Biglow v. Dell Technologies Inc.
10th Cir. CA · Mar 24, 2026
What happened in this matter?
The Tenth Circuit issued a formal warning to pro se litigant Kevin Lee Biglow for submitting appellate filings containing fabricated case law and misattributed quotes. The court attributed these errors to the unverified use of generative AI tools and cautioned that such conduct undermines judicial integrity and may warrant future sanctions, including dismissal.
- Why the court cared
- The court reasoned that the plaintiff's citations were non-existent or led to unrelated cases, and that the plaintiff failed to verify the accuracy of his research. It determined that while it had the authority to sanction the litigant, it would instead issue a warning, emphasizing the duty of all litigants to ensure citations point to real, relevant authority.
- Why it matters now
- This case serves as a clear appellate-level warning regarding the duty of verification when using generative AI. It highlights that pro se status does not excuse the submission of fabricated authority and establishes that courts will actively identify and call out AI-generated hallucinations.
Why this matter is tracked
In an appeal from a district court order compelling arbitration, the Tenth Circuit affirmed the lower court's decision. During the appellate process, the pro se plaintiff, Kevin Lee Biglow, submitted multiple motions and briefs containing numerous fabricated case citations and misattributed quotes. The court identified these as 'AI hallucinations' likely resulting from the plaintiff's use of generative AI tools without verification. While the court declined to impose formal sanctions such as dismissal, it issued a formal warning to the plaintiff regarding his responsibility to ensure the accuracy of legal authority. The court emphasized that such conduct wastes judicial resources and damages the credibility of the legal system, noting that future misrepresentations could lead to more severe consequences.
This case serves as a clear appellate-level warning regarding the duty of verification when using generative AI. It highlights that pro se status does not excuse the submission of fabricated authority and establishes that courts will actively identify and call out AI-generated hallucinations.
Record details
What the record establishes about AI use
The court identified the use of generative AI tools such as ChatGPT.
Appellate review of district court orders compelling arbitration and denying a motion to vacate an arbitration award.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Cited 'Burton v. Ghosh, 961 F.3d 1084, 1092 (7th Cir. 2020)'; the court determined the citation does not correspond to that case and is a fabrication.
- Fabricated: Case Law | Cited 'Iseminger v. Dist. Ct., 915 F.2d 1314 (10th Cir. 1990)' and 'Affolder v. Johnson, 53 F.3d 1178 (10th Cir. 1995)'; court found these reporter citations lead to different, unrelated opinions and treated them as fabrications.
- Fabricated: Case Law | Cited 'Bentley v. United States, 41 F.3d 593, 604 (10th Cir. 1994)' and 'Clean Boat v. United States, 833 F.3d 1224 (10th Cir. 2016)'; court found the pin cites lead to different actual cases and treated them as fabricated or mis-cited.
- Fabricated: Case Law | Several fabricated citations in Biglow's motions (e.g., Paula Denogean, Young v. Nationstar, Singleton v. Wulff, In re Delta/Airtran, Saxena v. Allen, Jones v. State of Colorado) were identified by the court as non-existent or incorrect.
- False Quotes: Case Law | Attributed a quote about opposing counsel preying on pro se ignorance to Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836, 840; the court found no such language in Garrett.
- Fabricated: Case Law | Cited 'Ricks v. Lindsay, 480 F.2d 538 (10th Cir. 1973)' for waiver; court found the citation actually leads to Hanley v. Four Corners Vacation Properties, Inc., 480 F.2d 536 and does not support Biglow's proposition.
Questions this record answers
- What happened in Kevin Lee Biglow v. Dell Technologies Inc.?
- The Tenth Circuit issued a formal warning to pro se litigant Kevin Lee Biglow for submitting appellate filings containing fabricated case law and misattributed quotes. The court attributed these errors to the unverified use of generative AI tools and cautioned that such conduct undermines judicial integrity and may warrant future sanctions, including dismissal.
- Why does Kevin Lee Biglow v. Dell Technologies Inc. matter for legal AI risk?
- This case serves as a clear appellate-level warning regarding the duty of verification when using generative AI. It highlights that pro se status does not excuse the submission of fabricated authority and establishes that courts will actively identify and call out AI-generated hallucinations.
- What does the public record establish about Kevin Lee Biglow v. Dell Technologies Inc.?
- 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 Kevin Lee Biglow v. Dell Technologies Inc. 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.