Kevin Lee Biglow v. Dell Technologies Inc.
10th Cir. CA · Mar 24, 2026
- Jurisdiction
- federal
- Court
- 10th Cir. CA
- Record ID
- kevin-lee-biglow-v-dell-technologies-inc-2026-03-24
- Observed outcome
- The court affirmed the district court's judgment and issued a formal warning to the plaintiff regarding his use of AI in legal filings.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fabricated Case Law
- Fabricated Citations
- Misattributed Quotes
- Failure To Verify AI Generated Output
- Pro Se
- Fake Citations
- AI attribution
- Explicitly Recorded
- Recorded tool
- Generative artificial intelligence (e.g., ChatGPT)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of district court orders compelling arbitration and denying a motion to vacate an arbitration award.
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 AI tools such as ChatGPT.
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.