Merritt v. Moore
CA Tennessee · Jul 21, 2026
What happened in this matter?
The Tennessee Court of Appeals dismissed the appeal and deemed the issues waived because the pro se appellant's brief contained fabricated case citations, nonexistent authorities, inaccurate page references, and lacked required citations to the record, violating Tennessee appellate rules.
- Why the court cared
- The court reasoned that the appellant's brief failed to comply with mandatory appellate rules regarding the table of authorities, record citations, and relevant legal authority. The court noted that the appellant's reliance on nonexistent cases and fabricated quotes—which it characterized as 'Artificial Intelligence hallucinations'—rendered the brief incapable of facilitating efficient appellate review. The court concluded that it could not construct arguments for the pro se litigant without unfairly disadvantaging the appellee, thus necessitating dismissal.
- Why it matters now
- This case illustrates the judiciary's increasing intolerance for AI-generated hallucinations in filings. It reinforces that pro se litigants are held to the same procedural standards as counsel, and that the use of unreliable AI tools to generate legal research can lead to the summary dismissal of appellate claims.
Why this matter is tracked
In Merritt v. Moore, the Tennessee Court of Appeals dismissed an appeal filed by a pro se litigant due to substantial non-compliance with Tennessee Rule of Appellate Procedure 27 and Tennessee Court of Appeals Rule 6. The court found the appellant's brief contained an inaccurate table of authorities, including nonexistent case citations and incorrect page references. Furthermore, the brief lacked citations to the record and included arguments supported by fabricated quotes and nonexistent legal authorities. The court explicitly identified these errors as 'Artificial Intelligence hallucinations,' noting the appellant's failure to verify the accuracy of the cited materials. Consequently, the court deemed the issues waived and dismissed the appeal, emphasizing that pro se status does not excuse compliance with substantive and procedural rules.
This case illustrates the judiciary's increasing intolerance for AI-generated hallucinations in filings. It reinforces that pro se litigants are held to the same procedural standards as counsel, and that the use of unreliable AI tools to generate legal research can lead to the summary dismissal of appellate claims.
Record details
What the record establishes about AI use
The court identified the fabricated citations as 'Artificial Intelligence hallucinations'.
Appeal from the Circuit Court for Shelby County to the Tennessee Court of Appeals; appeal dismissed.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Appellant's table of authorities lists at least one case authority that the court could not locate and appears to be nonexistent.
- False Quotes: Case Law | Brief contains quotations attributed to cited authorities that do not appear in those authorities.
Questions this record answers
- What happened in Merritt v. Moore?
- The Tennessee Court of Appeals dismissed the appeal and deemed the issues waived because the pro se appellant's brief contained fabricated case citations, nonexistent authorities, inaccurate page references, and lacked required citations to the record, violating Tennessee appellate rules.
- Why does Merritt v. Moore matter for legal AI risk?
- This case illustrates the judiciary's increasing intolerance for AI-generated hallucinations in filings. It reinforces that pro se litigants are held to the same procedural standards as counsel, and that the use of unreliable AI tools to generate legal research can lead to the summary dismissal of appellate claims.
- What does the public record establish about Merritt v. Moore?
- 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 Merritt v. Moore 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.