Merritt v. Moore
CA Tennessee · Jul 21, 2026
- Jurisdiction
- state
- Court
- CA Tennessee
- Record ID
- merritt-v-moore-2026-07-21
- Observed outcome
- Appeal dismissed and issues deemed waived due to significant deficiencies in the appellate brief, including the use of fabricated citations and quotes.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Hallucinated_case_law
- Fabricated_quotes
- Citation_verification_failure
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appeal from the Circuit Court for Shelby County to the Tennessee Court of Appeals; appeal dismissed.
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 fabricated citations as 'Artificial Intelligence hallucinations'.
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.