Robert Cole Stemkowski Goldman v. Arizona Board of Regents
D. Arizona · Oct 29, 2025
What happened in this matter?
The court issued a show cause order requiring plaintiff's counsel to explain the inclusion of non-existent case law, misattributed quotes, and misrepresented legal precedents in their response brief. The court explicitly linked these errors to the likely use of generative AI and ordered counsel to show cause why they should not be sanctioned under Rule 11.
- Why the court cared
- False Quotes: Case Law | Plaintiff quoted language attributed to Johnson v. City of Shelby that does not appear in that decision; Court notes the quoted text is not in the cited opinion. || Misrepresented: Case Law | Plaintiff relied on Pearson v. Callahan while characterizing it as supporting the opposite proposition; Court explains Pearson actually endorses early resolution of qualified-immunity questions. || Fabricated: Case Law | Plaintiff cited a non-existent Ninth Circuit opinion to support the proposition that qualified-immunity dismissals are premature; Court and defendants could not locate the case and characterized it as hallucinatory.
- Why it matters now
- Misrepresenting precedent is treated like fabrication; verify each holding, not just the citation string.
Why this matter is tracked
In a civil rights action against the Arizona Board of Regents and individual university officials, the court identified multiple instances of AI-generated hallucinations in the plaintiff's response brief. The court noted that the plaintiff cited a non-existent Ninth Circuit opinion, mischaracterized the holding of Pearson v. Callahan, and included a fabricated quote attributed to Johnson v. City of Shelby. The court observed that these errors, combined with unusual language patterns, indicated the use of generative AI. Consequently, the court dismissed several claims and issued a show cause order requiring counsel to explain the briefing issues and justify why Rule 11 sanctions should not be imposed for the submission of inaccurate and hallucinatory legal authority.
Misrepresenting precedent is treated like fabrication; verify each holding, not just the citation string.
Record details
What the record establishes about AI use
The court identified indicators of generative AI use.
The court ruled on a motion to dismiss the plaintiff's amended complaint, dismissing several claims with prejudice while preserving others, and simultaneously issued a show cause order regarding the plaintiff's briefing conduct.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Plaintiff quoted language attributed to Johnson v. City of Shelby that does not appear in that decision; Court notes the quoted text is not in the cited opinion.
- Misrepresented: Case Law | Plaintiff relied on Pearson v. Callahan while characterizing it as supporting the opposite proposition; Court explains Pearson actually endorses early resolution of qualified-immunity questions.
- Fabricated: Case Law | Plaintiff cited a non-existent Ninth Circuit opinion to support the proposition that qualified-immunity dismissals are premature; Court and defendants could not locate the case and characterized it as hallucinatory.
Questions this record answers
- What happened in Robert Cole Stemkowski Goldman v. Arizona Board of Regents?
- The court issued a show cause order requiring plaintiff's counsel to explain the inclusion of non-existent case law, misattributed quotes, and misrepresented legal precedents in their response brief. The court explicitly linked these errors to the likely use of generative AI and ordered counsel to show cause why they should not be sanctioned under Rule 11.
- Why does Robert Cole Stemkowski Goldman v. Arizona Board of Regents matter for legal AI risk?
- Misrepresenting precedent is treated like fabrication; verify each holding, not just the citation string.
- What does the public record establish about Robert Cole Stemkowski Goldman v. Arizona Board of Regents?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Robert Cole Stemkowski Goldman v. Arizona Board of Regents 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.