Ryan-Michael Jarvis v. County of Teton Wyoming
10th Cir. CA · Apr 24, 2026
- Jurisdiction
- federal
- Court
- 10th Cir. CA
- Record ID
- ryan-michael-jarvis-v-county-of-teton-wyoming-2026-04-24
- Observed outcome
- The court affirmed the district court's dismissal of the underlying claims and issued a formal warning regarding the use of AI-generated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to the pro se appellant after identifying fabricated quotations and misattributed case law in his appellate brief, which the court attributed to the use of generative AI. The court explicitly declined to impose sanctions but emphasized the professional responsibility of all litigants to verify the accuracy of their citations.
The court determined that the appellant's cited quotations and holdings did not exist in the referenced opinions. It reasoned that these errors were likely AI-generated hallucinations and warned that litigants have a duty to ensure cited authorities and quotations are accurate.
This case highlights the judiciary's increasing scrutiny of AI-generated content in pro se filings. It serves as a reminder that the duty of candor and citation verification applies to all litigants, regardless of representation status, and that courts will actively identify and disregard AI-hallucinated authority.
Failure modes and consequences
- Fabricated Case Law Quotations
- Misrepresented Case Law Holdings
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- Generative artificial intelligence (AI) tool
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a district court's dismissal of civil rights claims under 42 U.S.C. § 1983 and other statutes.
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 a generative artificial intelligence tool.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.