Saad Hanna v. Kimberly A. Nelson
Colorado CA · Jan 8, 2026
What happened in this matter?
The court declined to impose sanctions against the pro se appellant for including AI-generated fabricated citations in his brief. The court determined that the appellant was a first-time offender and that the conduct, while improper, did not meet the threshold of egregious behavior necessary to warrant sanctions against a self-represented litigant.
- Why the court cared
- Fabricated: Case Law | Appellant's brief contained allegedly three AI-generated citations to nonexistent cases; doctor alleged fictitious cases produced by GenAI; court recognized at least some citations were fabricated. || Misrepresented: Case Law | Appellant incorrectly cited an unpublished decision that does exist: People in Interest of J.L.S.; citation was misused and violates court's policy on unpublished opinions. || Misrepresented: Case Law | Appellant miscited In re Estate of Ongaro; the case exists but does not articulate the test Hanna attributed to it.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in Colorado CA, with the listed outcome: Warning; No adverse costs order.
Why this matter is tracked
In this appeal, the defendant-appellee alleged that the pro se appellant, Saad Hanna, included three AI-generated fictitious case citations in his brief. The Colorado Court of Appeals acknowledged the presence of these fabricated citations, as well as the misuse of an unpublished opinion and the miscitation of a published case. The court noted that while the use of generative AI tools by self-represented litigants presents risks, it declined to impose sanctions, including attorney fees, against the appellant. The court reasoned that the appellant appeared to be a first-time offender, the cited propositions were otherwise supported by legitimate authority, and the conduct did not reach the level of egregious behavior required for sanctions against a pro se party.
This record documents a Pro Se Litigant filing issue in Colorado CA, with the listed outcome: Warning; No adverse costs order.
Record details
What the record establishes about AI use
The court refers to the use of a generative artificial intelligence tool.
Appeal of a district court order denying a C.R.C.P. 60(b) motion for relief from judgment.
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.
- Fabricated: Case Law | Appellant's brief contained allegedly three AI-generated citations to nonexistent cases; doctor alleged fictitious cases produced by GenAI; court recognized at least some citations were fabricated.
- Misrepresented: Case Law | Appellant incorrectly cited an unpublished decision that does exist: People in Interest of J.L.S.; citation was misused and violates court's policy on unpublished opinions.
- Misrepresented: Case Law | Appellant miscited In re Estate of Ongaro; the case exists but does not articulate the test Hanna attributed to it.
Questions this record answers
- What happened in Saad Hanna v. Kimberly A. Nelson?
- The court declined to impose sanctions against the pro se appellant for including AI-generated fabricated citations in his brief. The court determined that the appellant was a first-time offender and that the conduct, while improper, did not meet the threshold of egregious behavior necessary to warrant sanctions against a self-represented litigant.
- Why does Saad Hanna v. Kimberly A. Nelson matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in Colorado CA, with the listed outcome: Warning; No adverse costs order.
- What does the public record establish about Saad Hanna v. Kimberly A. Nelson?
- 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 Saad Hanna v. Kimberly A. Nelson 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.