Simmons v. Shahidul Islam
CA Tennessee · May 21, 2026
What happened in this matter?
The Court of Appeals of Tennessee identified that the pro se appellant's brief contained citations to non-existent cases, which it characterized as 'artificial intelligence hallucinations.' The court further noted that the appellant misattributed propositions to existing cases, finding these misrepresentations unpersuasive and insufficient to support his legal arguments.
- Why the court cared
- The court reasoned that the appellant's reliance on non-existent cases and mischaracterized precedent failed to support his legal arguments, and that the underlying summary judgment was final and not voided by the death of a party during the initial appeal.
- Why it matters now
- This case illustrates the judicial identification and rejection of AI-generated hallucinations and misrepresentations in pro se appellate briefing. It reinforces the expectation that all cited authorities must be verified for existence and accuracy, regardless of the research method employed.
Why this matter is tracked
In an appellate opinion, the Court of Appeals of Tennessee addressed numerous motions filed by a pro se appellant, Tray Simmons, following the dismissal of his health care liability action. The court affirmed the trial court's denial of Rule 60.02 relief and other post-judgment motions. Notably, the appellate court identified that the appellant's brief contained citations to non-existent cases, which the court explicitly labeled as 'artificial intelligence hallucinations.' Furthermore, the court found that the appellant mischaracterized existing case law to support his propositions. The court concluded that the appellant's arguments were meritless and that the trial court did not err in its procedural handling of the case or its refusal to grant the requested relief.
This case illustrates the judicial identification and rejection of AI-generated hallucinations and misrepresentations in pro se appellate briefing. It reinforces the expectation that all cited authorities must be verified for existence and accuracy, regardless of the research method employed.
Record details
What the record establishes about AI use
The court identified the use of artificial intelligence.
Appellate review of a trial court's order denying multiple post-judgment motions, including a Rule 60.02 motion for relief from judgment, following the affirmance of a summary judgment in a health care liability action.
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 brief included case citations that do not appear to exist; the court labeled these as AI 'hallucinations' and found they did not support appellant's propositions.
- Misrepresented: Case Law | Appellant cited existing cases but attributed propositions to them that they do not support; the court found these were misrepresentations of precedent and not persuasive.
Questions this record answers
- What happened in Simmons v. Shahidul Islam?
- The Court of Appeals of Tennessee identified that the pro se appellant's brief contained citations to non-existent cases, which it characterized as 'artificial intelligence hallucinations.' The court further noted that the appellant misattributed propositions to existing cases, finding these misrepresentations unpersuasive and insufficient to support his legal arguments.
- Why does Simmons v. Shahidul Islam matter for legal AI risk?
- This case illustrates the judicial identification and rejection of AI-generated hallucinations and misrepresentations in pro se appellate briefing. It reinforces the expectation that all cited authorities must be verified for existence and accuracy, regardless of the research method employed.
- What does the public record establish about Simmons v. Shahidul Islam?
- 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 Simmons v. Shahidul Islam 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.