Teresa Jewel Whitten v. Kristopher Brian Everitt
CA Kentucky · Jul 10, 2026
- Jurisdiction
- state
- Court
- CA Kentucky
- Record ID
- teresa-jewel-whitten-v-kristopher-brian-everitt-2026-07-10
- Observed outcome
- The court affirmed the domestic violence order and issued a formal warning to the appellant regarding her non-compliant appellate brief.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Kentucky Court of Appeals issued a warning to a pro se litigant after determining she used generative AI to draft her appellate brief, which included two fabricated case citations and multiple mischaracterized legal authorities. The court cautioned that future non-compliant filings may result in severe penalties.
The court reasoned that the appellant failed to comply with RAP 32(A)(4) by including non-existent and mischaracterized authorities, noting that while pro se litigants are held to a different standard, they are not exempt from procedural rules. The court exercised its discretion to review the merits rather than striking the brief, but issued a formal warning that future non-compliance could lead to severe penalties.
This case illustrates judicial scrutiny of AI-generated filings in pro se appellate practice. It reinforces that courts will identify and penalize the inclusion of hallucinated or misrepresented authorities, even when the court chooses to reach the merits of the underlying dispute.
Failure modes and consequences
- Fabricated Case Law
- Misrepresented Case Law
- Incorrect Citations
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Explicitly Recorded
- Recorded tool
- Generative AI
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a domestic violence order (DVO) entered by the Daviess Circuit Court.
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 explicitly stated the appellant used Generative AI.
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.