T.M. v. M.M.
CA Indiana · Sep 24, 2025
- Jurisdiction
- state
- Court
- CA Indiana
- Record ID
- tm-v-mm-2025-09-24
- Observed outcome
- The court affirmed the protective order and issued a formal warning regarding the appellant's use of fabricated and incorrect citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Indiana Court of Appeals issued a formal warning to a pro se litigant for submitting an appellate brief containing multiple fabricated case citations, non-existent legal authorities, and mischaracterized statutes. The court admonished the litigant that such conduct hinders judicial review and may result in future sanctions.
The court reasoned that the appellant's inclusion of fabricated citations and mischaracterized authorities made meritorious review impossible, noting that pro se litigants are bound by the same procedural standards as attorneys and must provide cogent reasoning supported by accurate citations.
This case illustrates the judiciary's intolerance for AI-facilitated or otherwise fabricated legal research in pro se filings. It serves as a reminder that courts will enforce strict citation verification standards regardless of a party's representation status.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Tort
- Appellate
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appeal from a Marion Superior Court protective order; the Court of Appeals of Indiana affirmed the trial court's judgment.
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 invented citations, implying the use of generative AI tools.
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.