What happened

  • The court reviewed two filings on its own initiative: a motion to vacate (Docket Entry 125, filed July 7, 2026) and a reply on a motion for order of compliance (Docket Entry 128, filed July 16, 2026).
  • Docket Entry 125 had six problem citations. Two were cases that "do not exist" at the cite (State v. Gonzalez, 347 Conn. 770, and Vanderbilt v. Hartford Accident & Indemnity Co., 342 Conn. 215). In each, a different, unrelated case sits at that page. The others misstated what real cases hold or attributed quoted language that is not in them (Mulligan v. Rioux).
  • Docket Entry 128 had sixteen. Three more reporter cites led to unrelated cases (Gagne v. Vaccaro, Rinfret v. Porter, State v. Mattioli). Two quotations were not in the cited cases (Cologne v. Westfarms; Blumberg Associates). The rest attributed sweeping "collateral bar" and no re-filing rules to real decisions, including U.S. Supreme Court cases (National Hockey League v. Metropolitan Hockey Club, Federated Department Stores v. Moitie, Walker v. Birmingham, Maness v. Meyers). The court found those statements were not the holdings.
  • On July 14, 2026, defense counsel wrote to the plaintiff that AI use was suspected. She did not respond to that part of the letter. The defendant also raised the bad citations in an objection filed July 21.
  • The court issued an order to show cause on August 26 and set a hearing for October 5. Fifteen minutes before it, the plaintiff moved to continue. The court moved it one day. She did not appear on October 6 and never responded to the order.
  • The order does not say which AI tool was used and does not report an admission. The finding rests on the nature of the errors and her silence.

What the court said

The court relied on Connecticut's new rule. Practice Book § 4-9(b), effective June 23, 2026, requires anyone who uses generative AI in a filing to "independently verify all citations, legal authorities or evidence produced by generative AI." The rule applies to lawyers and self-represented parties alike, and filing a document is a representation that the filer complied (§ 4-9(c)).

The court acknowledged the rule is new but was "troubled by the plaintiff's lack of explanation for the use of artificial intelligence" (p. 5). It found violations of §§ 4-2(b) and 4-9(b) and said it was "adopting the narrowest sanction it can devise" (p. 5). It struck both filings and warned that further rule violations, including failing to appear, "may result in sanctions."

The defendant had asked the court to consider dismissal. The court did not dismiss. Connecticut courts say they are solicitous of self-represented litigants, but the court also noted that such a litigant "is bound by the same rules" as lawyers (p. 5, quoting precedent).

What it means for your firm

  • Opposing pro se filings now come with a verification duty on their face. If you practice in Connecticut, § 4-9 gives you a rule to cite when an opponent's brief has authorities you cannot find.
  • The cheapest tell in this order was a reporter cite that lands on a different case. Pulling the cited page takes minutes and gave this court its clearest findings.
  • Misdescribed holdings were the larger category here (14 of the 22 itemized problems, by our count). A citation checker that only confirms a case exists would have missed most of them.
  • Our reading: a notice letter from opposing counsel plus silence from the filer gave the court its record. If your firm sends such a letter, keep it, and put the specific bad citations in your written objection.
  • Our reading: the same rule binds your own attorneys' filings, and § 4-9(d) says compliance rests "solely with the person filing."

What to do Monday

  1. For any Connecticut filing you sign, add a pre-filing step where someone other than the drafter pulls every cited reporter page and confirms the case name and proposition match.
  2. When you receive a pro se or opposing brief with unfamiliar authority, check the pinpoint cite of each case and flag any that land on an unrelated case.
  3. If you suspect AI use, send a short written notice to the other side naming the specific citations, and cite Practice Book § 4-9 in your objection.
  4. Check every court in which you file for a local generative AI rule or standing order, and list the effective dates in your filing checklist.

Sources

Questions and answers

Did the court find the plaintiff used AI?

Yes, in effect. It identified "artificial intelligence hallucinations" in both filings and found a violation of § 4-9(b). The order does not name a tool or record an admission. The plaintiff never responded to the show cause order.

What was the sanction?

Both filings (Docket Entries 125 and 128) were stricken. The court called this the narrowest sanction it could devise and did not impose a fine or dismiss the case, though the defendant had asked it to consider dismissal.

Does the Connecticut rule apply to lawyers?

Yes. The court said the new Practice Book sections "apply to both self-represented parties and lawyers" (p. 4, citing Elliott v. New York Bariatric Group).

Operational information, not legal advice. Facts come from the court record linked under Sources, read on Oct 21, 2026. The reading of what it means for your firm is ours. A source link does not replace the full docket or later history.