Wisconsin Court of Appeals Warns Pro Se Appellant in Waushara County v. Bruning Over False Citations and Possible AI Use

What happened

• Beatrice Bruning, representing herself, appealed two judgments finding her guilty of county traffic ordinance violations (left of center, and failure to keep control of her vehicle) after a June 2024 ditch crash. This was her second appeal; the first ended with the commissioner's trial order void because a court commissioner lacked authority to preside.
• The appeal argued that the circuit court acted too early, before the record was remitted from the first appeal, and violated the appellate mandate.
• In footnote 6, the court says some of her citations "are to legal authorities that do not exist," and others "exist but are wholly unrelated to the proposition for which they are cited."
• The circuit court had already cautioned her about false citations, and the County raised concerns in its respondent's brief. According to the court, she "did not acknowledge her error in her reply brief and instead repeats some of the same false citations."
• The order does not list the specific false citations.

What the court said

The court affirmed both judgments summarily under Wis. Stat. Rule 809.21. On the merits, it assumed her view of the statutes was right, but held she had forfeited the competency argument by not raising it in the circuit court, and said she showed no harm. On the mandate, it noted that she "again supports her argument with citations to false authority."

On the citations, the court held that false citations violate Rules 809.19(1)(e) and (4)(b) and are "a significant violation of court rules, especially when done in a repeated manner." It considered ordering her to show cause under Rule 809.19(2) but chose "a prompt resolution of this appeal," cautioning her "not to repeat this violation in any future filings in this or any court." It then added: "It could be that the root of the problem is that Bruning used generative AI for legal research and trusted it to provide accurate results."

The order is a one-judge summary disposition and is not published; the order says such orders may not be cited as precedent or authority except for limited purposes under Rule 809.23(3).

What it means for your firm

• The court did not find that AI was used. It raised it as a possible root cause ("It could be"), so the AI link is the court's guess and not a finding.
• No sanction was imposed, but the court said it considered one, and it noted the repeated citations after warning. Our reading: the first warning matters, and ignoring it is what moves a court toward sanctions.
• If you represent a county, municipality or other repeat party facing self-represented litigants, your respondent's brief is where the court looked for the first flag. Here, the County raised the issue.
• Because this is an unpublished summary order, use it as an example of how one appellate judge handled the issue and not as authority.

What to do Monday

1. When you receive a pro se brief, check every authority for existence and relevance before drafting your response.
2. If you find false citations, say so specifically in your respondent's brief, identifying each one, as the County did here.
3. Consider asking the court to address any repetition of false citations after a prior warning, since the order shows that is what the court weighed.
4. Do not cite this order as precedent in Wisconsin; if you need to refer to it, check Rule 809.23(3) first.

Sources

• Wisconsin Court of Appeals summary disposition order, Waushara County v. Bruning, Nos. 2025AP2505 and 2025AP2506 (Oct. 15, 2026), 2026 WL 3083883
• AI Vortex Legal AI Risk record for this matter (Structured record in the public case database)

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.