HISPI Project Cerebellum HISPI PROJECT CEREBELLUM

Purportedly AI-Generated False Citations in Arizona Probate Appeal Reportedly Led to Sanctions Against Self-Represented Appellant

September 11, 2025

Self-represented appellant Jeffrey Kotchka reportedly used purported AI tools to prepare an opening brief in a probate dispute involving his late mother's estate. The Arizona Court of Appeals found six of its eight citations deficient, including two nonexistent cases, and said Kotchka had made no effort to verify them. The court affirmed the appointment of his sister, Kim Dineen, as personal representative, ordering Kotchka to pay her attorney fees attributable to addressing the false citations.

This incident highlights the risks associated with relying on AI tools for legal research without proper verification and fact-checking. It also underscores the importance of adherence to established legal standards and protocols in probate proceedings. As the use of AI in legal contexts continues to grow, it is essential that individuals like Kotchka take steps to ensure the accuracy and reliability of their citations.

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Matched TAIM controls

Suggested mapping from embedding similarity (not a formal assessment). Browse all TAIM controls

Alleged deployer
jeffrey-kotchka, pro-se-litigants, litigants
Alleged developer
large-language-model-developers
Alleged harmed parties
jeffrey-kotchka, kim-dineen, pro-se-litigants, judicial-integrity, epistemic-integrity, arizona-court-of-appeals, litigants

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Source

Data from the AI Incident Database (AIID). Cite this incident: https://incidentdatabase.ai/cite/1600

Data source

Incident data is from the AI Incident Database (AIID).

When citing the database as a whole, please use:

McGregor, S. (2021) Preventing Repeated Real World AI Failures by Cataloging Incidents: The AI Incident Database. In Proceedings of the Thirty-Third Annual Conference on Innovative Applications of Artificial Intelligence (IAAI-21). Virtual Conference.

Pre-print on arXiv · Database snapshots & citation guide

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