Description: 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.
Editor Notes: The incident ID date is 09/11/2025, based on the official appellate docket's filing date for Jeffrey Kotchka's opening brief containing the reportedly inaccurate and nonexistent citations. The Arizona Court of Appeals later determined that Kotchka had relied on purported generative AI and had not independently verified the citations before submitting the brief. The incident ID was created 07/21/2026. See also: (1) https://apps.azcourts.gov/aacc/appella/1CA/CV/CV250606.PDF and (2) https://coa1.azcourts.gov/Portals/1/OpinionFiles/Div1/2026/1%20CA-CV%2025-0606%20PB%20Dineen%20Shibata%20v%20Kotchka.pdf.
Entities
View all entitiesAlleged: Large language model developers developed an AI system deployed by Jeffrey Kotchka , Pro se litigants and Litigants, which harmed Jeffrey Kotchka , Pro se litigants , Litigants , Kim Dineen , Judicial integrity , Epistemic integrity and Arizona Court of Appeals.
Alleged implicated AI systems: Large language models and AI-assisted legal research systems
Incident Stats
Incident ID
1600
Report Count
1
Incident Date
2025-09-11
Editors
Daniel Atherton
Incident Reports
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The Arizona Court of Appeals put lawyers and self-represented litigants alike on notice: If you let artificial intelligence write your legal brief and don't check whether the cases it cites are real, you can be sanctioned for it --- even if…
Variants
A "variant" is an AI incident similar to a known case—it has the same causes, harms, and AI system. Instead of listing it separately, we group it under the first reported incident. Unlike other incidents, variants do not need to have been reported outside the AIID. Learn more from the research paper.
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