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

AI Incident Database · article · Jul 16, 2026 · UTC

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.

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recordType
incident-report
evidenceStatus
reported
region
Global

Reported occurrence date: 2025-09-11T00:00:00.000Z

Evidence & attribution

AI Incident Database, Responsible AI Collaborative; McGregor (2021), Preventing Repeated Real World AI Failures by Cataloging Incidents. Incident-specific contributor credits are available at each citation link. Metadata adapted; article text excluded.

License: CC BY-SA 4.0

First collected: 2026-09-19T22:50:59.123Z. This is not the publication date.

Observed changes

AIIC observation times, not verified publisher revision times. Up to eight recent revisions.

2026-09-20T23:22:28.549Z

  • publishedAt: Not provided2026-07-16T00:00:00.000Z