AIPolicyTracker

AI incident ·

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

1 news report Snapshot 7 Sep 2026

In brief

An AI system built by Large Language Model Developers and deployed by Jeffrey Kotchka, Pro Se Litigants and 1 other allegedly harmed Jeffrey Kotchka, Kim Dineen and 5 others.

Risk domain
Not classified
Occurred
Coverage
1 reportJul 2026

What happened

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.

Laws that address this harm

No recorded instrument yet addresses this use case where it happened. See the open queue.

Matched from the record's risk domain and country to the instruments recorded here. A reviewer can correct the match in the repository (data/external/incident_overrides.yaml).

News reports (1)

Titles link to the original publisher; report text is not reproduced here.

Who was involved

Alleged harmed party
Jeffrey Kotchka, Kim Dineen, Pro Se Litigants, Judicial Integrity, Epistemic Integrity, Arizona Court Of Appeals, Litigants

Classification (MIT AI Risk Repository taxonomy)

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Source record: incident #1600 on the AI Incident Database · all 1 report