Yes, using ChatGPT or a similar AI tool to help with court papers is not against the law by itself, but the person who signs and files the paper answers for every case it cites. In July 2026 the Arizona Court of Appeals said using generative AI "is not, in and of itself, objectionable" if the signer checks that the cases are real and accurately cited. It then ordered a self-represented man to pay part of his sister's legal fees over cases that do not exist.
Is it legal to use AI to write my own court papers?
Nothing in the rulings discussed here bans AI tools. The Arizona court, in a published opinion called Dineen/Shibata v. Kotchka, went out of its way to say that it "recognize[s] the promise" these tools hold for people who cannot afford a lawyer. That promise came with two conditions. The person signing the brief has to check that every case cited is real and accurately cited, and has to check that the facts cited from the record are correct.
The case came from a family fight over a will. A man appealed a probate ruling that admitted his late mother's will and made his sister the personal representative of the estate. He represented himself. His opening brief had eight citations, and six of them were deficient. Two were cases that "simply do not exist," according to the court. He told the judges he had used "artificial-intelligence-assisted research tools."
What can AI safely help with, and where does it go wrong?
The Arizona court listed the uses it viewed as fine: checking grammar, suggesting edits for clarity and concision, and summarizing large documents. Those tasks work with text you already have, so you can compare the result against your own material.
The trouble starts when the tool is asked to find the law. The same opinion called an unchecked AI tool "an unreliable narrator and researcher" and said it sometimes produces citations to authorities that do not exist, which is what people mean by a "hallucination." The court also warned that anyone can type a simple prompt and instantly receive a lengthy motion that looks competent, and that the results "very often are not" competent.
A Florida appeals court opinion, Kid International, LLC v. City National Bank of Florida, shows that the failures come in more than one form. The court found a case that did not exist (cited seven times in one brief, with a made-up quotation), a case cited with the wrong court, year, and citation that did not say what the brief claimed, and a quotation attributed to a real opinion that does not appear in it. In a footnote, the court described the same plaintiffs' earlier self-written complaint: it cited 32 cases, and 15 of them did not exist. Only one was accurately cited with the correct holding.
What have courts actually done to self-represented people?
The consequences differ by court, so here are the three rulings that involve people without lawyers.
In Arizona, the court struck the inaccurate and false citations. Because the brief had no other legal support, the court treated the arguments as waived and affirmed the probate ruling. It then awarded the sister the part of her reasonable attorney fees caused by the hallucinated and misrepresented citations, plus her costs on appeal. The court said it was joining "many courts nationwide" that sanction both lawyers and self-represented litigants for this.
In Florida's Second District Court of Appeal, Washington v. Justice involved a couple whose brief cited eleven cases the court could not find. They called it a scrivener's error caused by "intense logistical pressure." The court answered that "it is not the source of the fictitious cases that concerns us, but the Washingtons' reliance on them." It dismissed the appeal and told the clerk to put any new appeals or original proceedings they file in that court about the same lower-court case in an inactive file unless a member in good standing of The Florida Bar signs them. The court also relied on the couple's history of filings it called meritless in this case and two related ones, so the fake citations were not the only factor.
In Arkansas, the state Supreme Court issued an order to show cause to a self-represented man in a probate matter after finding a cited case, Biscoe v. Williams, that "does not appear to exist." The court said it was concerned the citation "was hallucinated by artificial intelligence." That order was a demand for an explanation. As of this writing, the outcome is not known, and nothing here should be read as a finding that he was sanctioned.
Does it matter if I did not know the AI made the cases up?
It did not excuse anyone in the Arizona case. The man there said he was not a trained lawyer and that the fake cases were unintentional, and he asked for indulgence. The court answered that submitting hallucinated case citations is unjustifiable whether the error is intentional or not, and that accepting a lack of bad intent as a defense would "legitimize reckless indifference to the truth."
The court did say his lack of training and lack of intent were relevant to choosing the sanction. They did not remove the sanction. The judges also noted that he admitted he did nothing to verify the citations, had not reviewed the free self-represented litigant materials on the court's own website, and did not move to amend his brief or offer to withdraw his appeal after the other side pointed out the problems. They appreciated his candor, but said every litigant, with or without a lawyer, must make sure filings follow the rules, and that relying on AI does not excuse or ease that requirement.
The court acknowledged that people without lawyers often lack easy access to professional legal databases and may not know these tools produce fake cases. It then said that difficulty "cannot, and does not, excuse" filing papers that rely on nonexistent authority.
Who is responsible for a citation, the AI company or the person who signs?
The person who signs. Arizona's court put it this way: anyone who files "may not offload their duty" to check the truth and accuracy of what the filing says "to any technological tool." Arkansas's Supreme Court, in its order, said that people who represent themselves there are "held to the same standards as licensed attorneys with respect to complying with the rules."
Florida wrote the idea into a rule. Effective June 15, 2026, the Florida Supreme Court amended Rule 2.515(d)(2) so that anyone who signs a document filed in Florida's courts represents that "the legal authorities identified exist and are accurately cited." The Court said this applies to filings by attorneys and by unrepresented parties. After notice and a chance to be heard, a court can impose sanctions that "may include reprimand, contempt, striking of the document, dismissal of proceedings, costs, attorneys' fees, or other sanctions."
Florida's Supreme Court also issued Administrative Order AOSC26-12. It tells Florida courts that they may not impose their own AI disclosure or certification requirements and should rely on the statewide rule. In Florida state courts, the duty the rule describes is accurate citations, not a separate announcement that you used AI. That order is about Florida only. Elsewhere, an individual court or judge may have its own AI rule, which is why checking local rules matters.
Federal civil cases carry a similar duty. Under Federal Rule of Civil Procedure 11(b), an attorney or unrepresented party who presents a paper to the court, whether by signing, filing, submitting, or later advocating it, certifies after an inquiry reasonable under the circumstances that its legal contentions are "warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law." Federal appeals courts have their own rules.
How do I check every citation before I file?
Verification takes time but costs little. Do these steps before the paper is filed.
List every case, statute, and rule the draft mentions, along with every quotation.
Find each case on the court's own official website, or ask a public law library or a court self-help center to help you pull it. If you cannot find a case anywhere, treat it as fake and delete it.
Read the actual opinion, not a summary. Confirm that the court, the year, and the citation match what your draft says.
Check every quoted sentence against the opinion and confirm it appears word for word. Fabricated quotations from real cases were part of the problem in the Kid International case.
Confirm the case says what you claim it says. A real case can still be cited for something it does not hold.
Confirm the court that decided it applies to your case. A ruling from one state's court does not bind a judge in another state.
Check the local rules and the judge's procedures for any rule about AI. Some courts have their own, and Florida's order bars them in its state courts.
Check the facts you cite from your own case file against the record, since Arizona expected that too.
If you find an error after filing, move promptly to correct or withdraw the paper. Arizona faulted the litigant for not amending his brief or offering to withdraw his appeal after he learned of the problems.
What should I do if the court orders me to show cause about a citation?
Treat the order as urgent and answer by the deadline. The Arkansas order gave a specific date and time and told the man to either provide a copy of the case or explain how he learned of it, why he cited it, and why he should not be sanctioned. The Florida order in the Washington case asked the couple to supply copies of the eleven cases or show why sanctions should not be imposed, and it named dismissal as a possible sanction.
Be candid and specific. In Arizona, the court held a hearing, took the man's sworn testimony, and said it appreciated his candor. Candor alone did not avoid a fee sanction. The Florida couple's response neither confessed nor denied using AI and blamed volume and page numbers that were "mangled" during drafting, and the court said it failed to adequately explain the fabricated citations.
Correct what you can. If a cited case is fake, say so, withdraw the argument, and explain what you will do differently. Do not count on a particular result, because the sanction depends on the court and the facts. In the Kid International case, the lawyer admitted the errors, asked to replace the brief, and described new checking procedures, and the court still granted fees as a sanction. A lawyer, legal aid office, or court self-help center can help you prepare the response.
Does hiring a lawyer protect me from AI mistakes?
Not automatically. In the Kid International case, the plaintiffs began by filing the complaint themselves, then hired a lawyer. The lawyer told the court he had accepted his client's offer to supply research and authorities, and that his firm used generative AI as one component of its research and drafting. His verification step missed the bad cases. The court affirmed the ruling against the plaintiffs on statute-of-limitations grounds and then granted the defendants' motion for appellate attorney fees as a sanction. The plaintiffs and their lawyer were made jointly and severally liable for the award, which means the client can be on the hook for the fees too. The opinion notes it is not final until any timely motion for rehearing is decided.
Lawyers also face discipline. In Matter of Sethi, a precedent decision, the Board of Immigration Appeals suspended an attorney for six months from practice before the Board, the immigration courts, and the Department of Homeland Security, effective June 13, 2026. The suspension followed a Ninth Circuit suspension of the attorney for a brief with AI hallucinations and false statements to the court about his AI use.
If you have a lawyer, ask how the firm confirms citations before anything is filed, and do not hand over research from a chatbot as if it were verified. If you are still deciding whether to hire help, see our pages on divorce without a lawyer and representing yourself pro se for what self-representation involves.
Do these rulings apply where I live?
Each ruling binds only the court system that issued it. The Arizona opinion governs Arizona's courts, the Florida rule and appeals rulings apply in Florida, the Arkansas order concerns Arkansas, and the Board of Immigration Appeals decision applies in the immigration system. A judge in another state is not bound by them, and other courts may use different procedures.
What the rules cited here share is where they put the responsibility: on the person who signs or presents the paper. That is true of the Arizona rules, the Florida rule, the Arkansas rule the court mentioned, and Federal Rule 11. The law here is also still developing. Several of the opinions are recent, the Florida appeals opinions can still be revised or reheard.
This page is general legal information, not legal advice for your situation. Court rules change and differ by court, so check the rules that apply to your case or talk to a lawyer, legal aid office, or court self-help center.
Frequently asked questions
Is it illegal to use ChatGPT to write a motion or brief?
The rulings discussed here do not treat AI use as illegal or banned. The Arizona Court of Appeals said using generative AI is not, in and of itself, objectionable. The catch is that the person who signs the paper must make sure every cited case is real and accurately cited, and that the facts are correct.
What happens if my court paper cites a case that does not exist?
It depends on the court. Courts discussed here have struck the false citations, awarded the other side part or all of its attorney fees, dismissed an appeal (fake cases were one of several reasons), and ordered litigants to explain themselves. Florida's rule lists reprimand, contempt, striking, dismissal, costs, and attorneys' fees as possible sanctions.
Do I have to tell the court I used AI?
It depends on where you file. Florida's Supreme Court barred its state courts from imposing their own AI disclosure or certification requirements and relies on the rule that signers represent that cited authorities exist and are accurately cited. Other courts or individual judges may have their own rules, so read the local rules and the judge's procedures.
Does being self-represented get me a break on fake citations?
Not on the duty to be accurate. Arizona held self-represented people to the same standards as attorneys, and Arkansas said the same of its litigants. Lack of legal training and lack of intent did not excuse the Arizona litigant, though the court said they could shape the sanction it chose.
How can I check a case an AI tool gave me without paying?
Look the case up on the issuing court's own website, or ask a public law library or court self-help center to help you find it. Read the whole opinion, confirm each quotation appears word for word, and confirm the case says what you claim. If you cannot find it, do not cite it.
This article is general legal information, not legal advice, and may not reflect the most current law or the law in your jurisdiction. Laws vary by state and change over time. For advice about your specific situation, consult a licensed attorney.
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