If you are representing yourself and used an AI tool like ChatGPT to help draft a motion or brief, you are in a specific and documented risk category: pro se litigants using AI-generated case citations appear repeatedly in the public sanctions record, including Kruse v. Karlen (Mo. Ct. App. E.D. 2024), where a self-represented appellant was sanctioned $10,000 after a brief containing 24 citations, only two of which turned out to be genuine, reached the court. This guide covers how to check your own citations before filing, using only free tools.
Why this matters more, not less, when you don't have a lawyer
Courts generally hold self-represented litigants to the same basic obligation of accuracy as licensed attorneys when it comes to citing real, existing law, even while extending some procedural leniency elsewhere. There is no “I didn’t know” exception once the pattern of AI-hallucinated citations has become this well documented — the Kruse court’s sanction against a pro se appellant makes clear that self-representation does not create a lower bar for citation accuracy.
Step 1: List every case name and citation in your document
Go through your motion or brief and write down every case name, citation, and quoted passage in a separate list. Do this even for cases you think you remember being real — a citation you did not consciously add can hide inside a sentence the AI generated that otherwise sounds like your own writing.
Step 2: Search each citation on CourtListener, free of charge
Go to courtlistener.com, a free, nonprofit legal database, and search the exact case name and citation. If nothing matches, or if the citation resolves to a completely different case than the one named, the citation is very likely fabricated and should be removed from your filing. This single free step catches the most common and most damaging failure mode: a case that does not exist at all.
Step 3: Read the actual opinion, not a summary
For any case that does exist, click through and read the actual opinion text (CourtListener provides full opinion text for free). If your document quotes specific language from the case, use your browser’s find-in-page function (Ctrl+F or Cmd+F) to search for that exact quoted phrase inside the opinion. If it is not there, the quote is fabricated even though the underlying case is real.
Step 4: Confirm the case says what you're claiming it says
This is the step people skip because it takes the most time, but it matters: read enough of the opinion to confirm it actually addresses the legal point you are citing it for. AI tools can accurately quote real language from a real case while badly mischaracterizing what the case actually held, especially if the quoted language comes from a dissent, a summary of the opposing party’s argument, or a portion of the opinion that was later reversed.
Step 5: Watch for generic-sounding case names
Fabricated citations sometimes use suspiciously generic party names — patterns like “Smith v. ABC Corporation” or “Jones v. XYZ Corporation” have appeared in documented fabrication cases. A real case name that sounds like a placeholder is worth double-checking first, though absence of this pattern is not proof a citation is real — always still run the CourtListener check regardless.
Step 6: If your court has a self-help center, ask for a second look
Many courts have self-help centers or law libraries specifically for self-represented litigants, and some offer limited review assistance. This will not replace legal advice, but a second set of eyes on your citation list before filing is a reasonable, no-cost safeguard if one is available in your jurisdiction.
Understanding why courts hold pro se litigants to a real, if slightly flexible, standard
Courts generally extend some procedural leniency to self-represented litigants — more patience with formatting errors, missed deadlines addressed through a motion, or an unfamiliarity with local rules. That leniency does not extend to the basic factual accuracy of what is cited as law, because a fabricated citation does not just risk your own case, it can mislead the court and force the opposing party to spend real time and money chasing down something that does not exist. The Kruse v. Karlen sanction reflects the court's view that this specific harm to the opposing party and to judicial resources applies regardless of whether the filer had a lawyer.
If you cannot afford a lawyer, look for free verification help before AI-drafting help
Many jurisdictions have self-help legal centers, law school clinics, or legal aid organizations that may not be able to represent you fully but can sometimes provide limited help reviewing a draft you have already prepared. Prioritizing this kind of review specifically for your citations, even if you cannot get help with the substance of your legal argument, addresses the single highest-consequence risk category documented in the pro se AI-hallucination cases.
Warning signs that a paid drafting service may be using undisclosed AI
If you are considering paying a non-attorney “legal document preparer” or online drafting service, ask directly whether AI tools are used in preparing your document and whether citations are independently verified before delivery. A price point far below what a licensed attorney in your area would charge, combined with an unwillingness to answer this question directly, is exactly the pattern that produced the fabricated brief in Kruse v. Karlen — treat both as reasons to independently verify the citations yourself regardless of what you are told.
Understanding the specific formats CourtListener expects
When searching CourtListener, enter the citation in standard format (for example, "347 U.S. 483" for Brown v. Board of Education) rather than just the case name alone, since case names can be shared or similar across many unrelated cases while a specific reporter-volume-page combination is far more precise. If you only have a case name and no citation, CourtListener's general search can still help, but expect to review multiple results rather than a single direct match.
What to do if you can't find help and are running out of time
If a filing deadline is close and you have not been able to complete a full verification pass, prioritize checking the citations doing the most work in your argument first — the cases your strongest points depend on — rather than attempting a rushed, incomplete pass across every citation equally. A partial but focused verification pass on your most important citations is better than an unfocused attempt to check everything superficially.
A common question
What if I already filed something and I'm not sure the citations are accurate?
Run the free CourtListener checks above on your already-filed document as soon as possible. If you find a fabricated or inaccurate citation, file a corrected version or a notice with the court promptly rather than waiting to see if it gets caught — the documented cases consistently show courts respond more favorably to self-correction than to a fabrication discovered by the other side.