Wilkinson v. Schmelzer
Decided 2026-08-19 · Outcome: No sanctions · AI tool: Implied.
8 sanctioned cases on record in CA Iowa where an attorney filed briefs, motions, or other pleadings containing AI-fabricated citations. Every entry below traces to a real, publicly reported court ruling. Data pulled daily from the underlying dockets and reporter databases — last update within 24 hours.
How courts in CA Iowa have responded when a filing contained fabricated citations.
Filings in this jurisdiction most often cite the tool as “Implied” (the ruling describes an AI-generated brief but does not name a product).
Across 8 documented sanctions in CA Iowa, the most common judicial response is Warning (2 of 8). Of the 8 cases, 1 carried an explicit monetary penalty in the ruling text.
The rulings in this jurisdiction are consistent with the pattern Citation Safe tracks nationally: when a court identifies a fabricated citation, the sanction almost always follows within days, not weeks. The attorney of record — not the AI — is on the hook. Rule 11 (federal), state analogs, and inherent authority all support monetary sanctions, disgorgement, adverse-costs orders, and bar referrals independent of the tool that produced the citation.
Practical implication: any brief that reaches a docket in CA Iowa needs a citation-existence check before filing. Existence is Layer 1 — the case has to be real. Layer 2 is quote accuracy (any quoted language must actually appear in the opinion). Layer 3 is propositional support (the opinion must actually stand for what you cite it for). Every documented sanction below failed at Layer 1 or Layer 2 — the kind of failure that is trivially catchable before filing and catastrophically visible after.
Sample penalty language from this jurisdiction: “150 USD”.
Decided 2026-08-19 · Outcome: No sanctions · AI tool: Implied.
Decided 2026-06-10 · AI tool: Implied.
Decided 2026-05-27 · Outcome: Admonishment · AI tool: Implied.
Decided 2026-04-29 · Outcome: Issues deemed waived for failure to provide valid supporting authority · AI tool: Implied.
Decided 2026-04-01 · AI tool: Perplexity.
Decided 2025-10-01 · Outcome: Brief struck; Monetary penalty OR two hours of AI-specific CLE; referral to Bar · Penalty: 150 USD · AI tool: Unidentified.
Decided 2025-09-04 · Outcome: Warning · AI tool: Implied.
Decided 2025-08-06 · Outcome: Warning · AI tool: Implied.
Other courts on the Citation Safe sanctions database with a similar volume of AI-hallucination rulings on record.
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Informational only. Not legal advice. Data derived from public court records; corrections at /contact.