Was dineen/shibata v. Kotchka sanctioned over AI-generated citations?

dineen/shibata v. Kotchka (CA Arizona, July 15, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Sanction: the portion of appellee's reasonable attorney fees attributable to the unverified citations, plus costs on appeal (amounts contingent on ARCAP 21 compliance). No monetary penalty in this order.

Which AI tool was involved in dineen/shibata v. Kotchka?

The order in dineen/shibata v. Kotchka does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

July 15, 2026 · AI sanctions database

dineen/shibata v. Kotchka

dineen/shibata v. Kotchka is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: CA Arizona
Date: July 15, 2026
Party: Pro Se Litigant
AI tool: Not identified in the order
Outcome: Sanction: the portion of appellee's reasonable attorney fees attributable to the unverified citations, plus costs on appeal (amounts contingent on ARCAP 21 compliance)
Penalty: No monetary penalty in this order.

FineShow cause

What the record shows

The Arizona Court of Appeals, Division One, affirmed and sanctioned a self-represented appellant under A.R.S. Section 12-349 and ARCAP 25 for an opening brief containing cases the court could not locate and misrepresentations of other authority. Ordered to show cause and testifying under oath, the appellant stated he relied on artificial-intelligence-assisted research tools and admitted taking no independent step to verify the authorities. The court held that citing an unverifiable case is sanctionable whether the filer is an attorney or self-represented, and awarded the appellee that portion of her reasonable attorney fees incurred because of the citations, plus costs, contingent on ARCAP 21 compliance.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · CA Arizona

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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