Was Eric Posey v. Summer Bushnell sanctioned over AI-generated citations?

Eric Posey v. Summer Bushnell (SC Idaho, September 22, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: No sanction imposed under I.A.R. 11.2 after supplemental briefing on whether to dismiss the appeal as a sanction; nine of ten issues declined for deficient briefing; defamation judgment affirmed. No monetary penalty in this order.

Which AI tool was involved in Eric Posey v. Summer Bushnell?

The order in Eric Posey v. Summer Bushnell does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

September 22, 2026 · AI sanctions database

Eric Posey v. Summer Bushnell

Eric Posey v. Summer Bushnell 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: SC Idaho
Date: September 22, 2026
Party: Pro Se Litigant
AI tool: Not identified in the order
Outcome: No sanction imposed under I.A.R. 11.2 after supplemental briefing on whether to dismiss the appeal as a sanction; nine of ten issues declined for deficient briefing; defamation judgment affirmed
Penalty: No monetary penalty in this order.

WarningAlleged

What the record shows

The Idaho Supreme Court affirmed a defamation judgment against a self-represented appellant whose briefing, it found, cited a case that does not exist under the given citation and two cases it could not locate. The court also found that only six of twenty-two purported quotations were accurate. It stated the nature of the errors suggests she may have relied on generative AI; she denied doing so, and the court said the record raised serious doubt about that denial. After ordering supplemental briefing on dismissal as a sanction, the court declined to rule on nine of her ten issues for inadequate briefing but imposed no sanction, noting the $1,176,000 judgment against her.

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 · SC Idaho

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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