Was Holstein v. Holstein sanctioned over AI-generated citations?

Holstein v. Holstein (Ct. App. Indiana, June 16, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Sanction request (appellee sought $5,000 in attorney's fees) denied; monetary sanctions not warranted.. No monetary penalty in this order.

Which AI tool was involved in Holstein v. Holstein?

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

June 16, 2026 · AI sanctions database

Holstein v. Holstein

Holstein v. Holstein 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: Ct. App. Indiana
Date: June 16, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Sanction request (appellee sought $5,000 in attorney's fees) denied; monetary sanctions not warranted.
Penalty: No monetary penalty in this order.

Warning

What the record shows

The Indiana Court of Appeals affirmed a custody determination and addressed the appellee's request to sanction the appellant for citing fictitious authority. The appellant's counsel had informed the court that the initial brief contained citations to two cases that do not exist and attributed a fictitious quotation to a real case, then sought leave to file an amended brief, which the court granted. The appellee requested $5,000 in attorney's fees as a sanction. The court declined, finding monetary sanctions were not warranted because counsel had brought the errors to the court's attention and taken responsibility and the appellee had not shown resulting prejudice. The court echoed warnings from other courts about the risks of using artificial intelligence in litigation.

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.

Run a free review Back to the full tracker →

Filed under · AI sanctions database · Ct. App. Indiana

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.

AI sanctions database · Sample report · Pricing · Run a scan