Was Kevin Leiske v. Robert Gregory Kidd sanctioned over AI-generated citations?

Kevin Leiske v. Robert Gregory Kidd (Delaware C. Ch., July 1, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Rule to show cause issued to the signing attorney and his firm under Rule 11(c); affidavits ordered by July 15, 2026. No monetary penalty in this order.

Which AI tool was involved in Kevin Leiske v. Robert Gregory Kidd?

The order in Kevin Leiske v. Robert Gregory Kidd 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 1, 2026 · AI sanctions database

Kevin Leiske v. Robert Gregory Kidd

Kevin Leiske v. Robert Gregory Kidd 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: Delaware C. Ch.
Date: July 1, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Rule to show cause issued to the signing attorney and his firm under Rule 11(c); affidavits ordered by July 15, 2026
Penalty: No monetary penalty in this order.

Show cause

What the record shows

The Delaware Court of Chancery ordered the signing attorney and his firm to show cause why they should not be sanctioned under Court of Chancery Rule 11(c) after an answering brief was found to contain citations and quotations that could not be located and legal propositions absent from the cited opinions. Counsel acknowledged using a generative AI tool to revise the brief and not verifying the output, attributing the lapse to a paralegal's review. The court noted the corrected brief removed quotation marks while leaving the descriptions uncorrected, held the duty to verify nondelegable, and required affidavits from counsel and the firm addressing its AI policies and cite-checking process.

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 · Delaware C. Ch.

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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