Robert Cole Stemkowski Goldman v. Arizona Board of Regents
Robert Cole Stemkowski Goldman v. Arizona Board of Regents 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
- D. Arizona
- Date
- October 29, 2025
- Party
- Lawyer
- AI tool
- Not identified in the order
- Outcome
- Order to show cause why counsel should not be sanctioned under Rule 11
- Penalty
- No monetary penalty in this order.
What the record shows
The court confirmed that plaintiff's counsel cited a case that does not appear to exist (Morley v. City of San Rafael) in support of a qualified-immunity argument, and noted other indicators that counsel used generative AI without sufficient attorney review. The court ordered counsel to explain the issues and to show cause why he should not be sanctioned under Rule 11.
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
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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