Background
Mynesia Anderson, appearing pro se, appealed from a Black Hawk County district court ruling that denied her 2025 motion to vacate a 2019 child-support order. On review of her briefs, the Iowa Court of Appeals discovered that at least eight purported direct quotations from appellate decisions did not actually appear in those decisions, and that two Iowa cases she cited simply do not exist — the reporter citations she provided led to unrelated out-of-state cases.
Recognizing the pattern as AI-generated “hallucinations,” the court ordered Anderson to do one of two things: file copies of the ten decisions with the relevant passages highlighted, or submit a statement disclosing whether her briefs were prepared using generative AI tools. Anderson filed a fifteen-page response that did neither. In it, she disputed the court’s jurisdiction and stated only that she “asked a friend to help with the brief and reply brief so I can neither confirm or deny the assistance of generative artificial intelligence.”
The Court’s Holding
The court found Anderson in noncompliance with its order and dismissed the appeal. Writing for a panel of Chief Judge Ahlers, Judge Buller, and Judge Sandy, Judge Buller distinguished the case from prior Iowa Court of Appeals decisions — such as In re W.G. and In re R.A. — where the court had simply stricken offending AI-fabricated citations because the offending parties had complied with the court’s inquiry and expressed remorse. Anderson had done neither.
The court also noted a second, independent reason: in the prior cases it was at least arguable that genuine legal argument could be salvaged once the hallucinated authorities were removed. Here, fabricated citations were so pervasive that no cognizable legal argument remained on which the court could rule. Dismissal was the only available remedy. The court also addressed Anderson’s suggestion that the State’s brief had been held to a different standard, confirming that it had applied the identical verification process and found all citations in the Child Support Services brief to be accurate.
Key Takeaways
- Submitting AI-fabricated case citations and failing to comply with a court order to account for them can result in outright dismissal of an appeal, not merely the striking of offending passages.
- Compliance and remorse matter: courts have been more lenient — striking bad citations rather than dismissing — when litigants cooperate with the court’s inquiry and acknowledge the error.
- The Iowa Court of Appeals has now addressed AI hallucination problems in at least six published or noted decisions in the past year, signaling an established and increasingly strict enforcement posture.
- Pro se status does not shield a litigant from sanctions for submitting fabricated authorities; the court applied the same citation-verification standard to all parties.
Why It Matters
This decision is one of the sharpest judicial responses yet to the wave of AI-hallucinated citations appearing in court filings. By dismissing rather than merely sanitizing the brief, the court signals that noncompliance with remedial orders — and pervasive, not merely incidental, fabrication — crosses a threshold where no lesser remedy suffices. For attorneys and courts, the case reinforces that verifying every citation before filing is now a baseline obligation, not an optional quality-control step.
The ruling also illustrates the compounding risk when a litigant uses AI without understanding its outputs: the substantive appeal (vacating a child-support order) was never reached on the merits, meaning Anderson lost her opportunity for appellate review entirely. As courts continue to develop norms around AI-assisted filings, Anderson is likely to be cited as the benchmark for when dismissal — rather than a corrective order — is the appropriate sanction.