Arkansas · state supreme court · 2026
Supreme Court of Arkansas, 11 December 2025 to 5 February 2026. What the court wrote about citations that did not exist, in its own words, from 2 documents on file.
Case record · Ark.
Retrieved · the text below was read from the source documents on that day.
The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
217. During this court’s review of the expedited matter, we determined that parts of McClain’s response contained citations, including a direct quote, to cases that could not be located. We ordered McClain to respond to our concerns, provide any actual case law, and explain the specifics of how this occurred.
The Department maintained that the circuit court’s review order compelled the Department to take action that violated both the Juvenile Code and separation of powers. Dana McClain, t he attorney ad litem for the minor child , responded to the Department’s petition.1 During this court’s review of the expedited matter, we determined that parts of McClain’s brief contained citations to cases that could not be located. McClain included 1On December 4, we resolved the Department’s request for expedited consideration and the request for writ of certiorari.
And McClain cited a statute––without noting the statute has changed––for a proposition of law that the statutory text does not support. We are concerned that the citations may have been the result of generative artificial intelligence (GAI) tools and thus “hallucinated.” We put the Bar of Arkansas on notice about our concern in this area last spring. In re Amendments to the Ark.
Show-cause order issued. 2In addition to the “hallucinated” citations noted above, we are also gravely concerned about the possibility that confidential or sealed information —particularly regarding a juvenile—may have been entered into a GAI tool. We caution that the Arkansas Rules of Professional Conduct apply when using GAI.
Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.
This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.
More from Supreme Court of Arkansas, from Arkansas, or from 2026. The whole record is at court decisions on AI-hallucinated citations.
Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.