Iowa · state appellate court · 2026

Cecilia Sherwin and Joseph Sherwin v. State of Iowa, Department of Criminal Investigation and Jackson County Sheriff's Office

Court of Appeals of Iowa, 22 July 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Iowa Ct. App.

  1. Court. Court of Appeals of IowaCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 22 July 2026DATED
  4. Docket. No. 25-0992DOCKET
  5. Documents. one document, 1 passage quoted belowON FILE
  6. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

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.

Published opinion, 22 July 2026 · source · PDF · 8 pages

But nothing about the State’s citation to Benskin in its trial brief breached that duty. Even if the citation form was incomplete, the case was neither hallucinated nor “suspicious.” What’s more, the State cited the case for the familiar proposition that “[m]otions to dismiss are disfavored.” Benskin, 952 N.W.2d at 296. Thus, the district court did not act with prejudice by refusing to require the defendants to disclose any use of artificial intelligence.

What the text mentions

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Where this fits

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More from Court of Appeals of Iowa, from Iowa, 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.

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