Indiana · state appellate court · 2026

Jon Hansford Holstein v. Lacey Lawana Holstein

Indiana Court of Appeals, 16 June 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Ind. Ct. App.

  1. Court. Indiana Court of AppealsCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 16 June 2026DATED
  4. Docket. No. 25A-DC-02767DOCKET
  5. Judge. Kenworthy, Mathias, DeBoerJUDGE
  6. Documents. one document, 7 passages quoted belowON FILE
  7. 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, 16 June 2026 · source · PDF · 17 pages

Finding no abuse of discretion, we affirm. [2] On appeal, Mother requests that we order Father to pay her $5,000 in attorney’s fees as a sanction for citing fictitious cases in his initial brief. Finding monetary sanctions are not warranted, we deny Mother’s request.

Father appealed. [8] Shortly after Father’s counsel filed the reply brief in this appeal, he informed this Court that Father’s initial brief contained citations to two non-existent cases and attributed a fictious quote to an existing case. He explained that 2 It is not entirely clear from Father’s testimony whether he sought primary physical custody but intended to split parenting time with Mother equally, or whether he sought shared physical custody.

Court of Appeals of Indiana | Opinion 25A-DC-2767 | June 16, 2026 Page 5 of 17 Father had provided him with these citations, which he had included in the brief without verifying their existence or accuracy. While reviewing these authorities in preparing Father’s reply, counsel discovered they did not exist. Counsel subsequently filed a notice to this Court explaining the situation and seeking leave to file an amended brief, which this Court granted.

Counsel subsequently filed a notice to this Court explaining the situation and seeking leave to file an amended brief, which this Court granted. After Father amended his initial brief, Mother filed an amended appellee’s brief and requested that we sanction Father for the use of fictitious citations. Discussion and Decision 1.

Court of Appeals of Indiana | Opinion 25A-DC-2767 | June 16, 2026 Page 15 of 17 3. Sanctions [24] On appeal, Mother requests we sanction Father for citing non-existent legal authorities in his original brief. She seeks $5,000 in attorney’s fees as a sanction.

107 Judicature 68, 75 (2023). Court of Appeals of Indiana | Opinion 25A-DC-2767 | June 16, 2026 Page 16 of 17 [25] “Courts nationwide have confronted this problem and imposed sanctions on attorneys . . . who file briefs containing fictitious authority.” Wilcox v. Gingrich, 274 N.E.3d 1269, 1276 (Ind.

Mullin, 171 F.4th 940, 947 (7th Cir. 2026) (admonishing counsel for inclusion of non-existent citations and false quotations but declining to impose harsher sanctions where “she took responsibility and showed contrition” and “opposing counsel also failed to catch these errors and bring them to [the court’s] attention”). Furthermore, Mother offers no argument or evidence that this prejudiced her.

What the text mentions

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More from Indiana Court of Appeals, from Indiana, 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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