Al-Hamim v. Star Hearthstone, LLC
Colorado Court of Appeals · Colo. Ct. App. · Colorado bar guidance
Verified April 24, 2026
- Citation
- Al-Hamim v. Star Hearthstone, LLC, 2024COA128, No. 24CA0190 (Colo. Ct. App. Dec. 26, 2024)
- Decided
- December 26, 2024
Summary
A pro se litigant submitted a brief to the Colorado Court of Appeals containing AI-generated fictitious citations. The court found that the submitted citations violated C.A.R. 28(a)(7)(B), which requires clear argument with proper citations to authorities. The pro se litigant acknowledged the errors and apologized.
- AI tool:
- AI (unspecified)
What sanction did the court impose?
No sanction imposed. The court declined to sanction the pro se litigant given his acknowledgment, apology, and the novelty of the issue at the appellate level. The court issued an explicit warning: 'We will not look kindly on similar infractions in the future,' expressly cautioning that future AI-generated hallucinations, whether filed by lawyers or self-represented parties, 'may result in sanctions.'
Why does Al-Hamim v. Star Hearthstone, LLC matter for law firms using AI?
Al-Hamim v. Star Hearthstone is a Colorado Court of Appeals warning that AI-generated hallucinated citations are sanctionable conduct going forward. The opinion is carefully calibrated: it shows mercy to a pro se litigant who immediately acknowledged and apologized, but it removes any ambiguity about future enforcement. For Colorado attorneys, Al-Hamim is read alongside the Crabill suspension (90 days active suspension for fabricated citations plus a coverup) as a dual signal: pro se first-time errors may be forgiven, but attorney failures will not be, and coverups are aggravating factors that dramatically increase discipline.