Pamela Blair v. Sanctuary Bluff Homeowners Association, Inc.
Kentucky Court of Appeals · Ky. Ct. App. · Kentucky bar guidance
Verified May 14, 2026
- Citation
- Blair v. Sanctuary Bluff Homeowners Ass'n, No. 2024-CA-0650-MR, 2026 WL 784501 (Ky. Ct. App. Mar. 20, 2026) (Cetrulo, J.)
- Decided
- March 20, 2026
Summary
Pamela Blair, proceeding pro se, brought a consolidated appeal to the Court of Appeals of Kentucky from seven Jefferson Circuit Court orders in a sprawling homeowners-association and foreclosure dispute. In one of the six consolidated appeals, the HOA moved to strike Blair's brief over nine hallucinated citations. Blair admitted she had used AI and said she had submitted the wrong draft by mistake. The court struck the brief and let her refile with a certification that the new brief was AI-free. Her refiled brief still contained a hallucinated case, and her reply brief added yet another. The court named one of the fabrications: a "Pinnacle Homeowners Ass'n v. JPMorgan Chase Bank, 502 S.W.3d 891 (Ky. App. 2016)," where the reporter citation actually belongs to a Texas sexual-assault case.
- AI tool:
- Unidentified generative AI (Blair admitted using AI; no specific tool named)
What sanction did the court impose?
The court affirmed the circuit court's orders dismissing all of Blair's claims, and affirmed the foreclosure summary judgment except as to the attorneys' fee award, which it vacated and remanded for a reasonableness review. On the AI conduct, the court imposed no monetary sanction. It struck Blair's first noncompliant brief and required an AI-free certification on the refiled version; when the refiled brief and then the reply brief still contained hallucinated cases, the court denied the HOA's renewed motion to dismiss "in an abundance of grace." The repeated hallucinations across three successive briefs, despite a strike order and a certification requirement, were part of the recalcitrant litigation pattern the court found had "likely sabotaged her own litigation."
Why does Pamela Blair v. Sanctuary Bluff Homeowners Association, Inc. matter for law firms using AI?
Blair v. Sanctuary Bluff is the rare AI-citation case where the hallucinations recur across three successive briefs in the same appeal, each time after the court had already addressed the problem. The HOA moved to strike Blair’s brief over nine hallucinated citations. The court struck it and required an AI-free certification on the refiled version. The refiled brief still contained a hallucinated case. The reply brief added another, and arrived without the required certification.
What the case shows is the limit of a strike-and-refile remedy against a pro se litigant who will not adjust. The Court of Appeals never imposed a monetary sanction; it denied the HOA’s renewed dismissal motion “in an abundance of grace” and reached the merits anyway, affirming the dismissals on independent grounds. For a firm opposing a pro se appellant in Kentucky, the practical read is that moving to strike an AI-tainted brief is worth doing, but it will not necessarily end the appeal: the court is more likely to build a record of the litigant’s conduct and resolve the case on its merits than to dismiss outright.