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North Carolina Court of Appeals · N.C. Ct. App. · Decided October 21, 2025

Citation:

Creech v. City of Raleigh, No. COA25-513 (N.C. Ct. App.)

AI tool:

Vincent AI

What happened

Plaintiff Michael Creech sued the City of Raleigh after being struck by a tree branch in a city park, allegedly due to the city's failure to maintain the tree. The trial court dismissed on 2025-01-07; notice of appeal was filed 2025-01-29. On appeal, plaintiff's counsel cited two fictitious cases generated by Vincent AI, a legal-industry LLM. A contract attorney had conducted manual research "supplemented by" Vincent AI. The fabricated citations were Feldman v. City of Fayetteville (1979) and Polk v. Davison (1993). Counsel filed a motion for leave to amend the brief to remove the fictitious citations on 2025-10-21; the City responded on 2025-10-30.

Outcome

Pending as of 2026-04-24. No oral argument or decision reported. When decided, the ruling will establish the NC appellate standard for sanctions on AI-hallucinated filings. The City-Appellees acknowledged in their response that the court's handling of the amendment motion appears to be one of first impression in North Carolina appellate courts, and urged the court to use it to deter overreliance on AI legal research without independent verification. Counsel represented that the citations were inadvertent, the result of a licensed contract attorney using Vincent AI.

Creech is North Carolina’s first appellate test of how to handle AI-hallucinated citations. The case is pending, but it is already practically significant: the Court of Appeals will decide whether to sanction, what the sanction looks like, and whether an affirmative amendment by counsel once the error is discovered is mitigating. For firms in the Triangle and across North Carolina, the answer will set the ceiling and floor for AI-citation discipline in state appellate practice.

Primary sources

• https://appellate.nccourts.org/dockets.php?court=2
• https://www.wakeforestlawreview.com/2025/11/clearing-the-air-potential-guidance-from-the-north-carolina-court-of-appeals-on-ai-use-in-court-filings/

Last verified: April 24, 2026. Verify against primary sources before relying on this in a filing.