Dodds v. Bridges
U.S. Court of Appeals for the Tenth Circuit · 10th Cir. · Colorado bar guidance , Kansas bar guidance , New Mexico bar guidance , Oklahoma bar guidance , Utah bar guidance , Wyoming bar guidance
Conduct
Pro se § 2254 appellant cited three reporter-mismatched cases (US v. Farrow, US v. Matthews, US v. Mateo) plus fabricated quotations.
Consequence
§ 2254 denial affirmed. Court declined to sanction or dismiss and warned Dodds, and all pro se litigants and counsel before it, to cite only real, supporting authority.
Lesson
10th Cir. treats reporter-cite mismatches plus fabricated quotes as apparent AI hallucination, even when the litigant blames transcription errors.
Verified October 1, 2026
- Citation
- Dodds v. Bridges, No. 25-7021 (10th Cir. Feb. 11, 2026) (Carson, Baldock, Kelly, JJ., op. by Baldock, J.) (unpublished)
- Decided
- February 11, 2026
Summary
Pro se Oklahoma state prisoner Thomas Carl Dodds, Jr., appealed the district court's denial of his 28 U.S.C. § 2254 habeas petition, challenging a sentence-related due process claim under Tucker. The Tenth Circuit panel (Carson, Baldock, Kelly) identified three citations in Dodds's appellate briefing where the reporter cite pointed to an unrelated case rather than the cited authority: United States v. Farrow, 599 F.2d 154 (citation actually leads to Illinois v. City of Milwaukee); United States v. Matthews, 7 F.3d 1552 (citation leads to Post v. City of Fort Lauderdale); and United States v. Mateo, 476 F.3d 179 (citation leads to In re O'Lexa and Wishkin v. Potter). Quoted material attributed to Farrow and Matthews was likewise fabricated. The court attributed the conduct to unverified use of a generative AI tool "such as ChatGPT," even though Dodds claimed the brief had been typed by an unnamed outside source who introduced "transcription errors."
- AI tool:
- Generative AI inferred (panel: 'such as ChatGPT'; Dodds attributed the citations to 'transcription errors' by an unnamed outside source who typed the brief)
What did the court warn about?
Denial of habeas relief affirmed on the merits. Noting that it can sanction litigants who make such misrepresentations or dismiss their appeals, the court declined to do so here and instead warned Dodds "and all pro se litigants and counsel appearing before this court" of the responsibility to ensure that cited authority is real and at least arguably supports the proposition cited (p. 14). Motion to appoint appellate counsel denied; motion to proceed without prepayment of fees granted.
Why does Dodds v. Bridges matter for law firms using AI?
Dodds, an unpublished order and judgment, is a clear Tenth Circuit example of the reporter-cite-mismatch failure mode: a citation that looks valid on its face but points to a different case in the same reporter volume than the case named in the citation. Each of the three citations the panel addressed followed the pattern, with Farrow’s reporter slot occupied by Illinois v. City of Milwaukee, Matthews’s slot by Post v. City of Fort Lauderdale, and Mateo’s slot by two unrelated decisions. The panel concluded that the citations and quotations “appear to be fabrications resulting from the use of a generative artificial intelligence (AI) tool, such as ChatGPT.” Dodds’s explanation, that an outside source typed the brief and introduced “transcription errors,” did not hold up: the real Farrow decision he substituted “does not stand for the proposition he attributed to it,” and the explanation did not account for a fictitious citation paired with a quotation from that fictitious case (pp. 12-13).
For firms in 10th Cir. habeas appeals, the operational point is that the panel said it could sanction or dismiss for fabricated citations and chose a warning in these circumstances. The warning language explicitly extends to “all pro se litigants and counsel appearing before this court,” so a firm’s own represented filings are held to the same standard. For the proposition that AI tools generate fake cases, the panel cited Wadsworth v. Walmart Inc., 348 F.R.D. 489, 497 (D. Wyo. 2025), the District of Wyoming sanctions decision within the circuit.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- When opposing pro se habeas appeals in the 10th Cir., identifying reporter-cite mismatches in the response brief matters: here the State flagged several, and the panel addressed them and warned the appellant without a separate motion.
- Dodds is persuasive authority that an after-the-fact explanation (here, transcription errors by an outside typist) need not defeat an inferred AI-hallucination finding; the panel 'highly doubt[ed]' the explanation because the corrected cases did not support the propositions cited.
- The same panel (Carson, Baldock, Kelly, with Judge Baldock writing) also decided Chumpitaz-Morales v. Bondi the same day and Biglow v. Dell Technologies on March 24, 2026, both AI-citation matters on this tracker.
Sources
Primary sources
- Federal Courts (primary source)
- Federal Courts (primary source)
- CourtListener docket (primary source)
- Government primary source
- No Westlaw assignment is visible in the unpublished opinion's PDF header at this verification pass.