In re the Matter of Abiud Rosas Carreon v. Maria G. Rosas Rivera
Court of Appeals of Arizona, Division 1 · Ariz. Ct. App. · Arizona bar guidance
Conduct
Here the pro per appellee's brief cited five cases, three of which the court found had substantial defects, including unsupported premises and fabricated quotations.
Consequence
No sanction; the court found a Rule 13(a)(7) violation and warned that future failure to provide accurate authority may result in sanctions.
Lesson
Here the opposing party flagged the incomplete citations, and the court checked them and found fabricated quotations.
Verified September 29, 2026
- Citation
- In re the Matter of Rosas Carreon v. Rosas Rivera, No. 1 CA-CV 25-0415 FC, Memorandum Decision (Ariz. Ct. App. Feb. 4, 2026) (Fabian, J.)
- Decided
- February 4, 2026
Summary
In a marital-dissolution appeal, Maria G. Rosas Rivera ("Mother") challenged a decree resting on a Rule 69 agreement; Abiud Rosas Carreon ("Father") was the appellee and appeared pro per. Mother pointed out that "[m]any of [Father's] citations are incomplete, a sign of the use of [Artificial Intelligence]." Judge Veronika Fabian, joined by Presiding Judge Michael J. Brown and Vice Chief Judge David D. Weinzweig, wrote that "[t]his Court's review reveals that three of the five cases Father cited in his opening brief contain substantial defects, including unsupported premises and fabricated quotations," and found the brief violated Arizona Rule of Civil Appellate Procedure 13(a)(7), which requires that arguments contain citations to legal authority. The decision does not identify the defective cases and does not itself attribute them to AI; the only AI reference is its quotation of Mother's argument.
- AI tool:
- Unidentified (the decision quotes Mother's assertion that incomplete citations are "a sign of the use of [Artificial Intelligence]" but makes no AI finding of its own and names no tool)
- Amount or terms:
- None
What did the court warn about?
No sanction. The court warned: "Compliance with this Court's rules is not optional. The integrity of the appellate process depends on accurate and honest advocacy. In the future, failure to provide accurate legal authority may result in sanctions." It denied both parties' requests for attorney's fees and awarded Mother her taxable costs as the successful party on appeal. On the merits, the court held the Rule 69 agreement unenforceable for lack of mutual assent on how Mother would acquire the marital residence, vacated the decree to the extent it relied on that agreement, and remanded. The decision is a memorandum decision marked "NOT FOR OFFICIAL PUBLICATION" and not precedential under Arizona Supreme Court Rule 111(c).
Why does In re the Matter of Abiud Rosas Carreon v. Maria G. Rosas Rivera matter for law firms using AI?
Rosas Carreon is a warning to a self-represented party. Father, appearing pro per as the appellee, filed a brief citing five cases. Mother argued that many of his citations were incomplete and suggested that was “a sign of the use of [Artificial Intelligence].” The court then conducted its own review and found that three of the five cases “contain substantial defects, including unsupported premises and fabricated quotations,” a violation of Arizona Rule of Civil Appellate Procedure 13(a)(7).
The panel did not adopt Mother’s AI theory or make any finding about how the defects arose, and it did not identify the cases. Its response was a warning rather than a sanction: “Compliance with this Court’s rules is not optional. The integrity of the appellate process depends on accurate and honest advocacy. In the future, failure to provide accurate legal authority may result in sanctions.” Mother prevailed on the merits, and the court vacated the decree to the extent it relied on the Rule 69 agreement.
Firms documenting compliance may wish to consider that here the defects were raised by the opposing party and confirmed by the court’s own check.
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.
- Verify quotations and premises for each cited case. Here the court found defects in three of the five cases in a self-represented party's brief.
- Review cited cases for fabricated quotations. Here the court's own review found substantial defects ("unsupported premises and fabricated quotations").
Sources
Primary sources
- AI attribution is a Charlotin tracker inference and Mother's argument: the court found "fabricated quotations" and a Rule 13(a)(7) violation but made no finding that AI was used and named no tool.