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
Verified April 26, 2026
- Citation
- In re the Matter of Rosas Carreon v. Rosas Rivera, No. 1 CA-CV 25-0415 FC, 2026 WL 292003 (Ariz. Ct. App. Feb. 4, 2026) (Fabian, J.)
- Decided
- February 4, 2026
Summary
Abiud Rosas Carreon, appearing pro per as the appellee in a marital-dissolution appeal, filed an opening brief in which three of the five cases cited contained "substantial defects, including unsupported premises and fabricated quotations." Mother's counsel (Kip M. Micuda and Carlos Noel of Hildebrand Law PC) flagged the incomplete citations as "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, found the brief violated Arizona Rule of Civil Appellate Procedure 13(a)(7), which requires arguments to contain citations to legal authority.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. The panel issued a formal warning that "failure to provide accurate legal authority may result in sanctions" in the future, denied Father's request for attorney's fees, and awarded Mother her taxable costs as the successful party. On the merits, the court vacated the Rule 69 agreement underlying the dissolution decree for lack of mutual assent and remanded.
Why does In re the Matter of Abiud Rosas Carreon v. Maria G. Rosas Rivera matter for law firms using AI?
Rosas Carreon shows the warning shot a court issues before it starts handing out checks. The appellee here was self-represented, which lowered the stakes, but the panel’s reasoning, that incomplete citations and fabricated quotations violate the rule requiring “citations to legal authority,” applies with equal force to licensed counsel. For a managing partner, the operative line is paragraph 19: “Compliance with this Court’s rules is not optional. The integrity of the appellate process depends on accurate and honest advocacy.” A firm whose brief draws that quotation in a published or memorandum decision has a malpractice-carrier conversation in its near future, regardless of whether monetary sanctions issued this time.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- The specific generative AI tool used was not named in the order; the panel inferred AI use from citation defects rather than an admission by Father.
- No CourtListener docket located for this Arizona Court of Appeals memorandum decision; only the Westlaw citation (2026 WL 292003) is currently available per the order's own notice.