In re Termination of Parental Rights as to H.K.
Arizona Court of Appeals · Ariz. Ct. App. · Arizona bar guidance
Verified April 26, 2026
- Citation
- In re Termination of Parental Rights as to H.K. (Ariz. Ct. App. Feb. 25, 2026)
- Decided
- February 25, 2026
Summary
An appellate brief in this Arizona parental-rights termination matter contained fabricated quotations attributed to Appeal in Maricopa County Juvenile Action No. JS-501568, 177 Ariz. 577 (App. 1994). The quoted language did not appear in the cited opinion. The Arizona Court of Appeals referred counsel to the State Bar of Arizona for disciplinary review.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Referral to the State Bar of Arizona for investigation of the fabricated citations. No monetary sanction was imposed in the appellate order itself.
Why does In re Termination of Parental Rights as to H.K. matter for law firms using AI?
Termination-of-parental-rights appeals are among the highest-stakes matters in state court: the constitutional interest at stake is severance of the parent-child relationship. Fabricated authority in such a brief is particularly damaging because the opposing party is often the state and the appellate panel relies heavily on counsel’s representations of the record and precedent. This entry is provisional pending direct review of the court’s order.
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.
- Charlotin-hosted PDF returned as binary content during automated retrieval; full case caption, docket number, sanctioned attorney name, panel composition, and exact text of the fabricated quotations could not be confirmed against the order text. Manual review of the PDF or a CourtListener docket is required before publication.
- Specific AI tool used to generate the fabricated quotations was not confirmed; "Implied" per the Charlotin candidate row.
- Whether any monetary or fee-shifting sanction accompanied the bar referral was not confirmed from the order.