Kennon v. Ashley
U.S. District Court, District of Kansas · D. Kan. · Kansas bar guidance
Verified October 1, 2026
- Citation
- Kennon v. Ashley, No. 5:24-cv-04034-JWB, Doc. 66 (D. Kan. Mar. 18, 2026) (Broomes, C.J.); see also order to show cause (D. Kan. Feb. 18, 2026)
- Decided
- March 18, 2026
Summary
Filing in Kennon v. Ashley contained a fabricated block-quoted colloquy purportedly attributed to defendant Ashley, with no support in the record. The court issued an order to show cause directing the filer to explain why sanctions should not be imposed for citing or quoting material that does not exist, a hallmark of unverified generative-AI output submitted without independent verification.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction was imposed. On February 18, 2026 the court ordered counsel to respond in writing addressing the source of the fabricated deposition colloquy in Plaintiff's motion for reconsideration and the use, if any, of generative AI tools. On March 18, 2026, after counsel's response accepting responsibility, the court denied the motion "in light of the misleading representations," finding that "[t]he incorrect representations are so intertwined with the motion that they cannot be untangled" (Doc. 66).
Why does Kennon v. Ashley matter for law firms using AI?
Fabricated quotations attributed to a named party are a distinct and especially damaging hallucination mode: unlike phantom citations, a manufactured colloquy puts words in a real person’s mouth on the public docket. For managing partners, the takeaway is that verification protocols must cover record quotations and party admissions, not just case citations, before any AI-assisted draft is filed.
Sources
Primary 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.