Rechlicz v. Price Point Builders, LLC
Court of Appeals of Indiana · Ind. Ct. App. · Indiana bar guidance
Conduct
Counsel's brief cited Nat'l Wine & Spirits, 976 N.E.2d 286 (Ind. Ct. App. 2001), a non-existent merged-citation typo.
Consequence
Counsel admonished for failure to proofread and verify; sanctions request denied. Merits affirmed on arbitration.
Lesson
Ind. Ct. App. distinguishes typos from AI hallucinations but admonishes either; AI-hallucination is the default narrative now.
Verified May 7, 2026
- Citation
- Rechlicz v. Price Point Builders, LLC, No. 25A-PL-1071 (Ind. Ct. App. Feb. 12, 2026) (DeBoer, J.)
- Decided
- February 12, 2026
Summary
Indiana Court of Appeals decision authored by Judge DeBoer (Brown and Altice concurring) affirming a trial court order compelling arbitration in a homebuilder dispute. In ruling on the merits, the panel separately addressed the appellants' request to sanction the appellee's counsel for, among other things, citing a case that does not exist: "Nat'l Wine & Spirits, Inc. v. Ernst & Young LLP, 976 N.E.2d 286, 289 (Ind. Ct. App. 2001)." The court concluded the defective citations were the result of inadvertent typographical errors (counsel had conflated two real authorities into a single nonexistent cite), declined to impose monetary sanctions, and admonished appellee's counsel to proofread and verify legal authorities. The panel framed the admonishment in the broader context of generative AI hallucinations, noting "many courts" have sanctioned attorneys for AI-fabricated cites and citing HoosierVac as the leading Indiana federal precedent.
- AI tool:
- Not identified; court characterized errant citation as a typographical mistake but framed the broader risk as generative AI hallucination
What sanction did the court impose?
Appellee's counsel admonished for failure to proofread and verify legal authorities; sanctions request denied. Trial court order compelling arbitration affirmed on the merits. No monetary sanction.
Why does Rechlicz v. Price Point Builders, LLC matter for law firms using AI?
Rechlicz is the Indiana Court of Appeals’ clearest articulation of how the panel will treat ambiguous citation defects in the AI era. The appellants asked the court to sanction Price Point’s counsel for citing “Nat’l Wine & Spirits, Inc. v. Ernst & Young LLP, 976 N.E.2d 286, 289 (Ind. Ct. App. 2001).” That case does not exist. The court traced the error: the citation appears to have merged a real Indiana Supreme Court decision (976 N.E.2d 699) with a quoted Court of Appeals decision (743 N.E.2d 286, 289), producing a chimeric cite that pointed to neither. Judge DeBoer concluded this was a typographical error, not a fabrication, and declined to sanction. But the panel still admonished counsel and used the moment to note that “the increasingly prevalent use of generative artificial intelligence (AI) has led many courts to sanction attorneys whose filings included fake case citations,” collecting HoosierVac as the leading Indiana example.
For an Indiana appellate practice, the operational implication is that the line between typographical error and AI fabrication is thin and the panel will narrate either in AI-hallucination terms. A firm whose brief contains a defective cite needs to be able to demonstrate, in real time if asked, that the error was the result of clerical handling rather than AI use. That requires keeping a verifiable trail of how each citation was generated and proofread, and avoiding the merged-citation pattern that produced the Rechlicz error.
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.
- Train brief-finalization staff that an Indiana appellate panel will narrate a defective citation in AI-hallucination terms even when the underlying cause is a clerical error, because the reader cannot tell the difference at first review.
- Review citation conventions to avoid combining two real cites into a single citation string; the merged-citation pattern in Rechlicz is the diagnostic the court used to distinguish typo from fabrication.
- Document any cite-verification process the firm uses, so that if a defective citation surfaces in an Indiana appellate brief the firm can plausibly distinguish a typographical error from AI fabrication on the record.
Sources
Primary sources
- The court did not affirmatively find AI use; it characterized the defective cite as a probable typographical error while framing the broader admonishment in AI-hallucination terms. Whether counsel actually used AI is not on the record.