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Tippecanoe County Assessor v. Goergen

Indiana Tax Court · Ind. Tax Ct. · Indiana bar guidance

Pro-se party

Conduct

Pro se elected county assessor cited a fictitious case in a brief defending his right to represent the assessor's office without counsel.

Consequence

Appeal dismissed on representation grounds; petitioner cautioned about AI-hallucinated cites in a footnote. No monetary sanction.

Lesson

Ind. Tax Ct. will note AI hallucinations even when the case is dismissed on procedural grounds; the AI footnote travels with the docket.

Other

Verified May 7, 2026

Citation
Tippecanoe Cnty. Assessor v. Goergen, No. 25T-TA-00007 (Ind. Tax Ct. Oct. 17, 2025) (McAdam, J.)
Decided
October 17, 2025

Summary

Indiana Tax Court decision authored by Judge Justin McAdam dismissing the Tippecanoe County Assessor's pro se appeal on the ground that the county assessor must be represented by counsel and cannot appear pro se. Petitioner Eric Grossman, the elected assessor, filed a brief arguing he could represent the assessor's office without counsel. In a footnote, the court noted that Grossman's brief cited a fictitious case and observed that the citation "appears likely to be the result of a hallucination by generative artificial intelligence." Citing Williams v. Kirch as the leading Indiana appellate authority, the court cautioned attorneys and pro se litigants alike against using AI to conduct legal research without independent verification. This is one of nine related Tippecanoe County Assessor opinions issued the same day arising from the same Tax Court referral.

AI tool:
Generative artificial intelligence inferred from a fictitious case citation; specific tool not identified
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

Appeal dismissed because non-attorney elected assessor cannot represent the assessor's office. Petitioner cautioned in footnote for likely AI-fabricated case citation. No monetary sanction.

Why does Tippecanoe County Assessor v. Goergen matter for law firms using AI?

Tippecanoe County Assessor v. Goergen is one of nine related opinions issued by the Indiana Tax Court on October 17, 2025, addressing the same threshold question: whether an elected county assessor can appear pro se in the Tax Court on behalf of the assessor’s office. Judge McAdam answered no across all nine cases. Goergen is the lead opinion that contains the AI-citation footnote, noting that one of the cases Grossman cited in his representation-rights brief does not exist and appears to be an AI hallucination. The footnote tracks the same Williams v. Kirch admonishment language Judge McAdam used two months later in Donovan, suggesting an emerging Tax Court practice of flagging AI-fabricated cites in footnotes even when the merits decision rests on independent procedural grounds.

For a firm advising clients on Indiana property-tax matters, the operational implication is that elected officials and pro se litigants appearing in the Tax Court face two parallel risks: the procedural risk that a non-attorney cannot represent the office and the citation risk that AI-generated research will produce fabricated cases. Goergen shows that the Tax Court will document both in the same opinion. A firm that provides advisory help to elected county assessors or similar pro se public officials should ensure that any research shared with the client is verified against primary sources before the client incorporates it into a filing.

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 clients that an Indiana Tax Court footnote about AI-hallucinated citations becomes part of the public record for the case and the docket; even a procedural dismissal does not insulate an elected official from the AI-citation finding.
  • Document a verification workflow for any pro se filings made by elected officials whom firms advise on a non-representation basis; the Goergen pattern shows that an elected assessor lacking counsel is exactly the population that consumer AI tools target.
  • Consider whether the firm's client-advisory practice should include an explicit disclaimer that AI-generated research provided as part of an advisory engagement is not for filing without independent verification.

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Sanctions cases

From the blog

Sources

Primary sources

Unverified claims:
  • The court inferred AI use from the presence of a fictitious case citation; Grossman did not concede AI use on the record. The footnote frames the inference probabilistically (`appears likely to be the result of a hallucination`).
  • The specific fictitious case identified by the court is not extracted into this entry; consult the opinion footnote before citing the precise text.