This Case Builds On Cases Applicable To Attorneys, But Extends The Prohibition To In Pro Per Litigants.
In Sheerer v. Panas, Case No. A171804 (1st Dist., Div. 4 Mar. 19, 2026) (partially published; AI discussion published), the appellate court made clear that the recent California case authority which prohibits AI hallucinations equally applies to in pro per litigants. No sanctions were issued, but here is what the appellate court had to say as a warning to represented and in pro per litigants: “Thus, our warning to litigants is not merely an admonition to double-check citations and otherwise fastidiously comply with the Rules of Court; it is to be at all times truthful and to be responsible in crafting any written arguments presented in this Court. (See People v. Alvarez (2025) 114 Cal.App.5th 1115, 1119 [“ ‘Honesty in dealing with the courts is of paramount importance, and misleading a judge is, regardless of motives, a serious offense’ ”].) We further caution that our redress for false and missing citations is not limited to disregarding a brief. “We may impose monetary sanctions pursuant to our own motion for unreasonable violations of the rules governing appeals.” (Keitel v. Heubel, supra, 103 Cal.App.4th at p. 340; Noland, supra, 114 Cal.App.5th at p. 442; Rule 8.276(a)(4).)”