Colorado — AI Regulations

25 MAR 2026 · Court Case

Coomer v. Lindell/MyPillow, Inc. (2)

Misrepresented: Case Law | Defense counsel misattributed Capital Solutions (695 F. Supp. 2d 1149) as a Tenth Circuit decision; Court explained the citation is to the Federal Supplement (a district-court reporter) and the case was not appealed to the Tenth Circuit. || Fabricated: Case Law | Court noted defense counsel previously admitted that earlier citation errors were produced by generative AI and that the Court had earlier sanctioned counsel for similar AI-produced citation mistakes.

Court: D. ColoradoParty: LawyerTool: Unidentified

Harms: Hallucination in legal filings

10 FEB 2026 · Court Case

Labonte v. Bokf, et al.

Misrepresented: Case Law | Plaintiff cited Sterling v. Velsicol Chem. Corp. as '855 P.2d 1188' and as a Colorado court decision; the Court noted the correct reporter and that Sterling is 855 F.2d 1188 (Sixth Circuit), not a Colorado decision. || False Quotes: Case Law | Plaintiff attributed a quotation warning against dismissals that would 'strip a court of its ability to afford complete relief' to Citizen Center v. Gessler; the Court found that language does not appear in Gessler. || Misrepresented: Case Law | Plaintiff cited Harris v. Sand Canyon Corp. using an apparently fabricated or incorrect Westlaw-style citation that does not match the case or proposition relied upon.

Court: D. ColoradoParty: Pro Se Litigant

Harms: Hallucination in legal filings

06 FEB 2026 · Court Case

Nonnie Berg v. United Airlines, Inc. (3)

Fabricated: Case Law | Plaintiff's Motion for Extension cited a nonexistent Ninth Circuit case titled 'Kelley v. United States' with a fabricated reporter citation. || Fabricated: Case Law | Plaintiff's Motion for Extension cited a nonexistent 10th Circuit opinion 'United States v. Miller' with a fabricated Westlaw cite and date. || Misrepresented: Case Law | Plaintiff cited 'Moore v. City of Del City' but misstated the reporter information and attributed an 'excusable neglect' holding that the Moore opinion did not address.

Court: D. ColoradoParty: Pro Se LitigantTool: Unidentified

Harms: Hallucination in legal filings

28 JAN 2026 · Court Case

Nonnie Berg v. United Airlines, Inc. (2)

Fabricated: Case Law | Court noted plaintiff's Motion to Compel contained citations to a seemingly nonexistent case referred to as "Hernandez" (pages 6 and 8 of the motion). || Fabricated: Case Law | Court noted plaintiff's Motion for Relief from Order cited a seemingly nonexistent case "United States v. Miller" (page 4 of the motion).

Court: D. ColoradoParty: Pro Se Litigant

Harms: Hallucination in legal filings

16 JAN 2026 · Court Case

Alzado-Lotz v. Bock

Fabricated: Case Law | Defendant cited a non-existent Tenth Circuit decision 'Hinzo v. State of N.M., 79 F.4th 1164, 1175 (10th Cir. 2023)'; the court determined that citation is non-existent and does not support the argument. || False Quotes: Case Law | Defendant quoted language purportedly from Nikwei v. Ross Sch. of Aviation, Inc. (822 F.2d 939) that the court found does not appear in Nikwei; the court noted the wording likely originates from Aetna Business Credit, Inc., 635 F.2d 434, 435 (5th Cir. 1981).

Court: D. ColoradoParty: Lawyer

Harms: Hallucination in legal filings

01 JAN 2026 · Law / Act

Colorado SB 205

Colorado legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Generative AI ·Data Privacy & Protectiongoogle.com ↗

28 NOV 2025 · Court Case

Hanson v. Nest Home Lending, LLC et al.

Misrepresented: Case Law | Motion cites People ex rel. State Bd. of Equalization v. Hively, 336 P.2d 721 (1959) for a proposition about declaratory relief and ownership clarity that the case does not establish. || Fabricated: Case Law | Complaint cites Reagan v. Investors Mtg. Co., 977 P.2d 299 (Colo. App. 1999); court found no such case (Westlaw returns unrelated State v. Maier). || Fabricated: Case Law | Complaint cites In re Medina, 2012 WL 1368983 (Bankr. D. Colo.); court found no results for that citation. || False Quotes: Case Law | Motion to Disqualify quotes language attributed to Weeks v. Indep. Sch. Dist. No. I-89, but the quoted language does not appear in that opinion. || Misrepresented: Case Law | Motion to Remand attributes the parenthetical proposition about remandability of quiet title/foreclosure disputes to Easton v. Crossland Mortgage Corp., but Easton did not address that issue. || Misrepresented: Case Law | Motion for Declaratory Judgment cites Koon v. Barmettler, 301 P.2d 713 (1956) for the proposition that declaratory judgment is appropriate to resolve quiet title, but Koon did not address that subject. || Misrepresented: Legal Norm | Response cites Colo. Rev. Stat. § 38-41-201 to support a joinder rule for quiet title actions; the cited statute actually pertains to homestead exemptions and is unrelated. || Fabricated: Case Law | Response cites First Nat’l Bank of Greeley v. Conway, 34 Colo. 372, 83 P. 361 (1905); court found that citation does not exist. || Fabricated: Case Law | Response cites Hendricks v. Bank of America, N.A., 408 S.W.3d 688 (Tex. App. 2013); court found no such Texas Court of Appeals decision and noted the Ninth Circuit Hendricks decision cited does not support Plaintiffs' proposition. || Fabricated: Case Law | Response cites Goodman v. Heritage Savings & Loan Ass’n, 390 P.2d 712 (Colo. 1964); court determined this case does not exist as cited. || Misrepresented: Case Law | Plaintiffs cite In re Veal, 450 B.R. 897 (9th Ci

Court: D. ColoradoParty: Pro Se LitigantTool: Unidentified

Harms: Hallucination in legal filings

19 NOV 2025 · Court Case

Y.S. v. John Doe et al.

Fabricated: Case Law | Plaintiff cited 'In re Subpoena to Coinbase, Inc., No. 17-MC-80244, 2018 WL 1898913, at *4 (N.D. Cal. Apr. 19, 2018)' to support delayed notice; the court found this cited opinion does not exist. || Fabricated: Case Law | Plaintiff cited 'In re Subpoena to Coinbase, Inc., 2023 WL 177977, at 2 (N.D. Cal. Jan. 12, 2023)'; the court could not locate this citation on Westlaw and noted only an unrelated CourtListener docket for 'In re: Coinbase, Inc.' (23-1779). || Misrepresented: Case Law | Plaintiff relied on Strike 3 Holdings, LLC v. Doe, 964 F.3d 1203 (D.C. Cir. 2020) as approving 'delayed notice' to prevent targets from knowing of subpoenas; the court observed Strike 3 contains no discussion of preventing a subpoena target from learning of the subpoena and therefore does not support plaintiff's proposition. || Misrepresented: Case Law | Plaintiff cited Hard Drive Productions, Inc., 809 F. Supp. 2d 1150 (N.D. Cal. 2011) as supporting nondisclosure/delayed notice; the court found Hard Drive authorized notice to subscribers (the opposite of delayed notice) and does not support plaintiff's position. || Misrepresented: Case Law | Plaintiff cited Arista Records LLC v. Does 1-27, 584 F. Supp. 2d 240, 254 (D.D.C. 2008) to argue courts approved email service for early discovery; the court noted Arista is a decision from the District of Maine (584 F. Supp. 2d 240 (D. Me. 2008)) and did not address Rule 45 email service, so the citation was both jurisdictionally and substantively mischaracterized.

Court: D. ColoradoParty: Pro Se Litigant

Harms: Hallucination in legal filings

17 NOV 2025 · Court Case

Cotto v. United States

Fabricated: Case Law | Plaintiff cited 'Ayala v. Holmes, 29 F.4th 1015' for summary-judgment guidance; the Court found no such decision exists, noted the 29 F.4th pin cite aligns with Barrera Arreguin v. Garland, 29 F.4th 1010, and that an unrelated Ayala v. Holmes, 29 F. App'x 548 (10th Cir. 2002) exists.

Court: D. ColoradoParty: Pro Se Litigant

Harms: Hallucination in legal filings

14 NOV 2025 · Court Case

Matthew Lewis v. Eagle County Government

Outdated Advice: Repealed Law | Court noted the original Complaint relied on a pre-2011 regulatory '20% rule' that was amended in 2011 and therefore was a superseded/regulatory error. || Fabricated: Case Law | Court found this citation does not correspond to any existing opinion; counsel later conceded the citation, as presented, was fictitious. || Fabricated: Case Law | Court found this citation, as presented, does not exist and was included in the First Amended Complaint. || Fabricated: Case Law | Court determined this cited decision, in the form presented in the pleading, does not exist. || Fabricated: Case Law | Court concluded this citation as presented does not correspond to an existing case; included in First Amended Complaint. || Misrepresented: Case Law | Court observed counsel cited Huff for a proposition it does not support; Huff holds §203(y) does not require actual fire suppression, cutting against Plaintiff's asserted proposition. || Misrepresented: Case Law | Court determined this case is inapposite to the §203(y) proposition for which it was cited (does not involve §203(y)). || Misrepresented: Case Law | Court found these cited Ninth Circuit decisions do not support the proposition they were cited for (they did not arise on motions to dismiss as claimed). || Misrepresented: Case Law | Court found counsel misused this Ninth Circuit authority; it does not support the asserted proposition at the pleading stage.

Court: D. ColoradoParty: Lawyer

Fine: 28000 USD

Harms: Hallucination in legal filings

30 OCT 2025 · Court Case

Nonnie Berg v. United Airlines, Inc. (1)

Fabricated: Case Law | Plaintiff cited Salt Institute v. Leavitt, 440 F. Supp. 2d 240, 243 (D.D.C. 2006); court could not identify this citation in Westlaw and treated it as an AI-generated, non-existent opinion. || Fabricated: Case Law | Plaintiff cited In re Parke-Davis Sec. Litig., 177 F.R.D. 246, 250 N.6 (E.D. Mich. 1997); court could not verify the citation and treated it as fabricated AI output. || Fabricated: Case Law | Plaintiff cited Koch v. Koch Indus., Inc., 203 F.R.D. 479, 487 (D. Kan. 2011); court could not locate this citation in its database and treated it as a non-existent case likely generated by AI. || Fabricated: Case Law | Plaintiff cited Hodgson v. Mason & Hangar-Silas Mason Co., 545 F. Supp. 1189, 1192 (D. Kan. 1982); court could not identify this citation and considered it an AI-fabricated opinion. || Fabricated: Case Law | Plaintiff cited Smith v. Life Investors Ins. Co. of Am., 245 F.R.D. 580, 584 (D. Kan. 2007); court was unable to verify the citation and treated it as a fabricated case citation from AI-generated content. || Fabricated: Exhibits & Submissions | Plaintiff submitted a medical report (ECF No. 108-3) dated April 27, 2020 that the court found to contain indicia of AI generation (generic language, markdown artifacts, incomplete license info) and could not verify the physician.

Court: D. ColoradoParty: Pro Se Litigant

Harms: Hallucination in legal filings

07 JUL 2025 · Court Case

Coomer v. Lindell/MyPillow, Inc. (1)

False Quotes: Case Law | Opposition falsely quotes Pure as stating 'reputation and character are inextricably intertwined'; court found the quote does not appear. || Misrepresented: Case Law | Opposition cites Reaves to claim evidence can implicate multiple evidentiary rules; court found Reaves discusses only Rule 608(b) and does not support that proposition. || Fabricated: Case Law | Opposition cites a non-existent Tenth Circuit case styled Perkins v. Fed. Fruit & Produce Co. || Fabricated: Case Law | Opposition cites a non-existent District of Colorado case styled Estate of Martinelli v. City & County of Denver. || Fabricated: Case Law | Opposition cites a non-existent Tenth Circuit case styled United States v. Hoffman/Hoffmann. || Misrepresented: Case Law | Opposition asserts Perrin supports routine admission of truthfulness evidence in defamation actions; court found Perrin is not a defamation case and does not state that rule. || Misrepresented: Case Law | Opposition lists United States v. Hassan as Tenth Circuit authority; court notes it is a Fourth Circuit case and not binding. || False Quotes: Case Law | In related Pelishek filing by same counsel, Swetlik is quoted for 'falsified government records affecting taxpayer funds,' which the court notes does not appear in the opinion. || Fabricated: Case Law | In related Pelishek filing, citation to Bohannan v. Doe with Ninth Circuit reporter page is non-existent per the court’s review. || Misrepresented: Case Law | In related Pelishek filing, Gomez v. City of Chicago is cited to a WL citation that actually corresponds to a D.N.J. case (McKenna v. Verint). || Misrepresented: Case Law | Opposition misattributes Ginter as a District of Colorado decision; court notes it is from the Eastern District of Kentucky.

Court: D. ColoradoParty: LawyerTool: Co-Pilot, Westlaw’s AI, Gemini, Grok, Claude, ChatGPT, Perplexity

Fine: 6000 USD

Harms: Hallucination in legal filings

06 MAY 2025 · Court Case

Harris v. Take-Two Interactive Software

False Quotes: Case Law | Plaintiff attributed quotations to cited cases that, per Take-Two and the Court, do not contain those quotes; plaintiff later withdrew or clarified he was not quoting directly, and replacement citations did not support his argument. || Fabricated: Case Law | Plaintiff cited cases that, per Take-Two, could not be located; the Court noted the withdrawal and cautioned that use of fictitious cases may warrant Rule 11 sanctions.

Court: D. ColoradoParty: Pro Se Litigant

Harms: Hallucination in legal filings

06 JUN 2024 · Law / Act

Colorado House Bill 24-1468

Creates the Artificial Intelligence Impact Task Force to develop policy recommendations against AI system risks and algorithmic discrimination affecting consumers and workers. Requires diverse membership and adherence to transparency standards. Mandates a report by February 2025 to the legislature and governor; task force sunsets in 2027.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+20leg.colorado.gov ↗

24 MAY 2024 · Law / Act

Colorado House Bill 1147

Prohibits distributing AI-generated deepfakes about candidates close to elections without disclosures. Requires clear notifications in such communications. Allows candidates to seek legal remedies for unauthorized deepfakes. Effective July 1, 2024, with enforcement by the Secretary of State.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2leg.colorado.gov ↗

17 MAY 2024 · Law / Act

Colorado SB 24-205: Consumer Protections for Interactions with Artificial Intelligence Systems

Colorado became the first state to enact comprehensive AI bias legislation covering high-risk AI systems with this law, which requires developers and deployers of high-risk AI systems to use reasonable care to protect consumers from known or reasonably foreseeable risks of algorithmic discrimination. Covered entities must perform impact assessments, disclose AI use to consumers, provide an appeal process for adverse decisions, and file annual reports with the Attorney General. The law takes effect on February 1, 2026 and covers AI used in consequential decisions involving employment, credit, housing, healthcare, and other sensitive areas.

✓ ✓ OfficialData Privacy & Protection ·Labor & Workforce ·Finance ·+27leg.colorado.gov ↗

01 SEP 2021 · Law / Act

Colorado SB 21-169: Restrictions on Insurers' Use of External Consumer Data

Colorado enacted Senate Bill 21-169, prohibiting insurance companies from using external consumer data and information sources, as well as algorithms and predictive models using such data, in unfairly discriminatory ways in insurance underwriting and rating. The law directed the Colorado Division of Insurance to adopt rules requiring insurers to demonstrate that their use of external data and algorithms does not result in unfair discrimination based on protected characteristics. It was one of the first state laws to directly address algorithmic fairness in the insurance industry.

✓ ✓ OfficialFinance ·Data Privacy & Protectionleg.colorado.gov ↗

06 JUL 2021 · Other

Colorado SB21-169

Prohibits insurers from unfairly discriminating using algorithms and predictive models based on personal attributes. Requires the insurance commissioner to establish rules, conduct investigations, and engage stakeholders. Obligates insurers to demonstrate non-discriminatory use of consumer data.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2leg.colorado.gov ↗