Indiana — AI Regulations

30 MAR 2026 · Court Case

Nicole Olbera, et al. v. Tiara Sykes

Fabricated: Case Law | Appellee's pro se brief included a citation to a seemingly non-existent case; the court noted the citation appeared to be fabricated and an editor's note removed links to invalid citations in the official opinion.

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

26 MAR 2026 · Court Case

William C. Maxwell v. Dakota Michael & Chelsey Smith

False Quotes: Case Law | Plaintiff presented 28 quotations attributed to real cases that do not appear in those cited opinions; Plaintiff admitted the quotes were incorrect, calling many 'paraphrases.' Court found this insufficient and included these false quotations in the Rule to Show Cause. || Fabricated: Case Law | Plaintiff cited nine cases that do not appear to exist (non‑existent case citations); Court treated these as fabricated citations and included them in the Rule to Show Cause.

Court: S.D. IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

19 MAR 2026 · Court Case

Jana James v. National Board of Osteopathic Examiners, Inc.

Fabricated: Case Law | Plaintiff cited 'Knakmuhs v. Minneapolis Pub. Sch., 990 F. Supp. 2d 1035 (D. Minn. 2014)'; court was unable to locate that case and found the citation incorrect/non-existent. || Misrepresented: Case Law | Plaintiff's citation corresponded to Cooper v. Tokyo Elec. Power Co., 990 F. Supp. 2d 1035 (S.D. Cal. 2013), not the case plaintiff named. || Misrepresented: Case Law | Plaintiff cited Powell v. Nat'l Bd. of Med. Exam'rs, 364 F.3d 79 (2d Cir. 2004) as supporting declaratory relief; court noted Powell did not address or grant declaratory relief and was mischaracterized.

Court: S.D. IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

10 MAR 2026 · Court Case

Michael Platt v. Volunteers of America Ohio & Indiana

Fabricated: Case Law | Court could not locate any decision corresponding to the cited Bodine case and found the citation to be nonexistent. || False Quotes: Case Law | Court could not find the quoted language that the plaintiff attributed to the Williams decision; quotation appears misrepresented.

Court: S.D. IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

10 MAR 2026 · Court Case

A.K. v. M.R.

Fabricated: Case Law | Appellant included reporter citation '994 N.E.2d 228' that did not correspond to the case name cited; court noted links pointed to unrelated Illinois decision rather than the Indiana case appellant referenced. || Fabricated: Case Law | Appellant cited '106 N.E.3d 400' which the court found did not match the case name in the brief and linked to an unrelated Illinois decision instead of the Indiana authority claimed. || Fabricated: Case Law | Appellant cited '212 N.E.3d 768' that the court observed linked to a Massachusetts decision rather than the Indiana case the brief purported to cite. || Misrepresented: Case Law | Appellant relied on Costello v. Zollman for a proposition about signage constituting harassment; court found Costello does not address signage and appellant misrepresented the authority.

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

12 FEB 2026 · Court Case

Virgil v. Experian Information Solutions, et al.

Fabricated: Case Law | Counsel cited Myers v. Passport Health, 2013 WL 5819270 (S.D. Ind. Oct. 29, 2013); court found this citation does not exist. || Fabricated: Case Law | Counsel cited Schuh v. American Express Bank, FSB, 2019 WL 132741 (N.D. Ind. Jan. 8, 2019); court found the citation does not exist. || Fabricated: Case Law | Same non-existent Myers citation also appeared in a separate filing (Docket 240); court found it does not exist. || Fabricated: Case Law | Counsel cited Merriman v. Equifax Info. Servs., LLC, 2021 WL 5937732 (D. Kan. Dec. 16, 2021); court found this citation does not exist. || Fabricated: Case Law | Counsel cited Treece v. Perrillo, No. 1:17-cv-00406, 2018 WL 3815004 (S.D. Ind. Aug. 10, 2018); court found the opinion does not exist. || Fabricated: Case Law | Counsel cited Armstrong v. Kroger Co., 621 F.2d 934 (8th Cir. 1980); court found this citation to be non-existent as cited. || Fabricated: Case Law | Counsel cited Hinkle v. CBE Grp., 827 F.3d 129 (5th Cir. 2016); court determined the cited opinion does not exist. || Fabricated: Case Law | Counsel cited Wigington v. Hill-Soberg Co., 396 F.2d 228 (5th Cir. 1968); court found the citation non-existent. || Fabricated: Case Law | Counsel cited Jenkins v. Equifax Info. Servs., LLC, 736 F. Supp. 2d 962 (E.D. Va. 2010); court found the citation does not exist. || Fabricated: Case Law | Counsel cited Rodriguez v. Pasquarella, 2019 WL 2411480 (N.D. Ill. June 7, 2019); court found this citation non-existent. || Misrepresented: Case Law | Counsel cited Harris v. Mexican Specialty Foods, Inc., 564 F.3d 1301 (11th Cir. 2009); court found the case exists but was misrepresented for the proposition cited. || Misrepresented: Case Law | Counsel cited Wright v. Experian Info. Sols., Inc., 805 F.3d 1232 (10th Cir. 2015); court found the citation was misrepresented and did not support the asserted point. || Misrepresented: Case Law | Counsel cited In re TJX Cos. Retail Sec. Breach Litig., 524 F. Supp. 2d 8

Court: S.D. IndianaParty: Lawyer

⚠ Professional sanction imposedFine: 1

Harms: Hallucination in legal filings

06 FEB 2026 · Court Case

Mutugu v. Kiaraho

Fabricated: Case Law | The court determined Father cited five legal authorities that do not exist in total (multiple likely AI-generated cases cited in the brief). || Misrepresented: Case Law | Father cited In re Estate of Brown, 587 N.E.2d 686, 689 (Ind. Ct. App. 1992) for the proposition that admitted exhibits "cannot later be deemed inadmissible," but the cited opinion at that pincite addressed jurisdiction/venue, not that proposition. || Fabricated: Case Law | Father cited a non-existent Indiana case "Thompson v. State" with reporter citation 811 N.E.2d 501, which the court found does not exist and whose reporter cite corresponds to an unrelated Massachusetts case. || Misrepresented: Exhibits & Submissions | Father cited the transcript at page 371 to support that the trial court 'dismissed' exhibits as 'unreliable' or 'unauthenticated,' but the cited transcript page does not exist.

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

30 JAN 2026 · Court Case

Wilcox v. Gingrinch

Fabricated: Case Law | Court found 'Reed v. State, 810 N.E.2d 1186 (Ind. 2004)' does not exist and the citation actually corresponds to an unrelated utility case. || Fabricated: Case Law | Court determined 'Lacy v. State, 419 N.E.2d 489 (Ind. 1981)' does not exist at that citation and the reporter citation points to an Illinois case. || Fabricated: Case Law | Court concluded 'Graves v. State, 773 N.E.2d 157 (Ind. 2002)' is nonexistent at that citation; reporter citation leads to an Illinois case. || Fabricated: Case Law | Court identified 'Thompson v. Best' citations as internally inconsistent and not corresponding to any Indiana appellate decision cited; reporter citations direct to unrelated out-of-state cases. || Misrepresented: Case Law | Court found Harrison v. Thomas was cited for a cost-plus contract rule the decision does not contain; the case was mischaracterized. || Misrepresented: Case Law | Court noted Kapoor v. Dybwad was cited as authority for jury-review standards though the case addresses a 12(B)(6) dismissal and was mischaracterized. || Misrepresented: Case Law | Court observed Weber v. Costin was cited for standards about setting aside a jury fraud verdict though Weber addresses summary judgment/wavier and was misapplied. || Misrepresented: Case Law | Court identified J.S. Sweet Co. citation used to support a cost-breakdown principle though the actual case concerns mechanics' liens and prejudgment interest, a mischaracterization.

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

15 JAN 2026 · Court Case

North Atlantic Operating Company, Inc., et al. v. Indiana Import, LLC, et al.

Fabricated: Case Law | Defense counsel cited a non-existent case to argue duplicative litigation; the Court found the case did not exist and struck/ordered correction. || Fabricated: Case Law | Defense counsel cited a second non-existent case in support of the same argument; the Court found it did not exist and required docket sheets to be filed, after which defendants identified different actual cases.

Court: S.D. IndianaParty: Lawyer

Harms: Hallucination in legal filings

24 NOV 2025 · Court Case

M.H. v. C.S.

Fabricated: Case Law | Appellant's brief cited a case that the court determined does not exist; the court noted non-existent and irrelevant case law cannot support her contentions.

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

18 NOV 2025 · Court Case

Kamia Nellum v. Credit Acceptance Corporation

Misrepresented: Case Law | Plaintiff cited 'Messina v. N. Cent. Distrib., Inc., 821 N.E.2d 236 (Ind. Ct. App. 2005)'; court found the citation/method of attribution incorrect and that the proper decision appears as Messina v. N. Cent. Distrib., Inc., 821 F.3d 1047, 1050 (8th Cir. 2016). Court noted the case was not addressed by the Indiana Court of Appeals as plaintiff claimed. || Fabricated: Case Law | Plaintiff cited 'Miller v. Credit Acceptance Corp., 2019 WL 2450930 (S.D. Ind. 2019)'; court found that citation does not exist (2019 WL 2450930 corresponds to an unrelated D. Utah decision) and that the Miller v. Credit Acceptance decisions found on Westlaw are from 2012 (N.D. Ohio).

Court: S.D. IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

04 NOV 2025 · Court Case

Xavier Jamal Smith v. Santander Consumer USA Inc.

Fabricated: Case Law | Plaintiff cited 'Citizens Nat’l Bank of Paris v. Midwest Agri-Dev. Corp., 887 F.2d 1128, 1134 (7th Cir. 1989)'; the Court found the reporter citation corresponds to an unrelated First Circuit opinion, no Seventh Circuit case by that name from 1989 appears to exist, and it could not locate any case containing the quoted language.

Court: N.D. IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

03 NOV 2025 · Court Case

I.H. v. O.K.

Misrepresented: Case Law | Appellant's brief contained multiple authorities that did not support the propositions for which they were cited; the court attributed this to AI use and warned of risks.

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

30 OCT 2025 · Court Case

In re: the Marriage of Melinda Johnson v. Sabastian Johnson

Fabricated: Case Law | Mother's briefs included multiple cited cases that the court found do not exist; the court attributed the errors to AI-assisted drafting. || Misrepresented: Legal Norm | Mother relied on Indiana Code §31-17-2-16 for authority to appoint a parenting coordinator, but the court found the statute does not govern that point (misapplied legal norm).

Court: CA IndianaParty: Pro Se LitigantTool: ChatGPT

Harms: Hallucination in legal filings

24 SEP 2025 · Court Case

T.M. v. M.M.

False Quotes: Case Law | Appellant cited a quotation supposedly supporting judicial estoppel that the court found is not present in the cited case. || Fabricated: Case Law | Appellant cited a non-existent case 'Reynolds v. State' as authority; the court found the case does not exist. || Fabricated: Case Law | Appellant cited 'Robison v. Orthopedic & Sports Medicine Center' with a reporter citation that the court states does not exist. || Fabricated: Case Law | Appellant relied on purported authority 'Bill v. Bill' which the court found to be non-existent. || Fabricated: Case Law | Appellant cited 'Wann v. Wann' as controlling authority; the court states the cited case does not exist. || Fabricated: Case Law | Appellant cited 'A.H.L. v. C.Y.L.' which the court determined is not a real reported decision. || Misrepresented: Legal Norm | Appellant mischaracterized the content/purpose of a statute, citing Ind. Code § 33-25-1-2 as establishing appellate jurisdiction when it establishes court districts. || Misrepresented: Exhibits & Submissions | Appellant cited transcript page references that the court found do not support the assertions (various transcript page citations mis-cited).

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

19 SEP 2025 · Court Case

Cingel v. Ferreri

Fabricated: Case Law | Appellant cited 'In re Marriage of Dunston, 989 N.E.2d 830, 835 (Ind. Ct. App. 2013)' to support abuse-of-discretion review; court found no such case and reporter citation pointed to unrelated decisions. || Fabricated: Case Law | Appellant cited 'McCain v. State, 924 N.E.2d 56, 60 (Ind. 2009)' for a custody proposition; court determined that citation does not exist as given. || Fabricated: Legal Norm | Appellant relied on 'Indiana Code § 31-17-2.5-1' as the custody statute; court found no such statutory section (correct statute is 31-17-2-8). || Fabricated: Legal Norm | Appellant cited and purported to quote 'Indiana Code § 31-17-2.2-23(a)'; court noted no such statutory provision exists. || Fabricated: Legal Norm | Appellant cited 'Trial Rule 60.1' and 'Trial Rule 60.1(A)' to support procedural requirements for custody modifications; court found no such trial rule. || Misrepresented: Legal Norm | Appellant cited 'Trial Rule 59(G)' as requiring written orders or hearings on motions to correct error; court explained Rule 59(G) concerns cross errors and was misapplied. || Misrepresented: Case Law | Appellant cited 'Bowman v. Bowman, 682 N.E.2d 23, 28 (Ind. Ct. App. 1997)' for multiple propositions; court observed the correct Bowman citation is different (686 N.E.2d 921) and the cited reporter/pincite pointed to unrelated authority, and the asserted propositions were inaccurate. || Misrepresented: Legal Norm | Appellant relied on subsections 'Indiana Code § 31-17-2.2-1(a)' and '(b)' for notice timing and burden of proof on relocation; court found those subsections were mischaracterized (they address filing location and exceptions) and pointed to the correct provisions (31-17-2.2-3 and 31-17-2.2-5).

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

17 SEP 2025 · Court Case

Tsupko v. Kinetic Advantage, LLC

Fabricated: Case Law | Plaintiff's filings contained multiple other citations to cases the Court could not locate and deemed non-existent. || Misrepresented: Other | Plaintiff's brief included AI-style placeholder language and bracketed instructions indicating use of an AI-generated draft, undermining the brief's substantive citations/arguments. || Fabricated: Case Law | Plaintiff cited a nonexistent Eastern District of Kentucky decision to support a legal principle; the Court found the case does not exist and that similar-cited cases from Florida did not support Plaintiff's asserted principle.

Court: S.D. IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

02 SEP 2025 · Court Case

Davis v. Juvenile Detention Center

Fabricated: Case Law | Brief quoted a non-existent decision cited as Perry v. City of Indianapolis, No. 1:18-cv-02173-JRS-DLP, 2019 WL 2088435, at 2; court found the citation to be an amalgam of multiple cases and the 2019 WL cite actually corresponds to Rehal v. Weinstein (unrelated). || Fabricated: Case Law | Brief cited Berg v. Symons, 393 F. Supp. 2d 1215 (D. Minn. 2005) for a proposition about tax returns; court determined that citation does not exist and the similarly titled real opinion (393 F. Supp. 2d 525) does not support the quoted proposition.

Court: S.D. IndianaParty: Lawyer

⚠ Professional sanction imposedFine: 7500 USD

Harms: Hallucination in legal filings

18 AUG 2025 · Court Case

Williams v. Kirch

Fabricated: Case Law | Appellant cited a nonexistent U.S. Supreme Court case; the court found it fictitious and admonished appellant. || Fabricated: Case Law | Appellant cited a nonexistent Indiana case; the court suggested it may be AI-generated and admonished appellant. || Fabricated: Case Law | Appellant cited a nonexistent Illinois appellate case; the court noted it was fictitious and cautioned against unverified AI citations.

Court: CA IndianaParty: Pro Se Litigant

Harms: Hallucination in legal filings

13 MAR 2024 · Law / Act

Indiana Senate Bill 2024-150

Establishes an Artificial Intelligence Task Force to study AI use and impact, requiring state agencies to inventory all artificial intelligence technologies in use, being developed or considered by the agency.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+17iga.in.gov ↗

12 MAR 2024 · Law / Act

Indiana 2024 House Bill 1133

Adds Chapter 8 to Indiana Code, regulating election campaign communications with digitally altered media. Requires disclaimers for such media, specifying format and timing. Allows candidates depicted in undisclosed fabricated media to sue for damages, injunctive relief, and legal costs.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2iga.in.gov ↗

12 MAR 2024 · Law / Act

Indiana House Bill 1047

Defines "computer generated image" as those created or modified using AI or software. Criminalizes distributing non-consensual intimate images, including AI-generated ones, with enhanced penalties for repeat offenders. Establishes new offenses for voyeurism involving AI or digital tools.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2iga.in.gov ↗

04 DEC 2023 · Other

Indianapolis City Council Proposal No.362, 2023

Establishes a study commission to review and recommend policies for the City's AI use, emphasizing trustworthy, transparent AI applications. Requires public input, expert engagement, and collaboration with local departments. Mandates a final report by July 2024 for policy guidance.

✓ ✓ OfficialStrategies: Convening ·Strategies: Governance development ·Strategies: Government study or report ·+2media.graphassets.com ↗