Idaho · state supreme court · 2026

Eric Posey v. Summer Bushnell

Idaho Supreme Court, 22 September 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Idaho

  1. Court. Idaho Supreme CourtCOURT
  2. Level. state supreme courtLEVEL
  3. Date. 22 September 2026DATED
  4. Docket. No. 52072DOCKET
  5. Documents. one document, 6 passages quoted belowON FILE
  6. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 22 September 2026 · source · PDF · 17 pages

Our r eview of Bushnell’s briefing reveals that most of the issues raised on appeal are unsupported by cogent argument or authority. Although Bushnell cites numerous authorities in support of her arguments , many do not support her arguments because they are fabricated or inaccurate quotations. In fact, of the twenty -two purported quotations Bushnell attributes to caselaw, statutes, court rules, pattern jury instructions, and the Idaho Constitution, only six are accurate quotations with some minor spelling er rors.

Id. Bushnell also cites two nonexistent cases : McAdam v. McAdam and Dairyland Insurance Co. v.

8 they purport to rely. Indeed, fabricated authority is more troubling than the absence of authority because it introduces false information into the judicial process . Appellate advocacy depends on the accurate and candid presentation of legal authority .

Appellate advocacy depends on the accurate and candid presentation of legal authority . Fabricated authority hinders this Court’s consideration of the issues presented, requires this Court to expend resources i dentifying and correcting false representations, and undermines the integrity of the appellate process. Many of Bushnell’s arguments on appeal depend on fabricated or misrepresented authority.

Indeed, the nature and extent of the inaccuracies and misrepresentations in Bushnell’s briefing suggest that she may have relied on generative artificial intelligence (“GenAI” or “AI”) in drafting her briefs . It is well- established that such tools often “hallucinate” and generate false legal citations. See Kruse v.

App. 2024) (noting that GenAI often hallucinates or provides false authority). Based on the extent and nature of the misrepresentations in Bushnell’s briefing, we conclude that these cited authorities were not subjected to meaningful verification by Bushnell before filing.

What the text mentions

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More from Idaho Supreme Court, from Idaho, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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