Indiana · state appellate court · 2026

Melissa Wilcox v. Matthew A. Gingrich

Indiana Court of Appeals, 30 January 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Ind. Ct. App.

  1. Court. Indiana Court of AppealsCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 30 January 2026DATED
  4. Docket. No. 25A-PL-01157DOCKET
  5. Judge. May, Altice, FoleyJUDGE
  6. Documents. one document, 8 passages quoted belowON FILE
  7. 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, 30 January 2026 · source · PDF · 19 pages

[15] The Wilcoxes’ brief contains significant deficiencies. While their Statement of Facts includes some record citations, their reliance on nonexistent legal Court of Appeals of Indiana | Opinion 25A-PL-1157 | January 30, 2026 Page 7 of 19 a uthorities as well as their incorrect citations to and descriptions of other legal authorities significantly impeded our review. 1.

1. Fabricated and Mischaracterized Legal Authorities [16] The Wilcoxes cite numerous legal authorities in their Brief. Of the cases cited, a substantial number either do not exist or have nothing to do with the propositions they purport to support.

However, the Wilcoxes cite additional cases throughout the body of their brief that do not appear in the Table of Authorities at all, in violation of A ppellate Rule 46(A)(2). In total, counting both the cases listed in the Table of A uthorities and the additional cases cited only in the brief’s text, a majority of th e cases are completely fabricated – they do not exist at the citations provided. Of the cases that do exist, many are grossly mischaracterized or cited for propositions they do not support.

1.1. Completely Fabricated Cases [17] The Wilcoxes cite “Reed v. State, 810 N.E.2d 1186 (Ind.

Best” was decided by the Court of Appeals of Indiana in 2013 or 2019. [21] Additional fabricated cases include: “Coomer v. Bd. of Transp. of Knox County, 247 N.E.2d 93 (Ind.

Court of Appeals of Indiana | Opinion 25A-PL-1157 | January 30, 2026 Page 14 of 19 2. Further Violation of Appellate Rule 46 [29] In addition to citing fabricated and mischaracterized cases, the Wilcoxes violated Appellate Rule 46(A)(2) by failing to include numerous cases in their Table of Authorities that they cite in the body of their brief. Appellate Rule 46(A)(2) requires the Table of Authorities to “list each case, statute, rule, and other authority cited in the brief, with references to each page on which it is cited.

Appellate Rule 46(A)(2) requires the Table of Authorities to “list each case, statute, rule, and other authority cited in the brief, with references to each page on which it is cited. The authorities shall be listed alphabetically or numerically, as applicable.” The following cases (real and fabricated) are cited in the brief but do not appear in the Table of Authorities: Miller v. Ind.

Presumed Use of Generative Artificial Intelligence [30] The pattern and nature of the citation errors in the Wilcoxes’ brief strongly suggest the use of generative artificial intelligence without adequate verification. Fourteen completely fabricated cases, systematic mischaracterizations of real cases, and citations leading to Illinois, New York, Ohio, and Massachusetts cases when Indiana authority is claimed point to reliance on AI-generated research that was never independently confirmed. This case illustrates a troubling trend.

What the text mentions

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More from Indiana Court of Appeals, from Indiana, 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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