Colorado

Court - Judge Name

Effective Date

 Applicable To Categories

Summary

D. Colo. – Judge Nina Y. Wang  11/14/2025 Generative AI    Generative AI Usage In Lewis v. Eagle County Government, No. 1:25-cv-02269-NYW-NRN (D. Colo. Nov. 14, 2025), Dkt. No. 32, the court ruled on an order to show cause, denied the plaintiff’s motion to file an amended complaint, and addressed the defendant’s opposition to the plaintiff’s second motion for leave to file an amended complaint, which raised several concerns with the plaintiff’s inaccurate citations and citations to nonexistent cases in his first amended complaint. Dkt No. 20 at 6-10. Though the plaintiff filed a notice of voluntary dismissal without prejudice, the court issued an order to show cause as to why the action should not be dismissed with prejudice and as to why the plaintiff and his attorney should not be sanctioned for GenAI misuse. Dkt. No. 24. The court’s decision on the order to show cause discussed the several errors that “bear the hallmarks of generative artificial intelligence,” including incorrect party names, court reports, courts, years, and case assertions and found “no doubt that [plaintiff’s counsel] did not engage in an inquiry reasonable under the circumstances.” Dkt. No. 32 at 12. During the hearing on the order to show cause, the plaintiff’s counsel attributed these mistakes to her general disorganization and law firm office closing, but the court found these to be insufficient as she has made various errors that have “plagued Plaintiff’s pleadings since the inception of this case.” Id. at 12-13, 15. Judge Wang ruled that the plaintiff’s counsel violated Rule 11 of the Federal Rules of Civil Procedure and imposed a $3,000 fine jointly and severally against the plaintiff’s counsel and her law firm. Id. at 16. Additionally, as the plaintiff’s counsel’s misrepresentations have imposed “unwarranted costs” on a public entity, the court found “reasonable attorney’s fees” under 28 U.S.C. § 1927 to be appropriate and recommended that the parties meet and confer as to the requested amount pursuant to Local Rule 54.3. Id. at 20. The award of attorney’s fees, according to Judge Wang, would be a sufficient remediation that would render dismissal with prejudice inappropriate. Id. at 21.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
 D. Colo. – Judge Nina Y. Wang 10/30/2025 Generative AI Generative AI Usage In Berg v. United Airlines, Inc., 2025 U.S. Dist. LEXIS 214364 (D. Colo. Oct. 30, 2025), the pro se plaintiff’s “notice of appeal” in objection to the magistrate judge’s report and recommendation contained inaccurate citations and violated both the court’s Civil Practice Standards and Rule 11 through the “continued misuse of [GenAI].” The district court adopted the magistrate judge’s order and recommendation which specifically observed that “significant chunks” of the plaintiff’s responses appear to have been “copied and pasted from an artificial-intelligence program.” See Dkt. No. 118 at 4-7. The court warned that any future filing with hallucinated or misrepresented authority could prompt sanctions, including “a filing restriction, monetary sanctions, and/or dismissal of this action” notwithstanding the plaintiff’s pro se status.
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
 D. Colo. – Judge Nina Y. Wang  7/7/2025 Generative AI    Generative AI Usage  In Coomer v. Lindell, 2025 U.S. Dist. LEXIS 128372 (D. Colo. July 7, 2025), counsel for the defendants included AI-generated citations in their opposition brief to the plaintiff’s omnibus motion in limine. During the final pre-trial conference, defense counsel admitted that they “ran [the brief] through AI” but “did not [cite] check” the result. Emphasizing that “Rule 11 applies to the use of artificial intelligence,” the court expressed skepticism that the incident was “simply an inadvertent error,” held that defense counsel violated Rule 11, and imposed joint and several sanctions of $3,000 on one attorney and his law firm, and individual sanctions of $3,000 on another attorney. Judge Wang declined to sanction the defendants themselves, however, as counsel “confirm[ed] that [he] did not advise” his clients that he used AI tools in his practice.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
Colorado Court of Appeals – Hon. Elizabeth Beebe Volz   12/26/2024  Generative AI  Generative AI Usage  In Al-Hamim v. Star Hearthstone, LLC, 2024 WL 5230126, the Colorado Court of Appeals considered whether sanctions were appropriate for a pro se litigant who relied upon “[GenAI]-generated hallucinations.” When questioned by the court, the pro se litigant admitted to relying on AI in drafting his brief and to failing to verify the false citations. The court advised that “using a [GenAI] tool to draft a legal document can pose serious risks if the user does not thoroughly review the tool’s output.” The court concluded that the fictitious citations “violated [Colorado Appellate Rule] 28(a)(7)(B),” but declined to impose sanctions, citing the litigant’s apology and acceptance of responsibility for the mistake. However, the court did not permit the plaintiff to refile a second, corrected brief. The court concluded by warning that future use of such hallucinations—for both “lawyers and self-represented parties”—may result in sanctions.
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
D. Colo. - Judge S. Kato Crews 12/1/2024 Generative AI  Generative AI Usage Judge Crews has updated his standing orders for civil cases to require that any motion filed under Federal Rules of Civil Procedure 12, 56, or 65, or any opposed motion, contain a certification stating whether generative AI was using “in preparing the filing.” Filings must certify either that “no portion of the filing was drafted by AI,” or that any language drafted by AI—even if later edited by a human—was personally reviewed for accuracy and correct citations using traditional legal databases. The court will strike filings that fail to include this certification.
Requires Disclosure and/or Verification 
Applies to AI Used for Research
Applies to AI Used for Filings/Drafting
 D. Colo - Magistrate Judge Susan Prose   10/21/2024 Generative AI   Generative AI Usage Magistrate Judge Prose’s standing order requires that filings contain a certification regarding either the use or the non-use of GenAI “(such as ChatGPT, Harvey.AI, Google Bard, etc.) in preparing the filing, including any proposed amended pleadings.” The preparer of the filing must certify that either no portion of the filing was drafted by GenAI or that any language drafted by AI, even if later edited by a human, “was personally reviewed by the filer or another human being for accuracy using print reporters or traditional legal databases and attesting that the legal citations are to actual existing cases or cited authority.” The order states that the court will strike any filing that does not include a certification.
Requires Disclosure and/or Verification
Applies to AI Used for Filings/Drafting