Court - Judge Name	Effective Date	Applicable To	Categories	Summary
S.D. Ind. – Magistrate Judge Crystal S. Wildeman	11/18/2025	Generative AI	Generative AI Usage	In Nellum v.Credit Acceptance Corp., No. 1:25-cv-01579-TWP-CSW, 2025 U.S. Dist. LEXIS 227441 (S.D. Ind. Nov. 18, 2025), the court ruled on motions to compel arbitration, to strike, and to file a sur-reply, as well as an emergency motion. In its order, the court noted that the pro se plaintiff cited to a case that “does not exist.” Although the plaintiff claimed she “did not fabricate citations,” she admitted that some citations may have been “‘imperfect.’” The court declined to impose sanctions, but warned that “‘pro se litigants are not excused from compliance with the procedural rules,’” and reminded the plaintiff that “submitting hallucinated citations . . . is unacceptable.”
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
Ind. Tax Ct. -- Judge Justin McAdam	10/17/2025	Generative AI	Generative AI Usage	In Tippercanoe Cnty. Assessor v. Goergen, 2025 Ind. Tax LEXIS 32 (Ind. Tax Ct. Oct. 17, 2025), the county assessor filed appeals in his official capacity on behalf of the assessor’s office in various cases in the Indiana Tax Court, alleging that the Indiana Board of Tax Review is biased and has committed due process violations. His brief contained a fictitious citation, which the court presumed was “the result of a hallucination by generative artificial intelligence.” The court highlighted this as an example of the “risks of allowing a non-attorney to represent others in court.” The court ultimately prohibited the assessor from appearing without counsel and reminded him that both attorneys and pro se parties have a duty to verify all cited sources and include accurate citations.
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
Ind. Ct. App. – Judge Paul A. Felix	9/19/2025	Generative AI	Generative AI Usage	In Cingel v. Ferreri, 2025 WL 2680017 (Ind. Ct. App. Sept. 19, 2025), the Indiana Court of Appeals considered the pro se appellant’s appeal of the trial court’s decision on matters of child custody, relocation, and a motion to correct error. The court concluded that the plaintiff “waived her argument due to her significant noncompliance with Indiana Appellate Rule 46,” in large part because she cited multiple statutes and cases which “do[] not exist,” and “incorrectly cited or described” cases that do exist. The court concluded that “it is likely that [the pro se plaintiff] used generative artificial intelligence to draft her brief, either in whole or in part,” and dismissed the appeal on the grounds of waiver. The court also held that, waiver notwithstanding, her claims “are without merit,” and so affirmed the trial court on all grounds.
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Parties
Ind. Ct. App. – Judge Nancy H. Vaidik	8/18/2025	Generative AI	Generative AI Usage	In Williams v. Kirch, 2025 Ind. App. LEXIS 268 (Ind. Ct. App. Aug. 18, 2025), the defendant-appellee identified a few hallucinated citations in the pro se plaintiff-appellant’s opening brief on appeal of the trial court’s judgment ordering payment of attorney’s fees. The plaintiff-appellant did not, however, provide any reason for using these cases. Because the defendant-appellee did not seek sanctions in response to the AI-generated material, Judge Vaidik instead warned the parties that they must be able to “independently verify[]” all citations generated by AI in their filings since courts rely on briefings “to make just decisions.”
			Suggests Cautious Use of AI
			Applies to AI Used for Research
			Applies to AI Used for Filings/Drafting
S.D. Ind. – Judge Tanya Walton Pratt	7/18/2025	Generative AI	Generative AI Usage	In Parrish v. Miller, 2025 U.S. Dist. LEXIS 137247 (S.D. Ind. July 18, 2025), the plaintiffs included various hallucinated citations in support of their motion for reconsideration. Although the use of AI was not part of the court’s reasoning for denying the plaintiffs’ motion, the court warned that it has “recently admonished and sanctioned parties for submitting briefs containing miscited or non-existent cases.”
			Applies to AI Used for Filings/Drafting
S.D. Ind. – Judge James Patrick Hanlon	5/28/2025	Generative AI	Generative AI Usage	In Mid Cent. Operating Eng'rs Health v. Hoosiervac LLC, 2025 U.S. Dist. LEXIS 100748, the magistrate judge recommended that the defendant’s attorney be sanctioned $15,000 for submitting three briefs with false citations. The attorney claimed this penalty was inappropriate given the “‘significant and irreversible harm to [his] professional reputation’” that he has faced since the original order to show cause was issued. Judge Hanlon ultimately reduced the sanction to $6,000 based on the attorney’s attendance at continuing education programs on the “responsible use of AI” and “adhere[nce] to ‘the highest standards of professional conduct moving forward.’” The court noted that the sanction was still substantial given the repeated use of AI-generated citations and the fact that attorneys in other cases continue to cite to non-existent authorities.
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Attorneys/Law Firms
S.D. Ind. - Judge Dinsmore	2/24/2025	Generative AI	Generative AI Usage	Judge Dinsmore recently issued a decision in Mid Cent. Operating Eng'rs Health v. Hoosiervac LLC, 2025 U.S. Dist. LEXIS 31073 (Feb. 21, 2025), recommending that an attorney be “sanctioned the amount of $15,000 pursuant to Federal Rule of Civil Procedure 11 for submitting to the Court and opposing counsel, on three separate occasions, briefs that contained citations to non-existent cases.” The attorney admitted that “he had relied on programs utilizing generative artificial intelligence (‘AI’) to draft the briefs.” The Court found that this Gen AI use specifically violated Federal Rule of Civil Procedure 11(b)(2) as well as the Indiana Rules of Professional Conduct 1.1, 3.1, and 3.3 (governing competence, meritorious claims and contentions, and candor toward the court). However, the court explicitly allowed for the use of AI for certain legal research, explaining that “[i]t is one thing to use AI to assist with initial research, and even non-legal AI programs may provide a helpful 30,000-foot view. It is an entirely different thing, however, to rely on the output of a generative AI program without verifying the current treatment or validity—or, indeed, the very existence—of the case presented.”
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Attorneys/Law Firms

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