Adams v. Anderson (Kentucky Court of Appeals)

What happened

Cindy Lynn Adams and Joshua Bartley Anderson are parties to a divorce action in the Fayette Circuit Court, Family Division, in Kentucky, and the parents of two children. At a July 30, 2025 hearing on a motion to modify timesharing, Adams testified that she had taken one of the children to an urgent care center and obtained medication afterward. She produced a photograph of the prescription bottle, which was admitted into evidence.

On August 13, 2025, Anderson moved for sanctions. As the Court of Appeals recounts, his motion alleged that the testimony was false "and that the picture of the medication had been altered or was created by artificial intelligence," and stated that the urgent care center and the pharmacy both reported having no records for the date. Adams denied it and filed more documents; Anderson replied that those were "also fake, photoshopped, or created by artificial intelligence."

The matter first came to this record through the federal Reporter's memorandum on deepfakes described below. The opinion itself, No. 2025-CA-1309-MR, has since been located and read.

What the court did

At a motion hour on August 22, 2025, Judge Tiffany Yahr said that if the documents were falsified and the testimony untrue, Adams would be going to jail. Her counsel then indicated that the testimony and the documents were false or altered. The court set a show-cause hearing on contempt and made clear it was considering criminal, not civil, contempt. At the hearing on September 26, 2025, Adams pleaded guilty, and under oath "admitted to lying to the court." She was sentenced to 45 days in jail.

On appeal she raised unpreserved challenges, which the court reviewed for palpable error. It held the appeal not moot despite the completed sentence, and on May 29, 2026 it affirmed: "While it is true that Appellant did not disobey an order of the court, she did obstruct justice and disrespect the court. Providing false testimony during a hearing and submitting altered or fake documents into evidence is the epitome of resisting the authority of the court and degrading its authority." The opinion is designated not to be published.

Where it stands

The contempt sentence was affirmed. The opinion makes no finding about how the documents were produced; the concession was that they were false or altered, and the AI attribution was the opposing party's allegation. This entry therefore records the matter as a deepfake allegation that ended in an admitted fabrication, not as a judicial finding that a particular AI tool was used.

The Reporter's comment in the memorandum is the reason the matter is in the federal rulemaking file: the father's showing, that the provider and the pharmacy had no records, "would surely be a sufficient showing to trigger the deepfake inquiry" under the draft Rule 901(c) discussed in the entry on proposed Federal Rule of Evidence 707. Mendones v. Cushman & Wakefield ended a case over AI-generated exhibits; Adams v. Anderson ended with a jail sentence for the person who offered them.

The obligation it engaged

The Standard's clauses govern an expert's own use of systems, and nothing here involved an expert. The matter is in this record because it shows what tests a challenged item in practice. Anderson did not rely on a detection tool. He checked the photograph against the records it should have matched, which is Clause 4 of the Standard, checkability before adoption, applied by the opposing side.

For an expert asked to authenticate an image or document, that is the instructive part: the most persuasive test was an independent source that should have corroborated the item and did not, the approach Clause 3, independent authority, requires for anything an expert relies on.

Sources

• Advisory Committee on Evidence Rules (Reporter's memorandum, October 15, 2026 agenda book) · September 15, 2026
  Deepfakes and Draft Rule 901(c), memorandum of Professor Daniel J. Capra
• Kentucky Court of Appeals (via Justia) · May 29, 2026
  Adams v. Anderson, No. 2025-CA-1309-MR (Ky. Ct. App. May 29, 2026)

What could not be confirmed

The opinion does not find that AI was used; the AI attribution was the opposing party's allegation, and the concession was that the testimony and documents were false or altered. The Westlaw citation 2026 WL 1501021 used in the federal memorandum was not independently confirmed.