# The Expert Record

> The Expert Record by Bill Hartzer: the book and the eight-clause Standard for expert witnesses using AI, with the companion case record and working papers.

The companion site to the book The Expert Record by Bill Hartzer: the Standard for expert witnesses using AI, the case record, the working papers, and AI in the Courtroom, a dated record of matters in which an AI system was used in litigation. Every matter is labeled by whether its primary document was read.

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## The book and the Standard (6)

- [Home](https://www.theexpertrecord.com/): The Expert Record by Bill Hartzer: the book and the eight-clause Standard for expert witnesses using AI, with the companion case record and working papers.
- [The Expert Record](https://www.theexpertrecord.com/the-book/): The Expert Record: The Standard for Expert Witnesses Using AI, by Bill Hartzer. Thirty-two chapters, the eight clauses, and nine appendices.
- [The Expert Record Standard](https://www.theexpertrecord.com/standard/): Eight clauses governing the use of artificial intelligence in expert engagements. Licensed for verbatim adoption in engagement letters and firm policies.
- [Adopting the Standard](https://www.theexpertrecord.com/standard/adopt/): License terms and attribution for the Expert Record Standard, and where it belongs in an engagement letter.
- [Before You Use AI on an Engagement](https://www.theexpertrecord.com/checklist/): A checklist for expert witnesses before, during and after using AI on an engagement, with each item tied to a clause of the Expert Record Standard.
- [How this site is researched](https://www.theexpertrecord.com/methodology/): How theexpertrecord.com is researched: sources, how each fact is traced, the part AI systems play, review before publication, and dating.

## Case record and corrections (2)

- [The case record](https://www.theexpertrecord.com/case-record/): Every matter described in The Expert Record, identified in full, with disposition, current posture, and the date each entry was last checked.
- [Errata and updates](https://www.theexpertrecord.com/errata/): Corrections to The Expert Record, and notice of any material in it that has been superseded.

## Working papers (5)

- [The working papers](https://www.theexpertrecord.com/working-papers/): The AI-use log template, engagement letter provisions, verification checklist, deposition question sets, analysis specifications, and preservation protocol.
- [AI-use log template](https://www.theexpertrecord.com/working-papers/ai-use-log/): The log template from Appendix A of the book, in full: the header block, the per-use rows, and the four rules that make a log worth having.
- [Preservation and production protocol](https://www.theexpertrecord.com/working-papers/preservation-protocol/): The preservation protocol from Appendix F: the day-one folder, the export cadence, what to do when a request arrives, and the cross-matter problem.
- [Analysis scripts](https://www.theexpertrecord.com/working-papers/scripts/): Runnable implementations of the seven reproducible-analysis specifications from Appendix E, maintained against current language versions.
- [The verification checklist](https://www.theexpertrecord.com/working-papers/verification-checklist/): The verification checklist from Appendix C: the six categories of checkable assertion, the four dispositions, and what to do when a source cannot be located.

## AI in the Courtroom: index and topic hubs (7)

- [AI in the Courtroom](https://www.theexpertrecord.com/ai-in-court/): A dated record of real matters where AI was used in court: fabricated citations, deepfake evidence, AI experts, judges' orders and new rules.
- [Expert witnesses and AI](https://www.theexpertrecord.com/ai-in-court/expert-witnesses/): Expert declarations and reports prepared with an AI system, and how tribunals treated the evidence. 19 matters, each dated and sourced.
- [Fabricated citations and facts in filings](https://www.theexpertrecord.com/ai-in-court/fabricated-authority/): Filings that put a nonexistent case, quotation or fact before a court, and what the court did about it. 20 matters, each dated and sourced.
- [AI-generated and altered evidence](https://www.theexpertrecord.com/ai-in-court/ai-evidence/): Deepfakes offered as evidence, AI-enhanced media, and claims that genuine recordings were fabricated. 17 matters, each dated and sourced.
- [Judges, courts and AI](https://www.theexpertrecord.com/ai-in-court/judges-and-courts/): Orders containing AI errors, judges using AI openly, and the oversight that followed. 14 matters, each dated and sourced.
- [AI inside the courtroom](https://www.theexpertrecord.com/ai-in-court/in-the-courtroom/): Avatars, generated statements, AI in place of counsel, and AI tools used in proceedings. 7 matters, each dated and sourced.
- [Rules, orders and guidance](https://www.theexpertrecord.com/ai-in-court/rules-and-guidance/): Rules of evidence, court rules, standing orders, ethics opinions and expert-facing guidance on AI. 13 matters, each dated and sourced.

## AI in the Courtroom: Expert witnesses and AI (19)

- [In re Celsius Network LLC (Faraj report)](https://www.theexpertrecord.com/ai-in-court/in-re-celsius-network-faraj-report/): A bankruptcy court excluded a 172-page CEL token valuation report written by AI in 72 hours but admitted the expert's live testimony.
- [Matter of Weber](https://www.theexpertrecord.com/ai-in-court/matter-of-weber-copilot-damages/): A New York Surrogate's Court gave no weight to damages figures an expert cross-checked with Microsoft Copilot and set a disclosure rule for AI evidence.
- [Plonit v. Clal Insurance (DigitalOwl summary)](https://www.theexpertrecord.com/ai-in-court/plonit-v-clal-digitalowl-expert/): An Israeli court ordered a court-appointed medical expert to disregard an AI-processed claim summary and made the insurer resend the records unmarked.
- [Kohls v. Ellison](https://www.theexpertrecord.com/ai-in-court/kohls-v-ellison-hancock-declaration/): A Minnesota federal court excluded an expert declaration drafted with GPT-4o after 2 fabricated articles and 1 misattributed citation were found.
- [NSW Supreme Court Practice Note SC Gen 23](https://www.theexpertrecord.com/ai-in-court/nsw-practice-note-expert-reports-gen-ai/): Since February 2025 the NSW Supreme Court has barred generative AI in expert reports without leave, and requires disclosure and records if allowed.
- [Ferlito v. Harbor Freight Tools USA](https://www.theexpertrecord.com/ai-in-court/ferlito-v-harbor-freight-chatgpt/): An E.D.N.Y. judge denied a motion to exclude a product-design expert who used ChatGPT only after finishing his report, to confirm his conclusion.
- [Concord Music Group v. Anthropic (Chen declaration)](https://www.theexpertrecord.com/ai-in-court/concord-music-v-anthropic-chen-declaration/): Paragraph 9 of Olivia Chen's expert declaration was struck after Claude.ai, used by counsel to format a citation, produced a wrong title and wrong authors.
- [Butler and National Disability Insurance Agency](https://www.theexpertrecord.com/ai-in-court/butler-ndia-ai-assisted-expert-reports/): A tribunal gave reduced weight to AI-assisted expert reports, holding a practitioner must remain responsible and accountable for a report's content.
- [In re Valsartan MDL (Dr. William Sawyer)](https://www.theexpertrecord.com/ai-in-court/valsartan-mdl-sawyer-ai-citations/): A special master in the Valsartan MDL declined to exclude a toxicologist whose report cited non-existent sources produced by an AI tool.
- [Biton v. The National Insurance Institute](https://www.theexpertrecord.com/ai-in-court/biton-national-insurance-chatgpt-expert/): A labor court let a claimant put ChatGPT-sourced research to a court-appointed expert, but required the articles themselves, not the system's summaries.
- [Landgericht Darmstadt expert fee decision](https://www.theexpertrecord.com/ai-in-court/lg-darmstadt-expert-fee-zero/): A German regional court set a court-appointed expert's fee at zero euros after finding his report was AI-generated and the claimant was never examined.
- [Cour d'appel de Rouen, RG 25/01677 (Copilot analysis)](https://www.theexpertrecord.com/ai-in-court/rouen-court-of-appeal-copilot-analysis/): In a drainage dispute, a French appeals court relied on professional evidence and expressly not on a party's Copilot analysis of a contractor's letter.
- [Social Media MDL (Osborne AI citation tool)](https://www.theexpertrecord.com/ai-in-court/social-media-mdl-osborne-citations/): In the social media adolescent addiction MDL the court declined to exclude a school-district expert over citations attributed to an AI citation tool.
- [Riddle Aggregates (Tax Court rebuttal expert)](https://www.theexpertrecord.com/ai-in-court/riddle-aggregates-tax-court-appraisal/): The Commissioner withdrew two rebuttal appraisal reports mid-trial in the U.S. Tax Court after voir dire exposed citations to authority that does not exist.
- [Conservation Law Foundation v. Shell (expert AI prompts)](https://www.theexpertrecord.com/ai-in-court/clf-v-shell-expert-ai-prompts/): A Connecticut magistrate judge ordered production of the AI prompts an expert's team used to cull a document production. The order is stayed on objection.
- [LeDoux v. Outliers, Inc.](https://www.theexpertrecord.com/ai-in-court/ledoux-v-outliers-ai-citation-table/): A Tacoma federal judge fined counsel $3,000 over AI-generated citations, including a table given to 2 experts, and later excluded a third expert's report.
- [Bard Port Catheter MDL (El-Ghannam ChatGPT challenge)](https://www.theexpertrecord.com/ai-in-court/bard-port-catheter-mdl-el-ghannam/): An MDL court declined to exclude a materials-science expert who acknowledged using ChatGPT, where no hallucinated citation was identified in his report.
- [Watson Grinding explosion trial (3M expert)](https://www.theexpertrecord.com/ai-in-court/watson-grinding-3m-expert-chatgpt/): A 3M expert in a Houston explosion trial produced about 350 pages of ChatGPT logs and was questioned at trial about a report largely drafted by ChatGPT.
- [Villanueva v. Las Vegas Metropolitan Police Department](https://www.theexpertrecord.com/ai-in-court/villanueva-v-lvmpd-expert-chatgpt-log/): A federal judge ordered an expert's ChatGPT case summaries produced as facts or data considered, and held his prompts and draft-report output protected.

## AI in the Courtroom: Fabricated citations and facts in filings (20)

- [Mata v. Avianca, Inc.](https://www.theexpertrecord.com/ai-in-court/mata-v-avianca/): Two lawyers filed a brief citing airline decisions ChatGPT invented, then stood by them under questioning. What the court did, and what it cost them.
- [Ayinde v Haringey and Al-Haroun v Qatar National Bank](https://www.theexpertrecord.com/ai-in-court/ayinde-al-haroun-divisional-court/): The Divisional Court of England and Wales referred a barrister and solicitors to regulators in June 2025 after filings cited cases that do not exist.
- [Johnson v. Dunn (Butler Snow)](https://www.theexpertrecord.com/ai-in-court/johnson-v-dunn-butler-snow/): N.D. Ala. publicly reprimanded and disqualified 3 Butler Snow lawyers and referred them to the bar after ChatGPT supplied 5 false citations in 2 motions.
- [Victorian murder trial submissions (Nathwani KC)](https://www.theexpertrecord.com/ai-in-court/nathwani-victoria-murder-case/): Defense submissions in a Supreme Court of Victoria murder case contained AI-generated fake quotes and citations. Senior counsel apologized in August 2025.
- [Noland v. Land of the Free, L.P.](https://www.theexpertrecord.com/ai-in-court/noland-v-land-of-the-free/): California Court of Appeal fined counsel $10,000 and referred him to the State Bar after 21 of 23 case quotations in his opening brief proved fabricated.
- [Kjoller v. Superior Court (Nevada County DA)](https://www.theexpertrecord.com/ai-in-court/kjoller-nevada-county-prosecutor/): California Supreme Court directed an order to show cause on sanctions after Nevada County prosecutors filed briefs citing authority that does not exist.
- [Amarsingh v. Frontier Airlines (Tenth Circuit)](https://www.theexpertrecord.com/ai-in-court/amarsingh-v-frontier-tenth-circuit/): The Tenth Circuit ordered a pro se appellant who is a licensed attorney to pay $1,000 and referred her to Maryland disciplinary authorities.
- [Clinco v. Commissioner](https://www.theexpertrecord.com/ai-in-court/clinco-v-commissioner-fabricated-citations/): Counsel cited four cases in a Tax Court brief and three did not exist. The court called fictitious caselaw a recipe for sanctions but imposed none.
- [Fletcher v. Experian (Fifth Circuit sanction)](https://www.theexpertrecord.com/ai-in-court/fletcher-v-experian-fifth-circuit/): In a published opinion the Fifth Circuit sanctioned appellant's counsel $2,500 for an AI-drafted reply brief and for a response that was not forthcoming.
- [Obi v. Cook County](https://www.theexpertrecord.com/ai-in-court/obi-v-cook-county/): N.D. Ill. imposed a $5,000 Rule 11 sanction on a self-represented plaintiff in April 2026 after repeated AI-drafted briefs cited cases that do not exist.
- [In re Prince Global Holdings (Sullivan & Cromwell)](https://www.theexpertrecord.com/ai-in-court/prince-global-sullivan-cromwell/): Sullivan & Cromwell told the S.D.N.Y. bankruptcy court in April 2026 that an emergency motion contained AI hallucinations its policies should have caught.
- [Lnu v. Blanche (Ninth Circuit suspension)](https://www.theexpertrecord.com/ai-in-court/lnu-v-blanche-ninth-circuit-suspension/): The Ninth Circuit fined two attorneys $2,500 each, suspended them six months, and required AI statements under penalty of perjury for two years.
- [In re Rosslyn2016 (a legal research tool is still a tool)](https://www.theexpertrecord.com/ai-in-court/in-re-rosslyn2016-westlaw-precision/): A bankruptcy court rejected the argument that a legal vendor's AI research tool deserves different treatment, finding contempt and ordering $29,877 in fees.
- [Daghra v. Hinkley (government counsel)](https://www.theexpertrecord.com/ai-in-court/daghra-v-hinkley-government-lawyer/): A chief district judge found a citation in the Government's filing was likely produced by generative AI and barred non-existent case law in future.
- [State v. Sandoval (Aarons sanction)](https://www.theexpertrecord.com/ai-in-court/sandoval-new-mexico-murder-appeal/): New Mexico Supreme Court held murder-appeal counsel in contempt and ordered $5,000 after his ChatGPT-assisted brief invented witnesses and testimony.
- [SRA v Kumar (Solicitors Disciplinary Tribunal)](https://www.theexpertrecord.com/ai-in-court/sra-v-kumar-sdt-ai-strike-off/): The Solicitors Disciplinary Tribunal struck off a foreign lawyer whose AI-drafted filings in his own case cited cases and passages that did not exist.
- [Douglas v. Deutsche Bank National Trust Co.](https://www.theexpertrecord.com/ai-in-court/douglas-v-deutsche-bank-brief-struck/): The District of Columbia Court of Appeals struck a bank's appellate brief citing four nonexistent authorities and referred the matter to disciplinary counsel.
- [Henry v. Long Island University](https://www.theexpertrecord.com/ai-in-court/henry-v-long-island-university-two-year-order/): A federal judge made two lawyers file his opinion in every case they join for two years after a brief relied on fake cases they called typographical errors.
- [Cervantes v. Bianco (Supreme Court of California)](https://www.theexpertrecord.com/ai-in-court/cervantes-v-bianco-state-bar-referral/): California's Supreme Court referred counsel to the State Bar after a brief misquoted one of its decisions, an error AI tools apparently contributed to.
- [Aguilar v. The Crawford Group, Inc.](https://www.theexpertrecord.com/ai-in-court/aguilar-v-crawford-group-pro-hac-vice-revoked/): A federal judge revoked a lawyer's pro hac vice admission and ordered fees after AI-drafted briefs miscited cases. He had believed his AI tool could not err.

## AI in the Courtroom: AI-generated and altered evidence (17)

- [Huang v. Tesla](https://www.theexpertrecord.com/ai-in-court/huang-v-tesla-musk-deepfake-argument/): Tesla declined to authenticate recordings of Elon Musk, citing deepfakes. A Santa Clara judge called it deeply troubling and ordered a limited deposition.
- [State of Washington v. Puloka](https://www.theexpertrecord.com/ai-in-court/puloka-ai-enhanced-video/): A King County judge excluded a bystander video enhanced with Topaz Labs AI from a 2024 triple-homicide trial after a Frye hearing.
- [Maryland v. Darien (Pikesville High deepfake audio)](https://www.theexpertrecord.com/ai-in-court/pikesville-principal-deepfake-audio/): A former Pikesville High athletic director entered an Alford plea in 2025 over an AI-generated recording of the principal and received 4 months in jail.
- [Mendones v. Cushman & Wakefield](https://www.theexpertrecord.com/ai-in-court/mendones-v-cushman-wakefield-deepfake-exhibits/): An Alameda County judge dismissed a housing case with prejudice in 2025 after finding self-represented plaintiffs filed AI-generated video testimony.
- [Florida v. Schinault (ChatGPT image false report)](https://www.theexpertrecord.com/ai-in-court/st-petersburg-chatgpt-image-false-report/): A St. Petersburg woman gave police a ChatGPT-generated image of a supposed intruder in 2025. She pleaded no contest to false reporting.
- [State v. Amyda (deepfake claim without evidence)](https://www.theexpertrecord.com/ai-in-court/state-v-amyda-deepfake-authentication/): The Iowa Court of Appeals affirmed admission of a video over a deepfake objection: a speculative claim with no evidence does not defeat authentication.
- [Warner v. Gilbarco (ChatGPT work product)](https://www.theexpertrecord.com/ai-in-court/warner-v-gilbarco-ai-work-product/): A magistrate judge denied discovery into a self-represented plaintiff's ChatGPT use, holding that using the system did not waive work product protection.
- [Matter of M.S. (M.H.)](https://www.theexpertrecord.com/ai-in-court/matter-of-ms-video-authentication/): New York's Court of Appeals reversed abuse findings in 2026, holding 3 hacked security-camera videos were not properly authenticated. Two judges dissented.
- [United States v. Heppner](https://www.theexpertrecord.com/ai-in-court/united-states-v-heppner-ai-privilege/): A Manhattan federal judge ruled that 31 documents a fraud defendant made with Claude, seized by the FBI, were not protected as privileged or work product.
- [Burnley v. Valentin](https://www.theexpertrecord.com/ai-in-court/burnley-v-valentin-voice-clone-claim/): A federal magistrate judge in Virginia found a recorded call authentic in 2026 after a pro se party said it was an AI clone of his voice.
- [Morgan v. V2X (AI work product)](https://www.theexpertrecord.com/ai-in-court/morgan-v-v2x-ai-work-product/): A Colorado magistrate judge held a self-represented party's AI use is work product, ordered the tool named, and amended the protective order to restrict AI.
- [Tym v. Cerno (AI work product)](https://www.theexpertrecord.com/ai-in-court/tym-v-cerno-ai-work-product/): A magistrate judge compelled amended discovery responses but sustained a work product objection over a party's generative AI interactions, requiring a log.
- [Adams v. Anderson (Kentucky Court of Appeals)](https://www.theexpertrecord.com/ai-in-court/adams-v-anderson-ai-faked-evidence-contempt/): A parent conceded that testimony and documents were false or altered after AI fabrication was alleged. A 45-day contempt sentence was upheld on appeal.
- [Tate Group Automotive v. Legacy Automotive Capital](https://www.theexpertrecord.com/ai-in-court/tate-group-v-legacy-chatgpt-work-product/): A Texas Business Court judge treated a non-lawyer's ChatGPT chats as work product but ordered disclosure of what had been shared with the system.
- [Assini v. Hayward (subpoena to OpenAI quashed)](https://www.theexpertrecord.com/ai-in-court/assini-v-hayward-openai-subpoena/): A New York court quashed a subpoena seeking a pro se litigant's OpenAI account records, declining to follow the federal ruling in United States v. Heppner.
- [Shealy v. Seaside Investments](https://www.theexpertrecord.com/ai-in-court/shealy-v-seaside-chatgpt-work-product/): A business court compelled production of ChatGPT prompts and output a party's partner made, holding AI work is not work product without counsel's direction.
- [Fry v. Fry (Claude upload and sealing)](https://www.theexpertrecord.com/ai-in-court/fry-v-fry-claude-upload-sealing/): A federal judge declined to seal documents a party had uploaded to consumer Claude, and required disclosure of the AI tools, prompts and inputs used.

## AI in the Courtroom: Judges, courts and AI (14)

- [Snell v. United Specialty Insurance (Judge Newsom)](https://www.theexpertrecord.com/ai-in-court/newsom-llm-ordinary-meaning-concurrences/): 11th Circuit Judge Kevin Newsom queried ChatGPT, Gemini and Claude on ordinary meaning in 2 concurrences in 2024 and set out what he asked and got.
- [Colombia: Cartagena ChatGPT ruling and Sentencia T-323/24](https://www.theexpertrecord.com/ai-in-court/colombia-chatgpt-tutela-t-323/): A Cartagena judge consulted ChatGPT in a 2023 ruling. In T-323 of 2024 Colombia's Constitutional Court found no due process breach and set principles.
- [Shahid v. Esaam](https://www.theexpertrecord.com/ai-in-court/shahid-v-esaam/): Georgia Court of Appeals vacated a divorce-case order that relied on 2 fictitious cases and fined the attorney whose name appeared on it $2,500.
- [In re CorMedix Securities Litigation (Judge Neals)](https://www.theexpertrecord.com/ai-in-court/cormedix-neals-withdrawn-opinion/): A D.N.J. opinion in the CorMedix case was withdrawn after counsel flagged misstated outcomes and invented quotes. The judge cited an intern's ChatGPT use.
- [Jackson Federation of Teachers v. Fitch (Judge Wingate)](https://www.theexpertrecord.com/ai-in-court/wingate-mississippi-dei-order/): A Mississippi federal TRO named nonparties and misquoted the statute. The judge later cited a clerk's use of Perplexity; the 5th Circuit heard argument.
- [Senate Judiciary inquiry into judges' AI use](https://www.theexpertrecord.com/ai-in-court/grassley-federal-judges-ai-inquiry/): In October 2025 Sen. Grassley asked 2 federal judges about AI-drafted orders. Both acknowledged staff use; the courts' AO described interim AI guidance.
- [Judge Wheeler (Oklahoma) fabricated citations](https://www.theexpertrecord.com/ai-in-court/wheeler-oklahoma-judge-fabricated-citations/): An Oklahoma district judge's order contained citations to cases that do not exist. In September 2026 the state Attorney General declined to pursue the claims.
- [Payne v. State](https://www.theexpertrecord.com/ai-in-court/payne-v-state-georgia-new-trial-order/): Georgia Supreme Court vacated a new-trial order drafted by a prosecutor that contained fictitious citations, and suspended her from practice before it.
- [Henry County Schools v. Grant (party-drafted order)](https://www.theexpertrecord.com/ai-in-court/henry-county-schools-v-grant/): The Georgia Court of Appeals vacated a trial court order drafted by counsel that ignored binding precedent, misquoted cases and relied on a hallucinated case.
- [Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd.](https://www.theexpertrecord.com/ai-in-court/pooja-ramesh-singh-india-nclt-fake-precedents/): India's Supreme Court set aside NCLT and NCLAT orders that relied on 6 fabricated or misquoted precedents the tribunal found through its own research.
- [FJL v TGO (Gauteng Division, Johannesburg)](https://www.theexpertrecord.com/ai-in-court/fjl-v-tgo-acting-judge-fictitious-citations/): A South African appeal bench was shown 11 citation errors in an acting judge's judgment, including a nonexistent case. One judge referred it to a regulator.
- [Phillips v. Parlade (judicial immunity and AI)](https://www.theexpertrecord.com/ai-in-court/phillips-v-parlade-judicial-immunity/): A federal court held judicial immunity bars a claim that a state judge relied wholly on AI to issue a ruling, even assuming it were true.
- [Faiz Enterprise v. State Tax Officer](https://www.theexpertrecord.com/ai-in-court/faiz-enterprise-v-state-tax-officer-ai-order/): A tax officer cancelled a GST registration citing AI-generated cases. The High Court quashed the orders and made the department's new AI rules enforceable.
- [Vijay Ghanshyam Gadiya v. Union of India](https://www.theexpertrecord.com/ai-in-court/gadiya-v-union-of-india-ai-penalty-order/): India's Supreme Court set aside a customs penalty order after checking its authorities itself and finding cases that do not exist or say what was cited.

## AI in the Courtroom: AI inside the courtroom (7)

- [DoNotPay "robot lawyer" and FTC order](https://www.theexpertrecord.com/ai-in-court/donotpay-robot-lawyer-ftc/): DoNotPay dropped a 2023 plan to feed AI arguments to a traffic defendant by earpiece. In 2025 the FTC finalized a $193,000 order over its AI lawyer claims.
- [Arizona Supreme Court AI news reporters](https://www.theexpertrecord.com/ai-in-court/arizona-supreme-court-ai-avatars/): In March 2025 the Arizona Supreme Court began using 2 AI-generated avatars, Daniel and Victoria, to present video summaries of its decisions and news.
- [Dewald AI avatar argument (N.Y. App. Div., 1st Dept.)](https://www.theexpertrecord.com/ai-in-court/dewald-ai-avatar-appellate-division/): A self-represented appellant played an AI-generated avatar to argue his appeal in New York's First Department. The presiding justice stopped the video.
- [State v. Horcasitas (Pelkey AI victim impact statement)](https://www.theexpertrecord.com/ai-in-court/pelkey-ai-victim-impact-statement/): A family played an AI-generated video of a slain man at his killer's sentencing in Maricopa County. The judge imposed 10.5 years; the defense appealed.
- [Jones v. Delta Air Lines (ChatGPT at a deposition)](https://www.theexpertrecord.com/ai-in-court/jones-v-delta-deposition-chatgpt/): A court instructed a self-represented plaintiff that she could not use ChatGPT or any AI platform to help her answer questions during her deposition.
- [State v. Boles juror ChatGPT research (Paulding County, Ga.)](https://www.theexpertrecord.com/ai-in-court/boles-juror-chatgpt-georgia/): A Georgia murder trial was postponed in June 2026 after a prospective juror asked ChatGPT about the case. The judge released the jury pool.
- [Williams v. State (Ind. Ct. App.) AI-assisted transcript](https://www.theexpertrecord.com/ai-in-court/williams-indiana-ai-transcript/): The Indiana Court of Appeals noted that a trial transcript's errors suggested generative AI had helped prepare it, and reminded users to proofread output.

## AI in the Courtroom: Rules, orders and guidance (13)

- [Judge Starr's AI certificate and the Fifth Circuit rule](https://www.theexpertrecord.com/ai-in-court/starr-certification-and-fifth-circuit-ai-rule/): Judge Brantley Starr's 2023 AI certificate requirement in N.D. Texas, and the Fifth Circuit's June 2024 decision not to adopt a similar rule for briefs.
- [ABA Formal Opinion 512](https://www.theexpertrecord.com/ai-in-court/aba-formal-opinion-512/): What ABA Formal Opinion 512, issued July 29 2024, actually requires of lawyers using generative AI: competence, confidentiality, candor, supervision and fees.
- [California Rule of Court 10.430 and Standard 10.80](https://www.theexpertrecord.com/ai-in-court/california-rule-10-430-generative-ai/): California's Judicial Council adopted rule 10.430 and Standard 10.80 in July 2025, requiring courts that allow generative AI to adopt use policies.
- [AI Judicial Guidance, England and Wales (October 2025)](https://www.theexpertrecord.com/ai-in-court/uk-judicial-guidance-on-ai/): England and Wales judiciary issued updated AI guidance for judicial office holders on Oct. 31, 2025, covering confidentiality, accuracy and deepfakes.
- [Civil Justice Council consultation on AI in court documents](https://www.theexpertrecord.com/ai-in-court/civil-justice-council-ai-court-documents/): The Civil Justice Council consulted in 2026 on AI in court documents, including a proposal that expert reports identify and explain any AI used.
- [Proposed Federal Rule of Evidence 707](https://www.theexpertrecord.com/ai-in-court/fre-707-machine-generated-evidence/): Proposed Federal Rule of Evidence 707 on machine-generated evidence: its 2025 text, the public comment, and the May 2026 decision to revise and restudy it.
- [New York courts: interim AI policy and Part 161](https://www.theexpertrecord.com/ai-in-court/new-york-courts-ai-policy-part-161/): New York's court system issued an interim AI policy for judges and staff in October 2025 and adopted Part 161 on AI in court papers effective June 1, 2026.
- [Draft Regulations for Use of AI in Courts, 2026](https://www.theexpertrecord.com/ai-in-court/india-draft-regulations-ai-in-courts-2026/): India's Supreme Court published draft regulations for AI in courts, with absolute prohibitions and a duty to disclose AI help with documents and evidence.
- [Connecticut Practice Book Section 4-9 (Generative AI)](https://www.theexpertrecord.com/ai-in-court/connecticut-practice-book-4-9-generative-ai/): Connecticut's Superior Court requires anyone filing a document made with generative AI to verify every citation, authority and item of evidence it produced.
- [Cherokee County Superior Court AI standing order](https://www.theexpertrecord.com/ai-in-court/cherokee-county-ai-standing-order/): Four Superior Court judges ordered anyone using AI on a filing to name the tool and certify under penalty of perjury that every citation exists as cited.
- [AI clauses in protective orders (Jeffries; Dunn)](https://www.theexpertrecord.com/ai-in-court/ai-protective-orders-jeffries-dunn/): Two 2026 federal orders wrote AI restrictions into protective orders, barring open AI tools for discovery material and limiting which platforms parties use.
- [Tenth Circuit proposed Rule 46.5(B)(4) on generative AI](https://www.theexpertrecord.com/ai-in-court/tenth-circuit-proposed-rule-46-5-generative-ai/): The Tenth Circuit proposed that any filing made with generative AI be checked by a human who verified each authority and quotation. Comments close Oct. 18.
- [California SB 574 (Statutes of 2026, chapter 858)](https://www.theexpertrecord.com/ai-in-court/california-sb-574-attorneys-generative-ai/): California enacted SB 574, barring attorneys from delegating the practice of law to generative AI and requiring personal verification of citations in filings.

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