Date: Apr 26, 2026

Jarvis v. County of Teton, Wyoming — Litigants Must Verify AI-Generated Citations; Fabricated Authorities Are Disregarded and May Trigger Sanctions

Introduction

In Jarvis v. County of Teton Wyoming (10th Cir. Apr. 24, 2026) (unpublished “Order and Judgment”), pro se plaintiff Ryan-Michael Jarvis appealed the dismissal of his federal civil-rights suit arising from his arrest and overnight detention following a dispute at a music festival in Teton County, Wyoming.

After officers received witness accounts that Jarvis had acted aggressively, touched women, and threatened that he had a gun, he was detained, searched multiple times, arrested without a warrant, booked into jail, and released the next day after posting bail. He was later cited with two misdemeanors; the prosecution was ultimately dismissed. Jarvis then sued Teton County, the District Attorney (Andrew Hardenbrook), and multiple sheriff’s department officers under 42 U.S.C. § 1983 (plus other federal statutes). The district court dismissed under Rule 12(b)(6), allowed amendment as to some claims, and warned that failure to amend would convert the dismissal to one with prejudice.

The appeal presented (1) an appellate jurisdiction question stemming from the district court’s “dismiss-with-leave-to-amend” procedure and lack of a separate final judgment, and (2) the merits of Jarvis’s challenges to dismissal of his § 1983 official-capacity and individual-capacity claims, including defenses of Monell pleading failure, absolute prosecutorial immunity, and qualified immunity. Notably, the panel also addressed apparent fabricated quotations/case propositions likely generated through a generative AI tool, explicitly warning litigants to verify citations.

Summary of the Opinion

Jurisdiction: The court held it had appellate jurisdiction notwithstanding the absence of a separate final judgment, reasoning the appeal ripened and the district court’s intent was objectively to end the case if Jarvis chose not to amend.
Waiver: Jarvis waived appellate review of claims not raised in his opening brief.
§ 1983 official-capacity claims: Dismissal affirmed because Jarvis failed to plausibly allege an official policy/custom and causal link required by Monell.
Claims against the District Attorney: Damages claims barred by absolute prosecutorial immunity; injunctive claims failed on the pleadings.
Claims against officers: New theories raised for the first time on appeal (a Franks claim and First Amendment retaliation) were waived; remaining Fourth/Fifth/Sixth/Eighth Amendment theories failed to plead a constitutional violation and were barred by qualified immunity.
AI-generated “hallucinations”: The court disregarded suspect fabricated citations/quotes, declined to sanction Jarvis, but issued a clear warning to all litigants about the duty to ensure cited authorities and quotations are accurate (citing 10th Cir. R. 46.5(B)(2)).

Analysis

Precedents Cited

1) Appellate finality and premature notices of appeal

Moya v. Schollenbarger, 465 F.3d 444 (10th Cir. 2006): The panel used Moya to frame finality as a functional inquiry—examining the “substance and objective intent” of the district court’s order. Moya also provides the procedural expectation that a plaintiff who chooses to stand on the complaint should notify the district court and appeal after entry of a final order. Here, despite Jarvis’s procedural misstep, the panel focused on whether the district court intended to extinguish the action if no amendment occurred.
In re Syngenta AG MIR 162 Corn Litig., 61 F.4th 1126 (10th Cir. 2023) and Fed. R. App. P. 4(a)(2): These authorities supported the conclusion that a premature notice of appeal can “ripen” when the appealed order bears indicia of finality and will likely remain unchanged. Even without a separate final judgment, the panel deemed the notice effectively timely once the amendment window passed and the order’s finality became clear.

2) Pleading standards on Rule 12(b)(6), and pro se treatment

McNellis v. Douglas Cnty. Sch. Dist., 116 F.4th 1122 (10th Cir. 2024) and Ashcroft v. Iqbal, 556 U.S. 662 (2009): The panel reaffirmed plausibility pleading: courts accept well-pleaded facts, not conclusory labels, and require factual content supporting a reasonable inference of liability.
Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836 (10th Cir. 2005): The panel applied liberal construction for pro se filings while emphasizing the court will not act as advocate or build arguments for the litigant.

3) Waiver/forfeiture doctrines on appeal

Sawyers v. Norton, 962 F.3d 1270 (10th Cir. 2020): Claims not raised in the opening brief are waived.
United States v. Leffler, 942 F.3d 1192 (10th Cir. 2019): New issues raised on appeal without requesting plain-error review are treated as waived, leading the panel to decline review of Jarvis’s newly asserted Franks and First Amendment retaliation theories.

4) Official-capacity § 1983 and Monell municipal liability

Will v. Mich. Dep't of State Police, 491 U.S. 58 (1989): The panel reiterated the conceptual point that official-capacity suits are suits against the office/government entity, not the individual.
Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978): Monell supplied the governing rule: a municipality is not liable under § 1983 on a respondeat superior theory; the plaintiff must link a constitutional violation to a policy/custom.
Lucas v. Turn Key Health Clinics, LLC, 58 F.4th 1127 (10th Cir. 2023): The panel relied on Lucas for the elements—(1) policy/custom, (2) causation, (3) deliberate indifference—and the recognized ways to show a policy/custom (formal policy; widespread practice; final policymaker decision; ratification; failure to train/supervise with deliberate indifference). Jarvis’s allegations were deemed too generalized and untethered to a countywide practice.
Regan-Touhy v. Walgreen Co., 526 F.3d 641 (10th Cir. 2008): The panel refused to consider extra-record “anecdotal evidence” Jarvis referenced for the first time on appeal.

5) Prosecutorial immunity

Pfeiffer v. Hartford Fire Ins. Co., 929 F.2d 1484 (10th Cir. 1991): The panel affirmed that prosecutors are absolutely immune from § 1983 damages for activities “intimately associated with the judicial process,” including initiating and pursuing prosecutions. Jarvis’s allegations (proceeding with prosecution, plea offer, continuance request) fell squarely within protected advocacy functions.

6) Qualified immunity framework

VDARE Found. v. City of Colo. Springs, 11 F.4th 1151 (10th Cir. 2021): The panel restated the two-step inquiry at the motion-to-dismiss stage: (1) plausibly alleged constitutional violation, and (2) clearly established law at the time. The court affirmed dismissal because Jarvis did not plead facts sufficient to establish a constitutional violation; thus qualified immunity applied.

7) The court’s handling of suspected AI-fabricated authority

Spinelli v United States, 393 U.S. 410 (1969) abrogated by Illinois v. Gates, 462 U.S. 213 (1983): The panel noted Jarvis attributed to Spinelli a quotation the court could not locate and suggested the quote was fabricated. It also correctly situated Spinelli within the superseded Aguilar-Spinelli probable-cause framework, abrogated by Illinois v. Gates.
Meechaicum v. Fountain, 696 F.2d 790 (10th Cir. 1983): The panel similarly rejected Jarvis’s claimed “holding” as not found in the opinion.
Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025) and Jones v. Kankakee Cnty. Sheriff's Dep't, 164 F.4th 967 (7th Cir. 2026): These cases were used to underscore an emerging judicial concern: large language models can generate “fake cases” and “hallucinations” (fictional or inaccurate outputs). The panel expressly disregarded the suspect materials, declined sanctions here, but warned that litigants must ensure quotations and citations are accurate.
10th Cir. R. 46.5(B)(2): The panel anchored its warning in the professional responsibility to make truthful and accurate representations to the court. While the decision is nonprecedential, the admonition is a clear signal of increased scrutiny of AI-assisted citations.
Franks v. Delaware, 438 U.S. 154 (1978): Mentioned only because Jarvis attempted to raise a Franks-type theory for the first time on appeal; the panel refused to consider it.

Legal Reasoning

1) Jurisdiction despite lack of separate final judgment

The court confronted a procedural irregularity: the district court dismissed certain claims without prejudice, issued an “Order to Amend” stating the dismissal would convert to “with prejudice” if Jarvis did not amend within 30 days, but never entered a separate final judgment after the deadline. Applying Moya’s functional finality approach, and In re Syngenta’s ripening principle (consistent with Rule 4(a)(2)), the panel treated the notice of appeal as effectively ripe once the amendment period lapsed and the order’s “objective intent” to end the case was evident.

2) Official-capacity claims failed for lack of Monell facts

Jarvis characterized his experience as reflective of systemic failures (training, supervision, accountability) and alleged a “pattern of neglect.” But Monell liability requires more than an individual incident and conclusory assertions of systemic wrongdoing: the plaintiff must plead a specific policy/custom, a causal connection to the alleged constitutional violation, and deliberate indifference. The panel affirmed dismissal because Jarvis did not plausibly identify what Teton County’s policy/custom was or plead facts supporting a widespread practice.

3) Claims against the District Attorney were barred (damages) and inadequately pleaded (injunctive relief)

The panel affirmed absolute prosecutorial immunity for damages because Jarvis’s allegations targeted classic prosecutorial functions: continuing prosecution, making plea offers, and seeking a trial continuance. For injunctive relief, the court agreed with the district court that Jarvis failed to plead facts sufficient to support malicious prosecution or a Sixth Amendment violation.

4) Officer claims: waiver of new theories; remaining theories defeated by probable cause/qualified immunity at the pleading stage

The panel rejected newly asserted claims (including a Franks theory and First Amendment retaliation) as waived under Leffler. As to the remaining Fourth Amendment (seizure/false arrest/malicious prosecution), Fifth/Sixth Amendment, and Eighth Amendment theories, the panel affirmed on qualified immunity grounds because the complaint did not plausibly allege a constitutional violation given the witness reports and circumstances described, and because Jarvis’s arguments did not overcome the district court’s analysis.

5) Integrity of citations: the “AI hallucination” warning

A distinctive feature of the opinion is its explicit confrontation with apparent AI-generated fabrication: the panel could not locate key quotations/holdings Jarvis attributed to federal cases. The court treated this as likely “AI hallucination,” disregarded the fabricated materials, declined sanctions in this instance, and issued a forward-looking warning: parties—pro se or represented—bear responsibility for ensuring cited authorities and quotations are real and accurately characterized.

Impact

Practical litigation impact (AI use): Although nonprecedential, the decision reinforces a developing norm: courts will scrutinize suspect citations and may impose consequences for fabricated authorities. The explicit warning—tied to 10th Cir. R. 46.5(B)(2)—signals that “AI-assisted briefing” does not dilute the duty of candor/accuracy.
Municipal liability pleading discipline: The case reiterates that generalized allegations of “systemic” problems, without concrete facts showing a policy/custom and causation, will not survive Rule 12(b)(6) in the Tenth Circuit.
Immunity doctrines remain potent at the pleading stage: Absolute prosecutorial immunity and qualified immunity continue to dispose of claims early when the alleged conduct falls within protected functions or when the complaint fails to plausibly allege a constitutional violation.
Appellate procedure: The jurisdiction discussion illustrates the court’s willingness—within established doctrine—to treat some premature appeals as ripening, reducing the risk of dismissal where the district court’s intent to end the case is clear even if docket formalities lag.

Complex Concepts Simplified

Official-capacity vs. individual-capacity claims: An “official-capacity” suit is effectively against the government entity; an “individual-capacity” suit targets the official personally for damages.
Monell claim (municipal liability): A county/city is liable under § 1983 only if an unconstitutional act was caused by an official policy or a widespread custom—not merely because it employed the actor.
Absolute prosecutorial immunity: Prosecutors cannot be sued for damages under § 1983 for core prosecutorial acts (charging decisions, courtroom advocacy, plea bargaining, and case management tied to prosecution).
Qualified immunity: Government officials are shielded from damages unless the plaintiff plausibly alleges a constitutional violation and shows the violated right was “clearly established” at the time.
Rule 12(b)(6) plausibility: A complaint must include enough concrete factual detail to make liability plausible, not just possible or asserted in conclusory terms.
Waiver on appeal: If an argument is not raised in the opening brief—or is raised for the first time on appeal without the required standards of review—it is typically not considered.
AI “hallucinations” in legal filings: Sometimes generative AI produces fictitious quotations or case propositions. Courts treat those as unreliable and may sanction parties who submit them without verification.

Conclusion

Jarvis v. County of Teton Wyoming affirms the dismissal of a pro se civil-rights complaint on familiar doctrinal grounds: insufficient Monell pleading for official-capacity claims, absolute prosecutorial immunity for damages against the district attorney, and qualified immunity for officers where the complaint failed to plausibly plead a constitutional violation. Beyond the merits, the opinion’s most salient practical lesson is its explicit warning about AI-driven citation errors: litigants must verify that quotations and authorities are real and accurately presented—AI assistance does not excuse inaccuracies, and fabricated citations will be disregarded and may invite sanctions.