Regulating Generative AI in Appellate Practice: Commentary on Moore v. City of Del City (10th Cir. Dec. 3, 2025)

I. Introduction

The Tenth Circuit’s per curiam order in Moore v. City of Del City, No. 25‑6002 (10th Cir. Dec. 3, 2025), is a relatively routine employment-discrimination appeal on its face, but it stands out as an important early appellate decision on the use of generative artificial intelligence (“GenAI”) in litigation.

Substantively, the court affirms dismissal of a pro se plaintiff’s Title VII and ADEA claims as time-barred because she failed to timely file an EEOC charge. Procedurally, the court holds that she waived appellate review by failing to challenge that dispositive ground in her opening brief.

The opinion’s broader significance lies in its sanctions analysis. The court:

Identifies eleven case citations in the appellant’s brief that refer to non-existent decisions and additional citations that misrepresent the cited authorities;
Attributes these errors to the “hallucinations” of GenAI tools and the appellant’s failure to verify the citations;
Imposes alternative dismissal of the appeal as a sanction; and
Orders that in all future filings in the Tenth Circuit, the appellant must:
- state, under penalty of perjury, whether she used any GenAI tool; and
- verify that all case citations refer to actual, existing decisions.

The court also warns all future litigants, pro se and represented, that dismissal, monetary sanctions, and fee awards may be appropriate sanctions when fabricated case law or clear misrepresentations of law arise from unverified use of GenAI. Although issued as a nonprecedential “order and judgment,” the decision is likely to be cited widely for its persuasive authority on GenAI regulation in appellate practice.

II. Factual and Procedural Background

A. Underlying Employment Dispute

Plaintiff–appellant Rashonna Moore sued her employer, the City of Del City, in Oklahoma state court. She alleged:

Federal claims of race discrimination under Title VII of the Civil Rights Act of 1964;
Federal claims of age discrimination under the Age Discrimination in Employment Act of 1967 (ADEA); and
Additional claims under Oklahoma state law.

The City of Del City removed the case to the United States District Court for the Western District of Oklahoma and moved to dismiss. It sought:

Dismissal of the entire complaint for improper service;
Dismissal of the Title VII and ADEA claims for failure to file a timely charge with the Equal Employment Opportunity Commission (EEOC); and
Dismissal of the state-law claims on various state-law grounds.

B. District Court Ruling

The district court assumed, for the sake of argument, that service might have been proper and focused instead on the administrative exhaustion requirement for Title VII and ADEA claims.

Under:

42 U.S.C. § 2000e‑5(e)(1) (Title VII); and
29 U.S.C. § 626(d)(1)(B) (ADEA),

a plaintiff in a deferral state (like Oklahoma) must file an EEOC charge within 300 days of the alleged discriminatory act. The Tenth Circuit’s earlier decision in Daniels v. United Parcel Serv., Inc., 701 F.3d 620, 628 (10th Cir. 2012), characterized Title VII and ADEA claims as time-barred if the charge is not filed within those statutory limits.

The district court concluded that Moore’s EEOC charge was not filed within the required 300 days. The court therefore:

Dismissed the Title VII and ADEA claims under Fed. R. Civ. P. 12(b)(6) for failure to state a claim (because the claims were time-barred); and
Declined supplemental jurisdiction over the remaining state-law claims, remanding them to the state court.

Moore appealed.

C. Issues on Appeal

On appeal, Moore, proceeding pro se, did not challenge the district court’s determination that her EEOC charge was untimely. Rather, she:

Argued that her civil action in federal court was filed within the statute of limitations, and
Suggested that even if her action were untimely, equitable tolling might apply.

The Tenth Circuit immediately notes that:

Whether the civil action itself was timely filed is irrelevant to the district court’s actual basis for dismissal; and
The dispositive issue was the untimeliness of the EEOC charge.

Moore’s failure to confront that basis directly in her opening brief set the stage for a holding of appellate waiver.

A second, and ultimately more consequential, issue emerged during the appellate process: the court identified eleven case citations in Moore’s brief that corresponded to no known decisions in Westlaw, and two additional citations that did not stand for the propositions she claimed. The court suspected these were “AI hallucinations” generated by GenAI tools and issued a show-cause order.

III. Summary of the Court’s Opinion

A. Disposition of the Employment Claims

The Tenth Circuit, reviewing the Rule 12(b)(6) dismissal de novo (citing Albers v. Bd. of Cnty. Comm’rs, 771 F.3d 697, 700 (10th Cir. 2014)), affirms the district court’s judgment for “substantially the same reasons” articulated in the lower court’s January 8, 2025 order.

The court holds that:

Moore did not timely file an EEOC charge within the 300‑day statutory window, making her Title VII and ADEA claims time-barred;
In her opening brief, she failed to address that basis for dismissal at all; and
By omitting any challenge to the untimeliness ruling, Moore waived appellate review of the Title VII and ADEA dismissals.

Accordingly, the court affirms the dismissal of the federal discrimination claims and the district court’s remand of the state-law claims.

B. Sanctions for Misuse of Generative AI

In an extensive section titled “Misuse of GenAI,” the court:

Describes the discovery of eleven non-existent cases and two misattributed authorities in Moore’s appellate brief;
Notes that it ordered Moore to:
- Provide accurate copies of the eleven cases or explain their inclusion;
- Explain the misattribution of the other two cases;
- Identify any AI tools, prompts, and outputs used; and
- Show cause why sanctions should not be imposed under the court’s inherent power or Fed. R. App. P. 38.
Observes that Moore missed the court’s response deadline, did not acknowledge the delay, and submitted a notarized but unsworn (not “under penalty of perjury”) response;
Concludes, after considering her response, that the dubious citations were indeed GenAI hallucinations or similar fabrications; and
Notes that Moore’s attempt to justify citation inconsistencies itself included yet another fabricated case, “Cohen v. United States, 201 F.3d 109 (2d Cir. 2000),” which proved to be non-existent.

The court holds that Moore’s conduct—her failure to verify that the eleven case citations and the “Cohen” citation corresponded to real decisions, and her failure to confirm that two real cases stood for the propositions cited—constitutes sanctionable misuse of GenAI. Citing Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024), the court characterizes reliance on fake opinions as “an abuse of the adversary system.”

Invoking its inherent power (citing Mann v. Boatright, 477 F.3d 1140, 1150 (10th Cir. 2007)) and its authority to dismiss appeals for failure to comply with appellate rules (citing MacArthur v. San Juan Cnty., 495 F.3d 1157, 1161 (10th Cir. 2007)), the court:

Dismisses Moore’s appeal in the alternative as a sanction for misuse of GenAI and violation of Fed. R. App. P. 28(a)(8)(A); and
Orders that, in any future filings in the Tenth Circuit, Moore must:
- State, under penalty of perjury, whether she used a GenAI tool; and
- Verify that all case citations refer to actual, existing cases.

The court warns that:

Any future filing by Moore that does not comply with this requirement will be stricken; and
For all future litigants, pro se or represented, outright dismissal, monetary sanctions, or fee awards may be appropriate where fabricated case citations or clear misrepresentations of law are caused by unsupervised GenAI use.

C. In Forma Pauperis and Fees

Finally, the court grants Moore’s motion to proceed on appeal without prepayment of costs or fees, but clarifies that 28 U.S.C. § 1915(a)(1) excuses only the prepayment of fees. It orders that Moore remains obligated to pay the full appellate filing and docketing fees immediately to the district court, underscoring that in forma pauperis status does not extinguish the underlying fee obligation.

IV. Detailed Analysis

A. Precedents and Statutory Framework

1. Timeliness of EEOC Charges: Daniels and the Statutes

The timeliness analysis rests on the interplay of:

42 U.S.C. § 2000e‑5(e)(1) (Title VII), and
29 U.S.C. § 626(d)(1)(B) (ADEA).

In deferral states such as Oklahoma, these provisions generally require a charge of discrimination to be filed with the EEOC within 300 days of the allegedly discriminatory act. In Daniels v. United Parcel Serv., Inc., 701 F.3d 620, 628 (10th Cir. 2012), the Tenth Circuit held that a Title VII or ADEA charge “not filed within these statutory limits is time barred.”

The opinion notes that Daniels has been “abrogated in part on other grounds” by Muldrow v. City of St. Louis, 601 U.S. 346 (2024), but that abrogation concerns other aspects of Title VII law, not the charge-filing deadline itself. The basic principle that untimely EEOC charges bar later Title VII/ADEA claims remains intact.

2. Standard of Review and Pro Se Construction

Albers v. Bd. of Cnty. Comm’rs, 771 F.3d 697, 700 (10th Cir. 2014), is cited for the proposition that a Rule 12(b)(6) dismissal is reviewed de novo. This means the appellate court applies the same standard as the district court, without deference to the lower court’s legal conclusions.
Yang v. Archuleta, 525 F.3d 925, 927 n.1 (10th Cir. 2008), is invoked for the familiar proposition that pro se pleadings are construed liberally, but courts cannot act as the litigant’s advocate.

Together, these authorities frame the court’s approach: it will read Moore’s filings with some leniency, but she must still meet essential procedural obligations, including addressing the grounds for the district court’s ruling.

3. Appellate Waiver and FRAP 28: Sawyers and Grant

The court relies on Sawyers v. Norton, 962 F.3d 1270, 1286 (10th Cir. 2020), which emphasizes that “[i]ssues not raised in the opening brief are deemed abandoned or waived.” This is tied to Federal Rule of Appellate Procedure 28(a)(8)(A), requiring an appellant’s brief to contain:

“[T]he argument, which must contain: appellant’s contentions and the reasons for them, with citations to the authorities and parts of the record on which the appellant relies.”

The Tenth Circuit also cites Grant v. City of Long Beach, 96 F.4th 1255, 1257 (9th Cir. 2024), where the Ninth Circuit struck a brief and dismissed an appeal due to noncompliance with Rule 28(a)(8)(A). Grant is used to reinforce that:

Citation to supporting authority is a mandatory component of appellate advocacy; and
Failure to do so can warrant severe sanctions, including dismissal.

In Moore, the waiver doctrine and Rule 28(a)(8)(A) converge: Moore did not argue the key issue (untimely EEOC charge) and, worse, she supported her other arguments with fabricated or misrepresented authorities.

4. Sanctions, Inherent Power, and GenAI: Mann, MacArthur, Mata, Park, and Wadsworth

Mann v. Boatright, 477 F.3d 1140, 1150 (10th Cir. 2007), is central. It recognizes the court’s “inherent power to impose sanctions that are necessary to regulate its docket, promote judicial efficiency, and deter frivolous filings.” This inherent authority exists alongside, and independent of, rule-based sanctions.
MacArthur v. San Juan Cnty., 495 F.3d 1157, 1161 (10th Cir. 2007), confirms the appellate court’s “indisputabl[e]” power to dismiss an appeal when the appellant fails to follow the rules of appellate procedure.
Mata v. Avianca, 678 F. Supp. 3d 443, 448–49 (S.D.N.Y. 2023), is cited from outside the circuit as an early, widely publicized case where lawyers were sanctioned for submitting fake cases generated by an AI tool. The Tenth Circuit invokes Mata to underscore that:
- GenAI is not inherently problematic, but;
- Unverified reliance on AI-generated research can waste judicial resources, impose needless costs on opposing parties, and undermine the integrity of the justice system.
Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024), is quoted for the principle: “An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” This frames fabricated cases as a fundamental affront to adversarial adjudication, not a mere technical defect.
Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025), a district court decision within the Tenth Circuit, is cited for defining and contextualizing “AI hallucinations”:
- It notes that “AI resources generate fake cases” and that a “hallucination occurs when an AI database generates fake sources of information.”
- The Tenth Circuit uses Wadsworth to emphasize that AI hallucinations are a well-known risk in the legal community.

These precedents collectively support:

The existence of a judicial power to sanction abusive or frivolous filings;
The specific application of that power to fabricated legal authorities—including AI-generated ones;
The appropriateness of sanctions up to and including dismissal of appeals; and
A heightened expectation that litigants (and especially attorneys) will verify the existence and content of any cited authority, regardless of whether GenAI tools are used.

B. The Court’s Legal Reasoning

1. Primary Ground: Waiver of Challenge to the Timeliness Ruling

The court’s primary merits holding is straightforward: appellate waiver.

The district court’s key ruling was that Moore’s Title VII and ADEA claims were time-barred because her EEOC charge was filed outside the 300‑day statutory period.
In her opening brief, Moore never attacked this conclusion. Instead, she focused on whether her federal civil action was timely filed and whether equitable tolling might apply to that separate question.
Under Sawyers and Fed. R. App. P. 28(a)(8)(A), failure to raise an issue in the opening brief results in abandonment or waiver.

Accordingly, the court holds that Moore:

Waived appellate review of the district court’s dismissal of her Title VII and ADEA claims; and
Provided no basis for the appellate court to disturb the lower court’s reasoning.

The court therefore affirms “for substantially the same reasons” given by the district court. This is a classic application of appellate waiver doctrine.

2. Alternative Holding: Dismissal as a Sanction for Misuse of GenAI

The more novel portion of the opinion is the court’s alternative disposition—dismissal as a sanction for GenAI misuse. The reasoning unfolds in several steps:

Identification of Fabricated and Misattributed Cases.
- The court notes that eleven case citations in Moore’s brief could not be found on Westlaw and that two additional cases were cited for propositions they did not reasonably support.
- This pattern of non-existent and misattributed authorities strongly suggested the use of GenAI tools that had “hallucinated” citations.
Issuance of a Show-Cause Order.
- The court ordered Moore to:
  - Provide accurate versions of the eleven cases or explain their inclusion;
  - Explain the misattributions;
  - Identify any AI tools, prompts, and outputs used; and
  - Show cause why sanctions should not be imposed under inherent authority or Fed. R. App. P. 38.
- This step satisfies due process expectations: Moore was put on notice of the suspected misconduct and given an opportunity to respond.
Moore’s Noncompliance and Further Fabrication.
- Moore filed her response late (after the October 31 deadline) and did not acknowledge or explain the delay.
- Her response, though notarized, was not sworn under penalty of perjury, contrary to the court’s explicit order.
- Substantively, she blamed “citation inconsistencies” on variations in reporters, parallel citations, pagination, and indexing errors—characterizing these as routine quirks, not misconduct. Yet she:
  - Provided no copies of the eleven supposed cases;
  - Offered no alternative citations for them; and
  - Cited a new case, “Cohen v. United States, 201 F.3d 109 (2d Cir. 2000),” which turned out to be another non-existent decision (the citation points to a page within Kalwasinski v. Morse, 201 F.3d 103 (2d Cir. 1999)).
- This additional fabricated citation, in a filing specifically addressing the court’s concerns, effectively confirmed the court’s suspicions that Moore was using GenAI outputs without verification.
Legal Characterization of the Misconduct.
- The court stresses that there is “nothing inherently problematic” about using GenAI in legal practice.
- The principal wrong is not the mere use of AI, but rather:
  - Failure to verify that cited cases actually exist; and
  - Failure to confirm that the cases cited reasonably stand for the propositions asserted.
- These failures, the court holds, “impair judicial efficiency” and constitute noncompliance with Rule 28(a)(8)(A)’s requirement that briefs include “supporting authority.” Fabricated citations are “the antithesis of citing to supporting authority.”
- Citing Park v. Kim, the court emphasizes that relying on fake opinions is “an abuse of the adversary system,” and, echoing Mata, notes the broader harms to judicial resources, opposing parties, and public confidence in the legal system.
- The court adds a pointed observation: if Moore did not use GenAI and still fabricated citations, her conduct would be even more culpable, and the same sanctions would apply. This clarifies that the core misconduct is fabrication, regardless of the tool used.
Choice of Sanctions.
- Invoking Mann and MacArthur, the court asserts its inherent authority to sanction and its power to dismiss for procedural noncompliance.
- The court points to the Ninth Circuit’s Grant decision to illustrate that striking briefs and dismissing appeals is a recognized sanction for Rule 28 violations.
- Here, the Tenth Circuit:
  - Dismisses the appeal in the alternative to its merits affirmance as a sanction for Moore’s misuse of GenAI and noncompliance with Rule 28(a)(8)(A); and
  - Imposes a forward-looking, litigant-specific order requiring Moore to:
    - State under penalty of perjury in any future Tenth Circuit filing whether she used GenAI; and
    - Verify that every case citation refers to an actual, existing decision.
- The court further warns that future noncompliance will result in filings being stricken, and that future litigants generally may face dismissal, monetary sanctions, or fee awards for similar misconduct.

Thus, even though the appeal is already destined for affirmance due to waiver, the court uses its alternative dismissal and prospective orders to articulate a sanctions framework for GenAI misuse that is likely to shape future practice.

C. Impact and Significance

1. For Employment Discrimination and EEOC Practice

On the employment-law side, Moore reinforces several settled principles:

The 300‑day EEOC charge-filing requirement under Title VII and the ADEA is strictly enforced. Late charges typically render federal discrimination claims time-barred.
Timeliness of the civil action is conceptually and legally distinct from timeliness of the EEOC charge. A complaint filed within the statute of limitations does not salvage a claim if the underlying EEOC charge was untimely.
Appellants must directly attack the specific grounds on which their claims were dismissed; general appeals to fairness, or arguments about other timing issues, will not suffice.

Although the opinion does not delve into equitable tolling of EEOC deadlines (because Moore did not properly raise the issue), the case illustrates how a failure to frame and brief the correct timeliness question can be case-dispositive.

2. For Appellate Advocacy and Pro Se Litigants

The decision sends several clear signals about appellate practice in the Tenth Circuit:

FRAP 28 is enforced rigorously. An opening brief must:
- Identify the specific errors alleged; and
- Support arguments with real, relevant authorities.
Pro se status does not excuse failure to engage the dispositive issue or to comply with basic briefing rules. The court will construe pro se filings liberally but will not rewrite or reframe arguments for the litigant.
Issue waiver remains a central constraint: arguments not made in the opening brief are lost, and attempting to pivot in later filings or at oral argument will not cure the omission.

In future cases, litigants who fail to address the specific grounds of dismissal or who rely on unsupported, generalized assertions should expect affirmances on waiver grounds, with the added possibility of sanctions if their filings are unsupported by genuine authority.

3. For Generative AI and Legal Ethics

The Moore opinion’s most novel and far-reaching implications concern GenAI. Several key points emerge:

Use of GenAI is permitted but regulated. The court explicitly acknowledges that there is nothing inherently wrong with using GenAI tools in legal practice. The problem is using them without verification.
Verification is non-delegable. Whether a party is represented by counsel or appears pro se, the responsibility to ensure that:
- Every cited case actually exists; and
- The case reasonably supports the proposition cited,
rests with the filer. GenAI outputs must be cross-checked against authoritative sources (e.g., official reporters, recognized legal databases). The court treats this as a baseline professional and procedural obligation.
Fabricated authorities are treated as serious misconduct. The opinion, following Mata and Park, aligns fabricated or hallucinated citations with abuse of the adversary system. This is not a minor formatting error; it is a substantive violation that can warrant dismissal and sanctions.
Prospective orders and individual restrictions are on the table. The court’s order that Moore, in all future Tenth Circuit filings, must:
- Declare under penalty of perjury whether she used GenAI; and
- Verify the existence of all cited cases,
functions as a targeted, prophylactic measure akin to limited prefiling restrictions for vexatious litigants. It is narrower than a full prefiling injunction but still a significant prospective constraint.
Warning to the bar and litigants generally. The court’s explicit warning that, going forward, similar GenAI-related misconduct “may” justify:
- Outright dismissal without reaching the merits;
- Monetary sanctions; and
- Attorney’s fees for the opposing party,
signals that the Tenth Circuit expects practitioners to adapt their research, drafting, and review practices to account for GenAI’s risks.

Although this particular order is marked as nonprecedential under Tenth Circuit rules, it will almost certainly be invoked for its persuasive guidance in:

Sanctions motions involving AI-generated filings;
Local or circuit-wide rulemaking on AI disclosure requirements; and
Ethics and professional-responsibility discourse on the duty of competence and candor when using advanced technologies.

4. For Access to Justice and In Forma Pauperis Litigants

The decision also touches briefly on fee obligations under 28 U.S.C. § 1915(a)(1). The court:

Grants Moore leave to proceed without prepayment of costs or fees; but
Clarifies that this statute waives only the prepayment requirement, not the underlying obligation to pay fees.

By ordering immediate payment of the full appellate fees, the court underscores an often-misunderstood aspect of in forma pauperis status: it is not a blanket waiver of all costs, particularly at the appellate level. While not the main focus of the opinion, this reminder is relevant for pro se and low-income litigants who may assume that IFP status absolves them entirely of fee responsibilities.

V. Clarifying Key Legal and Technical Concepts

A. EEOC Charge vs. Civil Complaint

EEOC Charge: An administrative complaint filed with the Equal Employment Opportunity Commission (or a state equivalent agency) alleging discrimination. Under Title VII and the ADEA, filing this charge within the statutory time limit (usually 180 or 300 days) is a prerequisite to later filing a lawsuit in court.
Civil Complaint: The lawsuit filed in federal (or state) court after the EEOC process. Even if the civil complaint is timely under general statutes of limitation, the discrimination claims can still be barred if the EEOC charge was filed late.

B. “Time-Barred” and Statutes of Limitation

A claim is “time-barred” when it is brought outside the legally prescribed time period. In this context, failing to file an EEOC charge within 300 days of the discriminatory act makes the Title VII and ADEA claims time-barred, such that they cannot proceed in court (absent some extraordinary doctrine like equitable tolling).

C. Equitable Tolling

Equitable tolling is a doctrine that can, in rare circumstances, pause or extend statutory deadlines where:

The plaintiff has been diligently pursuing their rights; and
Extraordinary circumstances beyond their control prevented timely filing.

In Moore, the court does not reach the merits of any equitable tolling argument because Moore focused on tolling the civil action rather than the EEOC charge, and she failed to challenge the specific timeliness ruling as to the charge in her opening brief.

D. Inherent Power to Sanction

Courts possess inherent powers independent of specific rules or statutes, including:

Regulating their own dockets;
Deterring and punishing abusive litigation conduct; and
Imposing sanctions, including dismissal or monetary penalties, for bad faith or abusive practices.

In Moore, this inherent power justifies the alternative dismissal of the appeal and the prospective restrictions on Moore’s future filings.

E. Appellate Waiver (Issue Abandonment)

Appellate waiver (or issue abandonment) occurs when an appellant fails to raise and argue an issue in the opening brief. Courts routinely hold that:

Arguments not made in the opening brief are deemed waived; and
Attempts to raise them in reply briefs or at oral argument come too late.

In Moore, the appellant’s failure to challenge the untimely EEOC charge in her opening brief meant the central ground of dismissal was not preserved for appellate review.

F. “GenAI Hallucinations”

The opinion adopts terminology from Wadsworth and technical literature in describing “AI hallucinations”:

GenAI tools sometimes generate plausible but false content, including citations to cases that do not exist.
These hallucinations are not random typos but fully fabricated authorities that look real enough to be convincing at first glance.

The court’s core message: lawyers and litigants must treat GenAI outputs as unverified drafts, not as authoritative sources. Every case citation must be independently checked in reliable legal databases or reporters.

G. “Order and Judgment” and Nonprecedential Status

The court notes that this is an “order and judgment,” not a formal precedential opinion. Under Tenth Circuit rules:

Such orders are not binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel; but
They may be cited for their persuasive value consistent with Fed. R. App. P. 32.1 and Tenth Circuit Rule 32.1.

Thus, while Moore does not formally bind future panels, it will likely be influential as persuasive authority and as a practical roadmap for how the Tenth Circuit will respond to GenAI-related sanctions issues going forward.

VI. Conclusion

Moore v. City of Del City is a dual-purpose decision. On the narrow merits, it is a conventional application of established law: Title VII and ADEA claims are time-barred if the EEOC charge is not filed within the statutory window, and an appellant waives review by failing to challenge that ground in her opening brief.

Its broader importance lies in its treatment of GenAI in appellate practice. The Tenth Circuit:

Explicitly recognizes the phenomenon of AI “hallucinations” producing fake case citations;
Holds that unverified reliance on such AI outputs is sanctionable misuse of GenAI;
Uses its inherent power and appellate rules to impose alternative dismissal as a sanction; and
Imposes a forward-looking verification and GenAI-disclosure requirement on the appellant, while warning all future litigants that dismissal, monetary sanctions, and fee awards may be appropriate in similar circumstances.

Although nonprecedential, Moore is likely to shape how courts, lawyers, and pro se litigants understand their obligations when using GenAI tools. The core lesson is clear: GenAI may assist in drafting, but it cannot replace the human duty to verify that every citation is real, relevant, and fairly characterized. Failing to do so risks not only the loss of a case on the merits, but also serious sanctions that can include dismissal and lasting restrictions on future filings.