Aps"s 79056-09-25 Vanderberg v. Shviro (judge disqualification appeal)

Unspecified generative AI tool (suspected) no_human_verification; fake_case_citation

I. Executive Summary

The Supreme Court dismissed an appeal challenging a small-claims judge’s refusal to recuse herself. The court noted that the notice of appeal contained four purported authorities on judicial disqualification that were fictitious. It stated there was an unavoidable suspicion that the citations originated from the ‘hallucinations’ of an AI tool and stressed that parties—represented or not—must verify that cited authorities exist and support the propositions advanced. As part of the outcome, the court ordered the appellant to pay costs to the State Treasury.

II. Conduct Analysis

A self-represented appellant filed an appeal brief containing four non-existent case citations that did not match proceeding types, party names, or contents; the court attributed this to suspected AI hallucinations.

III. Legal Foundations

Courts Law (judge disqualification standard); Civil Procedure Regulations 2018 (timeliness of disqualification motions).

IV. Key Facts

Appeal concerned refusal to disqualify a small-claims judge in Rehovot. The Supreme Court identified four fictitious authorities in the appeal brief and warned against the growing phenomenon of references to invented cases.

V. Consequences & Sanction

Appeal dismissed; costs awarded to the State Treasury due to fictitious AI-generated authorities.