⚡ CASE DIGEST
Riverchase LLC v. Paula Goldwyn — Court of Appeals of Kansas, 16 January 2026
Paula Goldwyn appealed a mobile home park eviction default judgment, but her appellate brief cited cases that do not exist. The Kansas Court of Appeals affirmed the eviction while Westlaw editors annotated the published opinion flagging the non-existent citations — adding another eviction case to the growing AI hallucination record.
Why it matters: AI hallucinations are now appearing in tenant-side eviction briefs. Even housing and landlord-tenant cases are not immune — and fabricated citations do not help vulnerable parties who are already facing eviction.
Category: Hallucinations & Sanctions | Jurisdiction: USA | Read time: 5 min
Case at a Glance
| Full Citation | Riverchase LLC v. Paula Goldwyn, No. 128,338 (Kan. App.) |
| Court | Court of Appeals of Kansas |
| Date of Decision | 16 January 2026 |
| Category | AI Hallucinations & Sanctions |
| Jurisdiction | USA |
| AI Tool Used | Not specified (citations identified as non-existent) |
| Judgment / Order | 2026 WL 123280 (Unpublished) |
Background
Paula Goldwyn and 86-year-old Leon Sanders held a month-to-month lease for a lot space at Riverchase mobile home park. Complications arose approximately 18 months into the tenancy, leading Riverchase to seek eviction. The district court granted a default judgment of eviction against Goldwyn after she failed to appear. Goldwyn appealed, but her appellate brief contained case citations that Westlaw editors identified as referring to cases that do not exist.
The AI Issue
The court had to assess whether the district court had abused its discretion in entering a default judgment of eviction and denying the motion to set it aside, while the published opinion contained non-existent citations in Goldwyn’s appellate briefing. The Westlaw editor’s note indicates that these citations were fabricated — consistent with AI-generated hallucinations — and have been preserved as part of the official record.
- The Kansas Court of Appeals affirmed the default judgment of eviction — the district court had not abused its discretion [eviction upheld].
- Goldwyn abandoned her second argument (failure to set aside default) by inadequate briefing [waiver].
- Westlaw editors annotated the opinion with a note that citations in the appellate brief were ‘incorrect or do not actually exist’ [AI hallucination documented].
- The case demonstrates that fabricated citations harm, rather than help, vulnerable parties who are fighting eviction [client harm].
- Housing and landlord-tenant cases are now part of the AI hallucination record [residential tenancy risk].
“Editor’s Note: This decision contains discussion of citation references that are incorrect or do not actually exist. These invalid citations appeared in the original court opinion and have been preserved as written since they are part of the official court record.”
— Westlaw Editorial Note, Riverchase LLC v. Paula Goldwyn, 2026 WL 123280
The India Angle
Indian Law Equivalent: Under Rule 15 of the Bar Council of India Rules and the Contempt of Courts Act, 1971, submitting fabricated or non-existent case citations before any Indian court constitutes professional misconduct and contempt. The duty to verify cited authorities is absolute — AI does not create an exception.
Bar Council Rules: BCI Rule 15 (duty not to mislead the court) and Rule 33 (duty to conduct cases with integrity) are directly engaged when AI-generated hallucinated citations are filed. Disciplinary proceedings before the State Bar Council can result in suspension or removal from the roll.
Practical Advice for Indian Advocates: Verify every AI-generated citation on SCC Online, Manupatra, or IndianKanoon before filing. No AI tool — ChatGPT, Claude, Gemini, or any Indian legal AI — reliably produces accurate citations. Treat AI output as a starting point for research, not a final product.
Quick Takeaways
- AI hallucinations in eviction briefs can doom a tenant’s appeal — fabricated citations weaken, not strengthen, a case.
- Westlaw’s annotation system now flags AI hallucinations in housing cases as well as complex commercial litigation.
- Indian advocates handling rent control and eviction cases under the Transfer of Property Act and State Rent Acts must verify all citations before filing.