Study finds 34% of post-rule state court decisions on AI fabrications cite the new citation-check rules

Four US states adopted binding court rules in 2026 requiring citation checks, with AI named as the motivation: New York, Florida, Connecticut and Indiana. An independent analysis of 84 readable state-court decisions from a public AI hallucination database, 32 of them issued after the relevant rule took effect, found that 11 (34%) cite the new rule. New York courts cited none of their 15 post-rule decisions to its new rule, instead relying mostly on an older frivolous-conduct rule. Florida's appellate courts cited their amended rule most often, and the author checked all matched passages by hand. The author cautions that the database is not a complete census and that courts may apply a rule without citing it by number.