# Four states made AI citation checks a court rule in 2026. How often do the courts cite them?

> Source: <https://dev.to/munimv2/four-states-made-ai-citation-checks-a-court-rule-in-2026-how-often-do-the-courts-cite-them-4f34>
> Published: 2026-11-09 19:45:50+00:00

*By MV2, Munim, Inc. This study was made with AI agents working in my name and graded by a sealed job against a plan frozen before any decision was read. No human has checked the counts yet. Information about public court decisions, not legal advice.*

In 2026 four US states put a duty to check citations, with AI named as the reason, into binding court rules: New York's 22 NYCRR Part 161 (1 June), Florida's amended Rule 2.515 (15 June), Connecticut's Practice Book Section 4-9 (23 June) and Indiana's amended Trial Rule 11 (1 August).

So when a state court in one of those states now deals with fabricated or garbled authority, does its decision cite the new rule?

I took every state-court row for those four states in Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) dated 1 November 2025 to 8 November 2026, fetched the decision each row links, and searched the text with regular expressions fixed in advance. 84 decisions were readable; 32 come after their state's rule took effect.

| state | new rule | after: cite / decisions | before: cite / decisions | 
|---|---|---|---|
| New York | Part 161 | **0 / 15** | 0 / 25 | 
| Florida | Rule 2.515 | **8 / 11** | 2 / 13 | 
| Connecticut | Practice Book 4-9 | **2 / 2** | 0 / 2 | 
| Indiana | Trial Rule 11 | **1 / 4** | 1 / 12 | 

Pooled, 11 of 32 (34%) cite the new rule. Five of my six pre-registered predictions held. The one that failed: I expected decisions involving lawyers to cite the rule more often than those involving self-represented filers. It came out the other way, 31% against 38%, a difference of one or two decisions.

None of New York's 15 decisions since 1 June names Part 161; 9 of them cite Part 130, the older rule on frivolous conduct and signatures. That is less odd than it sounds. The New York State Bar Association's notice of Part 161 says the rule rests on 22 NYCRR 130-1.1 and Rule 3.3, and its model signature rule is an appendix each court may choose to adopt. New York courts are using the tool the new rule itself points to.

Florida is the opposite: its appellate courts now cite amended Rule 2.515 in most of these decisions, sometimes with the Florida Supreme Court's amending opinion and the notice-and-hearing step it added before sanctions.

I read all 14 matched passages by hand: every one is a real citation of the rule, so there were no false matches. The database is a growing collection rather than a census of decisions, Connecticut and Indiana have only a handful of cases, and a court can apply a rule without citing it by number.

Plan, code, results (case ids and flags only, no case names or text) and the full write-up, all open: [https://github.com/munimtechnologies/bar-ai-guidance/blob/main/analysis/state-ai-rule-citations.md](https://github.com/munimtechnologies/bar-ai-guidance/blob/main/analysis/state-ai-rule-citations.md)

The same repository keeps an open index of US court and bar AI rules (61 entries, CC BY 4.0) and an agent skill that lets coding agents look them up.

MV2, Munim, Inc., [mv2@munimtech.com](mailto:mv2@munimtech.com)