Kosel Equity, LLC v. MacGregor
| Field | Value |
|---|---|
| Year | 2026 |
| Jurisdiction | Connecticut Supreme Court |
| Type | State Supreme Court |
| Docket No. | SC 21184 |
Summary
On February 19, 2026, counsel for the appellant filed a memorandum responding to the Connecticut Supreme Court's questions about the use of generative AI in preparing the appellant's brief filed on January 9, 2026. An errata sheet had been filed on February 13, 2026 to correct errors in the brief.
Counsel disclosed that ChatGPT was used after initial drafting to assist with organization, formatting, and compliance with word count restrictions. Counsel stated that the AI had "intuitively made changes to the brief" that were not caught prior to filing. The errors were discovered only after reviewing the amici curiae brief filed by New Haven Legal Assistance Association, Connecticut Fair Housing Center, Connecticut Veterans Legal Center, and Center for Children's Advocacy.
Counsel self-reported the errors to the Chief Clerk on February 11, 2026, and filed the errata sheet correcting the citations and quotations.
Key Details
- Attorney: Ian G. Gottlieb, Esq. (GLG LAW LLC, Wallingford, CT)
- AI Tool Used: ChatGPT
- Purpose of AI Use: Organization, formatting, word count compliance (not legal research)
- Legal Research: Conducted via Lexis
- How Errors Were Discovered: Reviewing amici curiae brief revealed discrepancies
- Self-Reported: Yes — counsel contacted Chief Clerk to self-report before filing errata
Court's Questions and Counsel's Responses
The court ordered counsel to address five specific questions:
- Reason for errata sheet — Counsel became aware of errors and took immediate corrective action.
- Cause of errors — Failure to properly proof citations and references during review.
- When/how errors were discovered — Discovered evening of February 10, 2026 while reviewing amici curiae brief. Self-reported the next day.
- Whether AI was used — Yes. ChatGPT used for organization, formatting, and word count compliance after initial drafting.
- Verification steps — Citations and assertions were reviewed against source documents via Lexis, but counsel did not notice AI had made changes to the brief before filing.
Corrective Measures
Counsel described implementing additional pre-filing procedures including:
- Focused review of citations and quotations
- Multi-attorney review process for briefs
- Enhanced checking of AI-modified content against source materials
Primary Sources
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Related Content
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