Felix, J.
Statement of the Case
In the order dissolving the marriage of Bethany Cingel and Gregory Ferreri, the trial court awarded the parties joint legal custody and Ferreri primary physical custody of their two children, and it denied Cingel’s request to relocate with the children. The trial court also denied Cingel’s subsequent motion to correct error. Cingel now appeals and raises several issues for our review regarding the trial court’s decisions on custody, relocation, and the motion to correct error, but Cingel has waived her argument due to her significant noncompliance with Indiana Appellate Rule 46. Waiver notwithstanding, Cingel’s arguments are without merit.
We affirm.
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Cingel Has Waived Her Appellate Claims by Failing to Substantially Comply with the Indiana Appellate Rules
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The purpose of our appellate rules—especially Appellate Rule 46 governing the content of briefs—“is to aid and expedite review and to relieve the appellate court of the burden of searching the record and briefing the case.”….
Cingel fails to provide citations to the record for numerous statements of fact in her Statement of Case, and Statement of Facts, as required by Appellate Rules 46(A)(5) and 46(A)(6)(a), respectively. To the extent Cingel does provide citations to the record, many of those citations are to individual documents rather than the record. [Footnote omitted.] While these failures alone likely would not have significantly impeded our review of Cingel’s appellate claims, her reliance on nonexistent legal authorities as well as her incorrect citations to and descriptions of other legal authorities did significantly impede our review.
Cingel cites 23 legal authorities in her Argument: 12 Indiana cases, 6 Indiana statutes, and 5 Indiana rules. Of those 23 legal authorities, 14 do not exist. The 14 nonexistent authorities include 11 cases, 2 statutes, and 1 trial rule.
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Of the nine legal authorities Cingel cites that do exist, six are incorrectly cited or described…
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Given Cingel’s citations to nonexistent legal authorities and to real legal authorities that have nothing to do with the propositions they purport to support, it is likely that Cingel used generative artificial intelligence to draft her brief, either in whole or in part. “Citations to fictitious, AI-generated authority is a growing problem nationwide. Courts have sanctioned both attorneys and pro se litigants for including them in briefs.”…
Waiver notwithstanding, even if we were able to move past all these procedural deficiencies, Cingel’s unsupported arguments are groundless….
Cingel’s briefing errors are significant and substantially impeded our review of her claims, so her claims are waived. Waiver notwithstanding, Cingel’s claims are without merit. We therefore affirm the trial court on all issues raised.
Affirmed.
Vaidik, J., and Tavitas, J., concur.