A Vanderburgh County business dispute has drawn statewide legal attention after an appellate brief alleged that a trial court judge cited a nonexistent Indiana case in his ruling, raising questions about judicial drafting practices and whether artificial intelligence or some other error may have played a role.
The case, Johnson v. Pugh, stems from a partnership dispute between John S. Johnson and Mark Pugh over several divisions of Alpha Organics, Inc., an Evansville-based lawn care and pest control company. After a five-day bench trial, Vanderburgh Circuit Court Judge Ryan Hatfield ruled against Johnson on all counts in an order issued in late 2025. Johnson appealed to the Indiana Court of Appeals in November 2025.
In their appellate brief filed March 6, 2026, Johnson’s attorneys at Jackson Kelly PLLC alleged that Hatfield’s order cited Bryant v. Walters, 409 N.E.2d 119 (Ind. Ct. App. 1980) — a case they contend does not exist in Indiana case law. The citation was used to support a legal conclusion concerning joint ventures and partnership formation.
Johnson’s attorneys wrote in their appellate brief that “the trial court’s Order hallucinates the Bryant case entirely.”
The brief further argues that the trial court relied on “hallucinated non-existent caselaw” and that several additional citations in the order do not support the legal propositions for which they were cited.
The issue has now become a focal point of the appeal. In a separate filing requesting oral argument, Johnson’s attorneys told the Court of Appeals that “a court’s citation to hallucinated caselaw has not been addressed by any published or unpublished Indiana decision.”
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The filing adds that oral argument would help the panel evaluate the extent to which reversal may be required when a court relies on nonexistent authority and what remedies should govern such circumstances as AI use becomes more prevalent in the legal profession.
The source of the citation error in this case has not been publicly established.
The case is now pending before a three-judge panel of the Indiana Court of Appeals consisting of Judges Weissmann, Scheele, and Senior Judge Baker. Earlier this month, the panel denied a motion to strike Johnson’s oversized brief and allowed it to remain filed.
Pugh’s response brief is due April 19.
Hatfield, a Democrat, served in the Indiana House of Representatives from 2016 to 2024 before winning election to the Vanderburgh Circuit Court bench. He has not publicly commented on the allegations raised in the appellate filings.
The case arrives as Indiana courts continue to develop guidance surrounding the use of AI tools and the importance of human verification in legal drafting, even as the precise source of the citation issue in this matter remains unclear.
A decision from the Court of Appeals is not expected before late 2026.
Disclosure: The author is acquainted with Judge Ryan Hatfield from his years serving in the Indiana General Assembly. That relationship has no bearing on the reporting or analysis in this story. AI tools assisted in the drafting of this story. All editorial decisions were made by the author.
