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David J Miescke v Teresa Lynn Pahl

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Case Information
Case name David J. Miescke v. Teresa Lynn Pahl[1]
Court Wisconsin Court of Appeals, District IV; Dane County Circuit Court[1]
Docket Appeal 2025AP1778; circuit court 2017FA2370[1]
Filed Exact original-action and appeal filing dates not identified in the reviewed opinion.[1]
Judge(s) Graham, Kloppenburg and Nashold (appellate panel); Rhonda L. Lanford (circuit court)[1]
Petitioner / Appellant David J. Miescke (petitioner-appellant)[1]
Respondent Teresa Lynn Pahl (respondent-respondent)[1]
Case type Family-law appeal with a caution about possible generative-AI filings[1]
Claims / issues Legal custody and physical placement orders; frivolous appeal under Wisconsin Rule 809.25(3); accuracy and privacy of possible AI-assisted submissions[1]
Status October 8, 2026: orders affirmed; costs and attorney’s fees awarded for a frivolous appeal, with amount to be assessed on remand. Opinion unpublished.[1]

David J. Miescke v. Teresa Lynn Pahl is a Wisconsin family-law appeal in which the court cautioned a self-represented litigant about possible generative-AI use in submissions. On October 8, 2026, the Court of Appeals affirmed the challenged custody and placement orders, found the entire appeal frivolous and remanded for assessment of costs and attorney’s fees.[1]

AI accuracy and confidentiality caution

In footnote 3, the court identified indicators of possible generative-AI use in appellate briefs and 2025 circuit-court filings, including false quotations, inaccurate citations and misrepresentations of the record. It warned that generative AI can produce unreliable results and that platforms may lack privacy protections for sensitive personal or confidential medical information uploaded to them. The observation is framed as possible AI use.[1]

Disposition

The court rejected the appellant’s challenges to the two 2025 custody and placement orders. It separately concluded that the entire appeal lacked a reasonable basis in law or equity: arguments mischaracterized the record, disregarded the review standard, were conclusory or lacked relevant support. It awarded costs and attorney’s fees under Wisconsin Rule 809.25(3), with the circuit court to determine the amount. The opinion states that it will not be published and identifies the limited purposes for which Wisconsin per curiam opinions may be cited.[1]

References