# A federal court held judicial immunity applies even if a judge 'relied wholly on artificial intelligence' to issue a ruling: Phillips v. Parlade, D. Nev., Aug. 12, 2026

> On August 12, 2026 the U.S. District Court for the District of Nevada (District Judge Gloria M. Navarro) dismissed Phillips v. Parlade with prejudice, in Case No. 2:25-cv-01464-GMN-NJK. A pro se plaintiff had sued a Nevada state family-court judge, arguing that judicial immunity should not apply because she 'unlawfully delegated her official decision-making duties when she relied wholly on artificial intelligence to issue a judicial ruling, without any discretionary human thought.' The court held that issuing a judicial ruling is a normal judicial function and that immunity applies even if that allegation were true, so the suit could not proceed in federal court. Critically, the court did NOT find that the judge used AI; the immunity holding is a matter of law reached without deciding the AI-use question. Every quote is taken verbatim from the court's own Order.

- Verification status: verified
- Case type: deployment
- Provider: U.S. District Court for the District of Nevada (District Judge Gloria M. Navarro; Report and Recommendation by Magistrate Judge Nancy J. Koppe). Defendant: Mari Parlade, a Nevada state family-court judge
- Client: U.S. District Court for the District of Nevada — T. Matthew Phillips v. Mari Parlade, Case No. 2:25-cv-01464-GMN-NJK, Order (Document 16), filed August 12, 2026, District Judge Gloria M. Navarro, legal (named)
- Sector: legal / US / cross
- Verified on: 2026-09-07
- Canonical URL: https://theinternetninja.com/stories/phillips-v-parlade-d-nev-judicial-immunity-ai-wholly-relied-ruling-dismissed-2026/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| Suit dismissed with prejudice on judicial immunity: the court held a state judge is entitled to absolute immunity even if she 'relied wholly on artificial intelligence to issue a judicial ruling' (Order, Doc 16, D. Nev. Case 2:25-cv-01464-GMN-NJK, filed Aug. 12, 2026, Judge Navarro; Tier 1 primary) |  |  |
| The court reached the immunity question as a matter of law and did NOT find that the judge actually used AI; the AI-use allegation was never adjudicated (Doc 16, primary; Reason/Volokh; Above the Law, Tier 2) |  |  |
| The Report and Recommendation of Magistrate Judge Nancy J. Koppe (ECF No. 6) was accepted and adopted in part on judicial immunity; the court declined to reach Rooker-Feldman and denied the plaintiff's Request for Judicial Statement of Decision as moot (Doc 16, primary) |  |  |

## Verification method

Every load-bearing quote is taken verbatim from the court's own Order (Document 16, D. Nev. Case No. 2:25-cv-01464-GMN-NJK, filed August 12, 2026, District Judge Gloria M. Navarro), fetched from CourtListener RECAP this session and saved to sources/order-doc16-dnev-2cv01464-20260812.pdf (Tier 1 primary; archived Wayback 20260828063643). The holding and its scope are corroborated by two independent secondaries: Reason (The Volokh Conspiracy, Eugene Volokh, Aug. 17, 2026; archived Wayback 20260906213049) and Above the Law (Joe Patrice, Aug. 18, 2026; saved to sources/). The AI-use allegation is reported as the plaintiff's unproven claim, never a judicial finding. No confirmation was sought from either party; a court order is independent of both. Date of verification: September 6, 2026.

## FAQ

**What did the court decide in Phillips v. Parlade?**

On August 12, 2026 the U.S. District Court for the District of Nevada dismissed the case with prejudice, holding that a state judge is entitled to absolute judicial immunity even if she 'relied wholly on artificial intelligence to issue a judicial ruling.' Issuing a ruling is a normal judicial function, so the suit could not proceed in federal court.

**Did the court find that the judge actually used AI?**

No. The court reached the immunity question as a matter of law and expressly did not decide whether any AI was used. As Reason's Eugene Volokh put it, 'even if the allegations are correct and she had indeed relied entirely on AI,' the judge could not be sued for it in federal court. Above the Law reported the AI-use allegation rested on thin circumstantial claims about how the judge read from a prepared script.

**So can a judge outsource decisions to AI now?**

The ruling does not say that. It holds only that federal judicial-immunity doctrine bars a civil damages suit against the judge over such an allegation. The order notes such objections can still be raised on appeal in state court or through state judicial-discipline proceedings; it does not license judges to delegate decisions to software.

## Full case file

**Verification status: CHECKING — the adjudicated fact (the Aug. 12, 2026 dismissal on judicial immunity) is quoted verbatim from the court's own Order, a primary record independent of both parties. The premise that the state judge actually used AI is an unproven allegation the court never decided, and is flagged as such below.**

## The problem
This is a case about what happens, legally, when a litigant accuses a judge of handing her decision to a machine. Plaintiff T. Matthew Phillips sued a Nevada state family-court judge in federal court and argued that judicial immunity should not protect her. As the Order recounts, "Plaintiff first objects to the judicial immunity analysis of the R&R arguing that judicial immunity does not apply in this matter because Defendant unlawfully delegated her official decision-making duties when she relied wholly on artificial intelligence to issue a judicial ruling, without any discretionary human thought, such that her actions cannot be considered a 'judicial act'" ([source](https://storage.courtlistener.com/recap/gov.uscourts.nvd.176224/gov.uscourts.nvd.176224.16.0.pdf)). He pushed the theory further, contending "that because Defendant delegated 100% of her decision-making duties, the rulings were in clear absence of all jurisdiction" ([source](https://storage.courtlistener.com/recap/gov.uscourts.nvd.176224/gov.uscourts.nvd.176224.16.0.pdf)).

## What was built
There is no technology deployment to describe here: the "build" is a federal Order resolving whether a judge can be sued for allegedly relying on AI. The procedural posture is a Report and Recommendation. "Pending before the Court is the Report and Recommendation ('R&R') by Magistrate Judge Nancy J. Koppe, (ECF No. 6), recommending that this case be dismissed with prejudice," reviewed de novo after the plaintiff filed an objection ([source](https://storage.courtlistener.com/recap/gov.uscourts.nvd.176224/gov.uscourts.nvd.176224.16.0.pdf)). The court applied the settled framework for judicial immunity, under which "Judges enjoy absolute immunity from civil liability, even if their action was in error, done maliciously, or in excess of their authority," and immunity fails only where "the challenged conduct is accompanied by a clear absence of all jurisdiction or where the challenged conduct is not judicial in nature" ([source](https://storage.courtlistener.com/recap/gov.uscourts.nvd.176224/gov.uscourts.nvd.176224.16.0.pdf)).

## The outcome
The court dismissed the suit. Applying the four-factor test for whether an act is judicial in nature, it held: "Here, Plaintiff alleges that Defendant issued a judicial decision in his state court case by relying wholly on artificial intelligence. Issuing a judicial ruling is clearly a normal judicial function and the controversy at issue centered around Plaintiff's state court case pending before Defendant" ([source](https://storage.courtlistener.com/recap/gov.uscourts.nvd.176224/gov.uscourts.nvd.176224.16.0.pdf)). Because the plaintiff offered "no case law or authority to support a finding that the challenged conduct was accompanied by a clear absence of all jurisdiction," the court concluded that "Defendant is entitled to judicial immunity and this case must be dismissed" ([source](https://storage.courtlistener.com/recap/gov.uscourts.nvd.176224/gov.uscourts.nvd.176224.16.0.pdf)). It adopted the magistrate judge's recommendation in part: "IT IS HEREBY ORDERED that the R&R, (ECF No. 6), is ACCEPTED AND ADOPTED IN PART. The Court accepts the portions of Magistrate Judge Koppe's R&R addressing judicial immunity but declines to reach the issue of Rooker-Feldman. IT IS FURTHER ORDERED that Plaintiff's Complaint is DISMISSED with prejudice" ([source](https://storage.courtlistener.com/recap/gov.uscourts.nvd.176224/gov.uscourts.nvd.176224.16.0.pdf)).

The scope of the holding matters as much as the result. The court decided the immunity question as a matter of law and never found that the judge in fact used AI. Reason's Eugene Volokh, flagging the decision, drew the line precisely: "even if the allegations are correct and she had indeed relied entirely on AI in making her decision, she can't be sued for that in federal court," while noting that such objections "can of course be raised on appeal to a state appellate court" or "in state court disciplinary proceedings" ([source](https://reason.com/volokh/2026/08/17/judges-allegedly-relying-wholly-on-ai-in-order-is-covered-by-judicial-immunity-court-rules/)).

## The evidence behind the claim
The load-bearing document is the court's own Order, which is independent of both parties, and every quote above is drawn from it. What the Order does NOT contain is any finding that the judge used artificial intelligence: that is the plaintiff's allegation, recited so the court can test the legal theory, not an adjudicated fact. Independent reporting underscores how thin the underlying accusation was. Above the Law's Joe Patrice wrote: "To be clear, the judge probably did not let AI decide this case. The plaintiff sued Nevada family court judge Mari Parlade, accusing her of farming out her opinion to AI based on the judge reading from a prepared script, stumbling over a word while reading it, and accidentally uttering 'appearance of any impartiality' when reading 'appearance of impropriety.' That's not particularly robust gruel" ([source](https://abovethelaw.com/2026/08/judicial-immunity-still-applies-even-if-the-judge-let-ai-decide-the-case/)).

**Weakest load-bearing source:** the AI angle itself. The only settled, verifiable facts are the legal ones, that the court dismissed the case with prejudice on judicial immunity, and that immunity would apply even if the AI allegation were true. Whether any AI was actually used is unproven, and both independent secondaries stress that the allegation rests on circumstantial inference rather than evidence ([source](https://abovethelaw.com/2026/08/judicial-immunity-still-applies-even-if-the-judge-let-ai-decide-the-case/)). Read this as a ruling about the reach of judicial immunity in the AI era, not as proof that a judge outsourced a decision to a machine.

## How this was verified
Method: every load-bearing quote was taken verbatim from the court's own Order (Document 16, D. Nev. Case No. 2:25-cv-01464-GMN-NJK, filed August 12, 2026, signed by District Judge Gloria M. Navarro), fetched from CourtListener RECAP this session and saved to `sources/order-doc16-dnev-2cv01464-20260812.pdf` (Tier 1, primary; archived at Wayback 20260828063643). The holding and its scope are corroborated by two independent secondaries: Reason (The Volokh Conspiracy, Eugene Volokh, Aug. 17, 2026; archived at Wayback 20260906213049) and Above the Law (Joe Patrice, Aug. 18, 2026). The AI-use premise is reported throughout as the plaintiff's unproven allegation, not a judicial finding. No confirmation was sought from either party; a court order is independent of both. Date of verification: September 6, 2026.

## Related case files
- [Prososki v. Regan: the Nebraska Supreme Court struck an AI-fabricated brief and referred the lawyer for discipline, the state disciplinary route this Order says remains open even though the federal suit fails](/stories/prososki-v-regan-nebraska-supreme-court-lake-ai-fictitious-citations-brief-struck-appeal-dismissed-discipline-referral-2026/)
- [Kjoller v. Superior Court: the California Supreme Court directed an order to show cause over AI-fabricated citations, a court disciplining conduct the immunity bar leaves to oversight rather than civil suit](/stories/kjoller-v-superior-court-cal-supreme-court-s293723-nevada-county-da-jesse-wilson-ai-fabricated-citations-osc-directed-2026/)
- [Deutsche Bank v. Letennier: the first New York appellate sanction for AI-fabricated citations, a court confronting AI misuse inside its own record](/stories/deutsche-bank-v-letennier-nyad-3d-dept-fisher-10000-ai-fabricated-citations-first-ny-appellate-sanction-2026/)

## Sources
1. U.S. District Court, District of Nevada · Phillips v. Parlade, Case No. 2:25-cv-01464-GMN-NJK, Order (Document 16) · August 12, 2026 · https://storage.courtlistener.com/recap/gov.uscourts.nvd.176224/gov.uscourts.nvd.176224.16.0.pdf — **Tier 1 (primary court record)**
2. Reason (The Volokh Conspiracy), Eugene Volokh · "Judge's Allegedly 'Relying Wholly' on AI in Order Is Covered by Judicial Immunity, Court Rules" · August 17, 2026 · https://reason.com/volokh/2026/08/17/judges-allegedly-relying-wholly-on-ai-in-order-is-covered-by-judicial-immunity-court-rules/ — **Tier 2 (independent legal commentary)**
3. Above the Law, Joe Patrice · "Judicial Immunity Still Applies Even If The Judge Let AI Decide The Case" · August 18, 2026 · https://abovethelaw.com/2026/08/judicial-immunity-still-applies-even-if-the-judge-let-ai-decide-the-case/ — **Tier 2 (independent press)**