As litigation over the American Heartland Theme Park project continues, Rick Silanskas — one of two men accused of “impersonating God” to manipulate a retired businessman — now faces accusations of using generative AI to write his legal briefs.
While lawsuits can sometimes go months without filings, Silanskas and attorneys for plaintiff Gene Bicknell kept their Northern District of Oklahoma docket busy through December.
In July, Bicknell sued Silanskas, former Mansion Entertainment Group CEO Larry Wilhite and American Heartland project leader Stephen Hedrick with claims they orchestrated a $60 million “predatory conspiracy of psychological manipulation” and a “pattern of racketeering activity” through the premise of building a $2 billion theme park near Vinita. Wilhite, a former Branson preacher, and Silanskas, whose theme park dreams had crumbled before, were accused of sending fraudulent messages to convince Bicknell they were members of the triune and that “God himself was commanding him” to finance the project.
December’s wash of filings started with an unusual request from Silanskas for a protective order against attorney Michael Nadel, which has not been granted. (Silanskas has also filed an ethics complaint against Nadel.)
Alongside motions about subpoenas for email accounts, additional allegations of generative AI use have also been raised.
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Silanskas sidestepped the initial allegations of AI use in his Dec. 16 filing, arguing his incorrect citations were “clerical errors” caused because he is representing himself.
“Plaintiff’s filing makes serious allegations that defendant used ‘fake cases’ or ‘hallucinatory’ citations. The accusations are incorrect, misleading, and intended to distract the court from the legal deficiencies in plaintiff’s subpoenas,” Silanskas wrote. “Defendant acknowledges that as a pro se litigant, some citations in the earlier reply — including certain unpublished cases and Westlaw references — may have contained inaccuracies or mis-citations arising from clerical errors, typographical error, or incomplete database references. Such issues are commonplace among pro se parties and do not constitute intentional fabrication, fraud, or Rule 11 violations.”
Ironically, a subsequent quote in Silanskas’ brief supposedly supporting his argument against sanctions appears to be fabricated as well. While the case, United States v. Venable, 666 F.3d 893 (4th Circuit 2012), does exist, the quoted phrase does not appear in the opinion. Similarly, a second quote in Silanskas’ Dec. 16 brief also appears to be fabricated and does not exist in the cited case, Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990).
The submission of legal briefs that include hallucinated case citations by pro se litigants may result in sanctions in federal court.
In his filings, Silanskas states he is living in Blue Eye, Missouri, a town best known as the home of televangelist Jim Bakker, who served five years in federal prison for America’s most infamous theme park scandal. After his release, Bakker moved to Branson in 2002, re-established Praise The Lord ministries and returned to TV. Ditching prosperity gospel for apocalypticism, Bakker has sold bulk soup buckets and promoted silver as a solution for COVID-19.
In 2008, The Jim Bakker Show moved production to Blue Eye after Bakker partnered with developer Jerry Crawford, the founder of Morningside Development LLC, to build homes and condominiums in the small community southwest of Branson near the Arkansas border.
Sometime in late 2021 or early 2022, Silanskas’ wife purchased the home, which is next to land owned by Bakker’s church. Silanskas’ father, Richard Silanskas Sr., was also a televangelist in the 1970s and the son-in-law of former Maryland State Censor Mary Avara. Silanskas Jr. claims that, in 2002, he had a vision of a girl in need, identified her using a sketch artist and adopted her from Russia.
Brief bears ‘the hallmarks of generative artificial intelligence’
Beyond his complaint against Nadel, Silanskas also filed two motions to quash subpoenas requesting access to email accounts — including the accounts allegedly used to pose as religious figures — from Yahoo and Google. Bicknell’s attorneys responded to both motions, arguing several severe procedural defects were present in Silanskas’ filings.
In between Silanskas filing his two responses, Bicknell’s attorneys filed a request to submit a supplemental brief accusing Silanskas of using generative AI to assist with writing his legal briefs and that the AI “hallucinated” several different case citations.
“The replies filed by defendant Richard M. Silanskas, Jr. in support of his motion to quash plaintiff’s subpoena to Yahoo! Inc. contains numerous fake case citations,” Nadel wrote. “The replies bear the hallmarks of generative artificial intelligence, suggesting that the citations are hallucinatory. But in any event, the citations appear to be invalid.”
The brief goes on to identify two citations that did not exist, two citations that provided the wrong case name, and four citations which misstate the holdings of law.
“Using a fake opinion to support an argument is a violation of Federal Rule of Civil Procedure 11(b)(2),” Nadel wrote. “Courts in the 10th Circuit have sanctioned ‘misrepresentations of principles of law associated with cited cases, including discussions of legal principles that simply do not appear within such decisions; … misattributions of case law to this district; and most egregiously, citations of cases that do not exist.’ Each of those defects is present in Silanskas’ replies.”
Silanskas notes ‘shocking contradiction,’ judge strikes ethics complaint
Silanskas, who is representing himself, filed an ethics complaint against Nadel, one of Bicknell’s attorneys, both with ethics investigators and the U.S. District Court for the Northern District of Oklahoma on Dec. 1.
Silanskas alleges Nadel lied about Bicknell’s condition in order to delay conducting a deposition. According to Silanskas, Nadel informed him Bicknell experienced a “severe medical event” Oct 7, was discharged with home hospice, and would be unable to sit for a deposition. On Oct 22, a letter from Bicknell’s doctor also indicated he could not sit for a deposition.
Under the header “shocking contradiction: bowling alley appearance Nov. 12, 2025,” Silanskas argues that photos of Bicknell at the Holiday Lanes Bowling Alley in Pittsburg, Kansas, showed him “smiling, upright in his wheelchair,” “socially engaging with family,” and “actively bowling.” Silanskas alleged that the photos contradicted Bicknell’s health claims. The bowling alley’s Facebook post received nearly 500 likes and more than 30 unanimously positive comments about the former Pittsburg mayor and local philanthropist.
While Silanskas noted that Bicknell had agreed to sit for a deposition Dec. 8, he argued that Nadel’s communications with him were intimidating and “caused significant emotional distress and a sense of fear for personal repercussions in the litigation.” It is unclear from court filings whether Bicknell was deposed Dec. 8.
In addition to filing the ethics complaint against Nadel, Silanskas also requested the court grant a him a protective order against the attorney that would:
- Limit their communications to written form;
- Prohibit Nadel from using “threatening, intimidating, accusatory, or coercive language” in their communications;
- Require Nadel to “exercise patience, provide clear explanation, and avoid assuming bad faith” with Silanskas;
- Require Nadel to provide clear discovery deadlines;
- Limit repeated communications;
- Bar Nadel from making statements implying dishonesty or misconduct on Silanskas’ part; and
- For the court to oversee discovery requests.
Silanskas’ main argument for the protective order appears to be that he considers Nadel rude. He alleged that Nadel’s tone on a Nov. 13 conference call made him feel “intimidated, overwhelmed, and afraid to assert himself.” Silanskas also alleges that Nadel did not respond to him communicating the death of his brother-in-law and later implied that Silanskas had lied about the death.
“This implication was deeply distressing and intimidating for an unrepresented litigant,” Silanskas wrote. “The suggestion attacked [my] integrity during a moment of grief and confusion, despite [my] acting transparently and in good faith.”
The court struck Silanskas’ filings related to the ethic complaint as an improper filing Dec. 3. Bicknell’s attorneys argued Nadel’s conduct was “run-of-the-mill” and asked the court to deny the protective order.
“As the complaint shows, this is a case with extraordinary facts. But there has been nothing extraordinary about plaintiff’s approach to discovery from Silanskas. Plaintiff’s counsel’s interactions with Silanskas have been run-of-the-mill,” attorney Amelia Fogleman wrote. “Plaintiff cannot know whether Silanskas is genuinely experiencing the range of emotions he describes, but if he is, they have not been caused by any inappropriate conduct by plaintiff’s counsel. Plaintiff’s counsel has litigated pursuant to the rules, which this court has already twice admonished Silanskas he must follow.”
