Courts on AI / monthly digest
What courts said about AI in March 2026
119 court-authored documents filed this month that substantively discuss generative AI. Fabricated or misquoted citations 117 · Discovery and AI-assisted review 1 · AI-generated evidence and authentication 1.
- Rosa Maria Cabrera Thompson v. Seattle Public Schools
· U.S. District Court for the Western District of Washington · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Western District of Washington granted leave to amend only in part and ordered the plaintiff to show cause within seven days for continued citation of nonexistent authority. A self-represented party submitted a motion with fabricated or nonexistent authorities.
- Quandel Construction Group, Inc. v. Hunt Construction Group, Inc.
· U.S. District Court for the Southern District of Ohio · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Southern District of Ohio ordered counsel to explain how nonexistent citations and nonexistent quoted language entered Hunt’s briefing despite counsel’s denial that AI caused the errors. Counsel submitted a brief with The brief cited nonexistent cases and quoted language that the court could not find in any actual decision.
- Evgeny Yaroshevsky v. Karlin et al.
· U.S. District Court for the Eastern District of New York · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Eastern District of New York recommended an adverse fee award after finding Rule 11 safe-harbor compliance and repeated nonexistent or misrepresented AI-generated authorities. A self-represented party submitted a complaint with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Ramirez v. Humala, 24-CV-242.
- Edward C. Allen v. Western Governors University, et al.
· U.S. District Court for the District of Nevada · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the District of Nevada dismissed the case with prejudice and imposed nominal monetary sanctions after finding fabricated authorities, factual misrepresentations, and bad faith. A self-represented party submitted a filing with false quotations and nonexistent or mischaracterized authorities, including Christian and Warren cases the court found did not contain the quoted language.
- Jaii LeShawn Quinones v. Unknown Love, et al.
· U.S. District Court for the Eastern District of Missouri · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Eastern District of Missouri ordered the plaintiff to show cause by April 17, 2026 why Rule 11 sanctions should not issue for nonexistent cases and mischaracterized authorities. A self-represented party submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Egelhoff v. Egelhoff and Wilkerson v. Wilkerson.
- Rushing v. Rushing et al. and Christ Temple Apostolic Church-Fridley
· Minnesota Court of Appeals · Fabricated or misquoted citations
On 2026-03-31, Minnesota Court of Appeals allowed the dismissal of the appellant’s action without prejudice to stand after rejecting his challenge to the AI-citation sanction. A self-represented party submitted a complaint with fabricated or nonexistent authorities. The court resolved the merits while identifying the defective legal research.
- Ford v. Sherwin-Williams
· U.S. District Court for the District of Kansas · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the District of Kansas denied the plaintiff’s review and default motions and warned that future fabricated or incorrect legal authority could bring sanctions or dismissal. A self-represented party submitted a filing with false quotations and fabricated or nonexistent authorities, including Clark v. City of Shawnee, Kansas, No. 21-2223-EFM.
- Elbert Coleman, III; Elbert Coleman, IV v. Nexo Capital Inc.
· U.S. District Court for the Southern District of Indiana · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Southern District of Indiana granted summary judgment to the defendant and warned the self-represented plaintiffs that their contract-voiding authorities were inaccurate. A self-represented party submitted a motion with nonexistent or misstated legal provisions and fabricated or nonexistent authorities, including Kramer v. Trans-Lux Corp., 24 F.3d 1001 and Indiana Code § 23-2-1-2.
- Ella and Ramin LLC v. Travelers Insurance Company
· U.S. District Court for the Northern District of Illinois · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Northern District of Illinois denied the sanctions motion and dismissed nonparty Travelers-related defendants while noting the movant’s admitted AI use and repeated legal misstatements. A self-represented party submitted a complaint with The complaint and sanctions papers cited nonexistent or irrelevant Illinois insurance authorities while relying on admitted AI-drafted legal research.
- Feldman & Trost v. District 6 Board of Education
· U.S. District Court for the Central District of Illinois · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Central District of Illinois resolved the motion to dismiss and warned counsel that further false quotations or unsupported legal authorities could trigger sanctions. Counsel submitted a complaint with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Rost v. Steamboat Springs RE-2 Sch. Dist and Busse v. Motorola, Inc.
- Zavadovsky v. Republic of Austria, et al.
· U.S. District Court for the District of Columbia · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the District of Columbia warned the plaintiffs after cataloging fake quotations, nonexistent cases, and misrepresented holdings that appeared to be AI-generated. A self-represented party submitted a filing with fake quotations, nonexistent cases, and misrepresented procedural rules in support of strike and response arguments.
- Nguedi v. General Dynamics Information Technology
· U.S. District Court for the District of Columbia · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the District of Columbia granted judgment to the employer and rejected the plaintiff’s filings after finding inaccurate citations and unsupported legal propositions. A self-represented party submitted a filing with nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities.
- Mohamed Hussain et al. v. Mansoor Quraishi et al.
· Connecticut Superior Court · Fabricated or misquoted citations
On 2026-03-31, Connecticut Superior Court considered the special motion to dismiss without the AI-generated portions and required counsel to explain the use and extent of AI in the brief. Counsel submitted a complaint with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities.
- Christopher A. Ambrose v. Bandy X. Lee
· U.S. District Court for the District of Connecticut · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the District of Connecticut cautioned the self-represented defendant that severe AI-assisted misreadings of law could lead to sanctions under Rule 11. A self-represented party submitted a brief with fabricated or nonexistent authorities and mischaracterized authorities, including Tyler v. Tyler and Martin v. Hearst Corp.
- Leonard Colbert v. County of Riverside
· U.S. District Court for the Central District of California · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Central District of California admonished counsel after finding a false statutory quotation and no supporting case, federal or state, for the quoted language. Counsel submitted an opposition brief with multiple nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Mata v. Avianca, Inc.
- Federal Trade Commission v. James D. Noland, Jr., et al.
· U.S. District Court for the District of Arizona · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the District of Arizona denied the emergency stay request and warned the self-represented movant that future inaccurate citations may expose him to sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities, including Ghadimi v. Ariz. Bank & Trust.
- Chelsea Montes v. Suns Legacy Partners LLC
· U.S. District Court for the District of Arizona · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the District of Arizona ordered cost reimbursement, remedial AI education, and notice measures after finding counsel’s filed motion contained fake cases and quotations. Counsel submitted a motion with The motion cited fake cases and quotations, including supposed Arizona privilege authorities, that looked real but did not exist as cited.
- Hampton v. Lofton
· Arizona Court of Appeals, Division One · Fabricated or misquoted citations
On 2026-03-31, Arizona Court of Appeals, Division One affirmed and denied costs while noting that both self-represented appellate briefs contained hallucinated or unsupported citations. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities and mischaracterized authorities. The court resolved the merits while identifying the defective legal research.
- Heimkes v. Fairhope Motorcoach Resort Condominium Owners Association, Inc.
· U.S. District Court for the Southern District of Alabama · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Southern District of Alabama publicly reprimanded counsel, ordered payment of $55,597 in fees and costs, required notice in related cases, and referred the matter for discipline. Counsel submitted a filing with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities.
- Staley v. City of Elba, et al.
· U.S. District Court for the Middle District of Alabama · Fabricated or misquoted citations
On 2026-03-31, U.S. District Court for the Middle District of Alabama adopted the recommendation, dismissed claims, and noted that the plaintiff’s response and objections used nonexistent cases and false quotations. A self-represented party submitted a motion with false quotations and fabricated or nonexistent authorities, including Kidd v. Mando Am. Corp and Osorio v. Miami-Dade Cnty.
- Randel Edward Page, Jr. v. Apperson Crump
· U.S. District Court for the Western District of Tennessee · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the Western District of Tennessee denied the appeal and warned that continued nonexistent, erroneous, or misrepresentative citations after admitted AI drafting could lead to sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities.
- Edward Reynolds v. Progressive Technologies, Inc.
· U.S. District Court for the Western District of Tennessee · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the Western District of Tennessee affirmed the magistrate judge’s order and warned that continued fabricated authority could result in dismissal without further warning. A self-represented party submitted a brief with multiple fabricated or nonexistent authorities.
- Yves Hector Vimegnon v. Gallagher Bassett Services, Inc.
· U.S. District Court for the District of Oregon · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the District of Oregon declined to sanction the plaintiff for a single erroneous citation but warned that fabricated authority can lead to monetary sanctions, striking, or dismissal. A self-represented party submitted a brief with fabricated or nonexistent authorities, including Abbott v. Washington County.
- Shaun Fleck v. Del-One Federal Credit Union
· U.S. District Court for the District of Oregon · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the District of Oregon ordered screening conditions and warned that any further hallucinated legal citations would expose the plaintiff to sanctions or dismissal. A self-represented party submitted an appellate brief with The appellate brief attributed a quotation to a non-existent case and relied on that authority for a proposition not supported by real law.
- Beedemariam Kassaw v. Wal-Mart Corporation
· U.S. District Court for the Western District of New York · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the Western District of New York struck the January 2026 filings and ordered the plaintiff to submit any future request to file additional papers as a motion. A self-represented party submitted a filing with fabricated or nonexistent authorities.
- 76 Route 6 Holdings Inc. v. Town of Yorktown, NY
· U.S. District Court for the Southern District of New York · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the Southern District of New York dismissed the complaint and admonished counsel to verify quotations and authorities after finding nonexistent quotations and misstated precedent. Counsel submitted a complaint with The complaint quoted language from McEachin and Goel that the court found did not appear in those cases.
- Souza v. City of Fitchburg
· U.S. District Court for the District of Massachusetts · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the District of Massachusetts dismissed the complaint. A self-represented party submitted an opposition brief with multiple fabricated or nonexistent authorities, including Mata v. Avianca, Inc., No. 22-cv-1461 and Allbaugh v. U. of Scranton, No. 3:24-CV-2237.
- Nicole Olbera, et al. v. Tiara Sykes
· Indiana Court of Appeals · Fabricated or misquoted citations
On 2026-03-30, Indiana Court of Appeals reached the merits despite briefing defects and warned that the self-represented brief included an apparently hallucinated Indiana case. A self-represented party submitted a brief with fabricated or nonexistent authorities, including Pavan v. Smith. The warning applied to later filings in the same case.
- Williams v. Chicago Board Of Education
· U.S. District Court for the Northern District of Illinois · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the Northern District of Illinois ordered counsel to file a statement explaining the nonexistent quotations, the Engquist misstatement, and whether the same source caused other errors. Counsel submitted a response brief with two false quotations, fabricated or nonexistent authorities and mischaracterized authorities.
- Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi
· Supreme Court of Hawaiʻi · Fabricated or misquoted citations
On 2026-03-30, Supreme Court of Hawaiʻi denied the mandamus petition and warned that non-existent or hallucinated citations in a family-court filing violate the reasonable-inquiry duty. A self-represented party submitted a petition with fabricated or nonexistent authorities and mischaracterized authorities, including State v. Burdett and State v. Masaniai, 63 Haw. 354, 628 P.2d 1018.
- Jacobs v. Payward, Inc.
· U.S. District Court for the District of Connecticut · Fabricated or misquoted citations
On 2026-03-30, U.S. District Court for the District of Connecticut admonished the plaintiff that hallucinated citations and excessive exhibits waste judicial resources and undermine the validity of his filings. A self-represented party submitted a brief with The brief relied on hallucinated or irrelevant CUTPA authorities, including Hottle and Wyndham citations that did not support the propositions asserted.
- Morgan v. V2X, Inc.
· U.S. District Court for the District of Colorado · Discovery and AI-assisted review
On 2026-03-30, the District of Colorado amends a protective order in an employment case involving a pro se plaintiff’s AI use. The court protects party work product, requires disclosure of the AI platform used with confidential information, and bars uploads to tools lacking contractual safeguards.
- Danuta Dec v. Homeland Security
· U.S. Court of Appeals for the Seventh Circuit · Fabricated or misquoted citations
On 2026-03-30, U.S. Court of Appeals for the Seventh Circuit admonished counsel for non-existent citations and a false quotation, but declined monetary sanctions because counsel accepted responsibility and showed contrition. Counsel submitted a brief with false quotations and fabricated or nonexistent authorities, including Jones v. Kankakee Cnty. Sheriff’s Dep’t and In re Nwaubani.
- Amtrust North America o/b/o Justin McGinness v. Liberty Mutual Insurance Company
· Superior Court of New Jersey, Appellate Division · Fabricated or misquoted citations
On 2026-03-27, Superior Court of New Jersey, Appellate Division affirmed in part, remanded for dismissal without prejudice, and imposed a $1,000 personal sanction on appellate counsel. Counsel submitted an appellate brief with The appellate brief cited four fabricated insurance cases that resembled real reporter citations but did not exist.
- Pizzimenti v. City of Detroit, et al.
· U.S. District Court for the Eastern District of Michigan · Fabricated or misquoted citations
On 2026-03-27, U.S. District Court for the Eastern District of Michigan dismissed the claims and warned that factitious citations in the complaint and motion could be treated as AI-created hallucinations. A self-represented party submitted a complaint with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Williams v. City of Cleveland, No. 1:18-CV-2911 and Jensen v. Utah Cnty.
- Patrick C. Shaltry, I v. Brent Benzing, et al.
· U.S. District Court for the Eastern District of Michigan · Fabricated or misquoted citations
On 2026-03-27, U.S. District Court for the Eastern District of Michigan warned the plaintiff that repeated false quotations and citations, including apparent AI hallucinations, would lead to sanctions for future violations. A self-represented party submitted an appellate brief with several false quotations and fabricated or nonexistent authorities, including People v. Swafford and People v. Kennedy.
- Anthony Wallace v. PennyMac Loan Services, LLC, et al.
· U.S. District Court for the District of Nevada · Fabricated or misquoted citations
On 2026-03-26, U.S. District Court for the District of Nevada granted amendment in part, denied the motion to dismiss as moot, and warned that fake AI-drafted cases must be verified. A self-represented party submitted a complaint with false quotations and fabricated or nonexistent authorities.
- Baker v. Rastelli Foods LLC
· U.S. District Court for the District of New Jersey · Fabricated or misquoted citations
On 2026-03-26, U.S. District Court for the District of New Jersey dismissed the patent claims without prejudice and required plaintiffs to provide PDFs and highlighted support for cited cases before amendment. A self-represented party submitted an opposition brief with multiple false quotations and fabricated or nonexistent authorities.
- Curry v. Capital One Auto Finance
· U.S. District Court for the Eastern District of North Carolina · Fabricated or misquoted citations
On 2026-03-26, U.S. District Court for the Eastern District of North Carolina denied leave to amend because the proposed amended complaint’s additional fabricated citations showed bad faith and amendment would be futile. A self-represented party submitted a complaint with nonexistent or misstated legal provisions and fabricated or nonexistent authorities.
- The Advocates for Human Rights and L.H.M. v. U.S. Department of Homeland Security, et al.
· U.S. District Court for the District of Minnesota · Fabricated or misquoted citations
On 2026-03-26, U.S. District Court for the District of Minnesota rejected defendants’ heightened-injunction argument after identifying misquotations and miscites in their brief and receiving unsatisfactory explanations at the hearing. Counsel submitted a brief with false quotations. The remedy followed the citation failures in that filing.
- Mission Critical Project Services, Inc.
· U.S. Government Accountability Office · Fabricated or misquoted citations
On 2026-03-26, U.S. Government Accountability Office warned the protester that future filings with non-existent authority may result in sanctions after reviewing erroneous AI-like citations. Counsel submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities. The warning applied to later filings in the same case.
- State National Insurance Company, Inc. v. Damon Treadwell, et al.
· U.S. District Court for the Northern District of Alabama · Fabricated or misquoted citations
On 2026-03-26, U.S. District Court for the Northern District of Alabama publicly reprimanded counsel and ordered notice of the reprimand after counsel admitted ChatGPT and OpenCase produced made-up quotations. Counsel submitted a filing with false quotations and fabricated or nonexistent authorities, including Co. v. Houston National Bank and Whelan v. Abell.
- Hong Chris Lu v. Capital One, N.A., et al.
· U.S. District Court for the Northern District of Ohio · Fabricated or misquoted citations
On 2026-03-25, U.S. District Court for the Northern District of Ohio dismissed the case with prejudice and treated the repeated fake cases in successive filings as a factor supporting dismissal. A self-represented party submitted an opposition brief with fabricated or nonexistent authorities.
- Fecteau v. Safety National Casualty Corporation
· U.S. District Court for the Southern District of New York · Fabricated or misquoted citations
On 2026-03-25, U.S. District Court for the Southern District of New York imposed Rule 11 sanctions for repeated arguments that included fictitious statutory language and false legal support. A self-represented party submitted a complaint with one nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Conroy v. Aniskoff.
- Elilton Alves Gouveia v. Meridian Financial Investments
· Florida Fourth District Court of Appeal · Fabricated or misquoted citations
On 2026-03-25, Florida Fourth District Court of Appeal cautioned the self-represented appellant, in prose and a limerick, that future briefs with nonexistent cases may invite sanctions. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities and mischaracterized authorities, including In re Kenney, 2025-0389.
- Jared Ashcraft v. First-Citizens Bank and Trust Company, et al.
· U.S. District Court for the Central District of California · Fabricated or misquoted citations
On 2026-03-25, U.S. District Court for the Central District of California denied the motion for discovery sanctions and advised that false citations in future briefs may result in sanctions. A self-represented party submitted a complaint with The complaint cited a nonexistent Plantronics decision while seeking discovery sanctions.
- Michael A. DeVita v. Midtown Motors, et al.
· U.S. District Court for the Middle District of Alabama · Fabricated or misquoted citations
On 2026-03-25, U.S. District Court for the Middle District of Alabama dismissed the complaint without prejudice and warned that hallucinated citations and shotgun pleading defects did not state a claim. A self-represented party submitted a complaint with fabricated or nonexistent authorities, including Lipham v. General Motors LLC and Zinnerman v. Williams.
- Jorge A. Zea v. National Association of REALTORS
· U.S. District Court for the Southern District of Florida · Fabricated or misquoted citations
On 2026-03-24, U.S. District Court for the Southern District of Florida recommended dismissal without prejudice and admonishment after finding that the plaintiff’s quotations and legal concepts were AI-hallucinated. A self-represented party submitted an opposition brief with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities.
- Kevin Lee Biglow v. Dell Technologies Inc.
· U.S. Court of Appeals for the Tenth Circuit · Fabricated or misquoted citations
On 2026-03-24, U.S. Court of Appeals for the Tenth Circuit affirmed dismissal and warned that further failure to check cited authority before filing could result in sanctions. A self-represented party submitted a reply brief with several false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Burton v. Ghosh and Iseminger v. Dist. Ct.
- Segui v. Moniz
· U.S. District Court for the District of Arizona · Fabricated or misquoted citations
On 2026-03-24, U.S. District Court for the District of Arizona ordered plaintiffs’ counsel to show cause why sanctions should not be imposed for citing a nonexistent Arizona RICO limitations case. Counsel submitted a motion with fabricated or nonexistent authorities, including Barker v. Brown & Brown, 210 Ariz. 321, 110 P.3d 1011.
- Nicholas and Barbara Moulder v. Davis School District (on behalf of M.M.)
· U.S. District Court for the District of Utah · Fabricated or misquoted citations
On 2026-03-23, U.S. District Court for the District of Utah required AI-related CLE and payment of $1,525.50 already agreed to reimburse fees for two nonexistent cases and a nonexistent quotation. Counsel submitted a brief with two false quotations and fabricated or nonexistent authorities.
- Stafford v. Andrew Taffet, et al.
· U.S. District Court for the District of Oregon · Fabricated or misquoted citations
On 2026-03-23, U.S. District Court for the District of Oregon declined sanctions because defendants did not request them, but warned that the plaintiffs’ false citations appeared to be unverified AI hallucinations. A self-represented party submitted an appellate brief with multiple fabricated or nonexistent authorities, including Campbell v. MERS and Tucker v. HSBC.
- Jane Doe, et al. v. Lincoln Consolidated Schools, et al.
· U.S. District Court for the Eastern District of Michigan · Fabricated or misquoted citations
On 2026-03-23, U.S. District Court for the Eastern District of Michigan granted summary judgment in part and ordered plaintiffs’ counsel’s firm to reimburse the defense costs of researching the hallucinated case. Counsel submitted a brief with multiple fabricated or nonexistent authorities, including Doe v. Univ. of Mich., No. 18-11914.
- Gregory Hardy v. K. Jones, et al.
· U.S. District Court for the Eastern District of Michigan · Fabricated or misquoted citations
On 2026-03-23, U.S. District Court for the Eastern District of Michigan struck the motion and issued a final sanctions warning after the plaintiff repeated fake quotations previously attributed to AI use. A self-represented party submitted a motion with false quotations, including Berndt v. Tennessee and United States v. Frazier.
- Endure Industries, Inc. v. Defense Health Agency
· Armed Services Board of Contract Appeals · Fabricated or misquoted citations
On 2026-03-23, Armed Services Board of Contract Appeals the Board granted dismissal and warned the self-represented contractor that future citations to non-existent authority may lead to sanctions. A self-represented party submitted a brief with fabricated or nonexistent authorities and mischaracterized authorities, including LLC v. United States and Corp. v. United States.
- Daniel Gentry v. Calvin Thompson et al.
· U.S. District Court for the Eastern District of Louisiana · Fabricated or misquoted citations
On 2026-03-20, U.S. District Court for the Eastern District of Louisiana personally sanctioned counsel $1,250 and formally admonished him after he admitted using ChatGPT without checking nine hallucinated cases. Counsel submitted a brief with The brief cited nine hallucinated cases generated through ChatGPT that counsel admitted he had not checked.
- Pamela Blair v. Sanctuary Bluff Homeowners Association, Inc., et al.
· Kentucky Court of Appeals · Fabricated or misquoted citations
On 2026-03-20, Kentucky Court of Appeals struck the appellant’s brief and allowed refiling after repeated hallucinated precedent and deficient AI certifications. A self-represented party submitted an appellate brief with nine false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Co. v. Thompson, 11.
- Hessert v. Hessert & Wieland-Pulayya
· Florida Sixth District Court of Appeal · Fabricated or misquoted citations
On 2026-03-20, Florida Sixth District Court of Appeal ordered the petitioner to show cause why sanctions should not issue for a petition with nonexistent cases and inaccurate legal propositions. A self-represented party submitted a petition with fabricated or nonexistent authorities and mischaracterized authorities.
- Prisbrey v. Prisbrey
· Utah Court of Appeals · Fabricated or misquoted citations
On 2026-03-19, Utah Court of Appeals reversed and remanded for a new trial while criticizing counsel’s incorrect Utah citations, misquotations, and authorities made out of whole cloth. Counsel submitted an appellate brief with seven fabricated or nonexistent authorities and mischaracterized authorities.
- Kelly Bartholomew v. Clackamas County
· Oregon Land Use Board of Appeals · Fabricated or misquoted citations
On 2026-03-19, Oregon Land Use Board of Appeals struck the petition for judicial review after concluding that fabricated authorities permeated the assignments of error and consumed tribunal resources. A self-represented party submitted an appellate brief with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities.
- Oscar Brownfield v. Cherokee County School District No. 35
· U.S. District Court for the Eastern District of Oklahoma · Fabricated or misquoted citations
On 2026-03-19, U.S. District Court for the Eastern District of Oklahoma denied the plaintiff’s sanctions motion but imposed a $500 sanction for citing fictitious or inaccurate authorities generated through AI research. A self-represented party submitted a motion with two false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hill v. Oklahoma and Wadsworth v. Walmart.
- Espinoza v. M&R Const. Group Inc.
· Supreme Court of the State of New York · Fabricated or misquoted citations
On 2026-03-19, Supreme Court of the State of New York scheduled a sanctions hearing after finding that the moving papers relied on a nonexistent Second Department case. Counsel submitted a filing with fabricated or nonexistent authorities, including Parrelli v. Temple Beth El of Great Neck.
- Jana James v. National Board of Osteopathic Examiners, Inc.
· U.S. District Court for the Southern District of Indiana · Fabricated or misquoted citations
On 2026-03-19, U.S. District Court for the Southern District of Indiana warned that future filings with nonexistent cases or unsupported authorities would result in Rule 11 sanctions. A self-represented party submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Knakmuhs v. Minneapolis Pub. Sch and Cooper v. Tokyo Elec. Power Co.
- Pittman v. Hazel and Olive, Inc.
· U.S. District Court for the Northern District of Illinois · Fabricated or misquoted citations
On 2026-03-19, U.S. District Court for the Northern District of Illinois dismissed the case with prejudice, struck the AI-generated response brief, and ordered counsel to pay defense fees and costs. Counsel submitted a response brief with fabricated or nonexistent authorities.
- Keirton Inc. v. Mersad Rahmanovic
· U.S. Bankruptcy Court for the District of Colorado · Fabricated or misquoted citations
On 2026-03-19, U.S. Bankruptcy Court for the District of Colorado dismissed the debtor’s counterclaims with leave to amend and warned that nonexistent AI-hallucinated citations did not save deficient pleading. A self-represented party submitted a complaint with several false quotations and fabricated or nonexistent authorities, including Gullickson v. Brown.
- Anna Sheerer v. Thomas Panas
· California Court of Appeal, First District · Fabricated or misquoted citations
On 2026-03-19, California Court of Appeal, First District reversed the child-support order but declined monetary sanctions after the self-represented respondent admitted AI-caused fake citations and quotations. A self-represented party submitted an appellate brief with two false quotations and fabricated or nonexistent authorities, including In re Marriage of Thomson and Keitel v. Heubel, supra.
- Burnley v. Valentin
· U.S. District Court for the Eastern District of Virginia · AI-generated evidence and authentication
On 2026-03-18, the Eastern District of Virginia enforces a settlement agreement after an evidentiary hearing. The plaintiff argued an audio recording was AI-cloned or manipulated; the court applied Rule 901, found the recording authentic, credited voice-identification evidence, and rejected the authentication challenge.
- Forest Ridge Townhomes Corporation of Greensboro v. Heag Pain Management Center et al.
· North Carolina Court of Appeals · Fabricated or misquoted citations
On 2026-03-18, North Carolina Court of Appeals affirmed the surplus-funds ruling and chastised counsel for relying on Perplexity.AI material without adequately checking irrelevant authorities. Counsel submitted a motion with fabricated or nonexistent authorities, including Benjamin v. Costco Wholesale Corp. The court resolved the merits while identifying the defective legal research.
- Davos Francois v. Vive Financial
· Florida Fourth District Court of Appeal · Fabricated or misquoted citations
On 2026-03-18, Florida Fourth District Court of Appeal affirmed and cautioned the appellant that future briefs with nonexistent authorities may result in sanctions. A self-represented party submitted a motion with multiple fabricated or nonexistent authorities, including Friend v. Serpa and Phadael v. Deutsche Bank Tr. Co. Ams., 83 So. 3d 893, 895.
- Sarah & Regina Alonso v. Jackson
· U.S. District Court for the Western District of Washington · Fabricated or misquoted citations
On 2026-03-17, U.S. District Court for the Western District of Washington granted the motion to dismiss claims against one defendant and warned counsel that another fictitious authority would trigger a sanctions show-cause order. Counsel submitted a motion with fabricated or nonexistent authorities, including Allen v. Bayshore Mall.
- Gregory Richmond and Lynne Richmond v. City of Newport, Washington
· Washington Court of Appeals, Division III · Fabricated or misquoted citations
On 2026-03-17, Washington Court of Appeals, Division III affirmed dismissal and warned self-represented appellants that cases cited for convenient propositions must be real and supportive. A self-represented party submitted an appellate brief with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 and Osborn v. Mason County.
- Zesiger v. Kansas et al.
· U.S. District Court for the District of Kansas · Fabricated or misquoted citations
On 2026-03-17, U.S. District Court for the District of Kansas dismissed the claims and recounted the magistrate judge’s fourth warning against inaccurate or nonexistent case citations. A self-represented party submitted a motion with fabricated or nonexistent authorities and mischaracterized authorities, including Levy v. Kan. Dep’t of Soc. & Rehab. Servs and Williams v. Utah Dep’t of Corrs.
- Michael Wayne Singletary v. SWBC Mortgage Corporation et al.
· U.S. Court of Appeals for the Fifth Circuit · Fabricated or misquoted citations
On 2026-03-17, U.S. Court of Appeals for the Fifth Circuit affirmed dismissal and warned that further failure to check cited authority before filing could lead to sanctions. A self-represented party submitted an opposition brief with multiple fabricated or nonexistent authorities, including Cervantes v. New Century Mortg. Corp.
- Esterra Commons Venture, LLC dba Verde Esterra Park v. Justin Norton
· Court of Appeals of Washington, Division One · Fabricated or misquoted citations
Washington Court of Appeals, Division One on 2026-03-16 in Esterra Commons Venture, LLC dba Verde Esterra Park v. Justin Norton found the self-represented party's appellate brief contained four citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.
- Domingo Beato-Estrella v. M. Arviza
· U.S. District Court for the Middle District of Pennsylvania · Fabricated or misquoted citations
On 2026-03-16, U.S. District Court for the Middle District of Pennsylvania dismissed the habeas petition without prejudice and cautioned that AI programs can hallucinate fake cases that do not support jurisdiction. A self-represented party submitted a petition with fabricated or nonexistent authorities and mischaracterized authorities, including Santos v. Warden Allenwood FCI, No. 1:17-CV-02116 and London v. Pettit.
- Shaquan Pridgen v. Amazon.com Services LLC
· United States District Court for the District of New Jersey · Fabricated or misquoted citations
District of New Jersey on 2026-03-16 in Shaquan Pridgen v. Amazon.com Services LLC found the self-represented party's opposition cited Lewis v. City of Trenton, 2020 WL 6204330, a case the court found did not exist. The court warned the self-represented party to disclose AI use when required and to verify future citations.
- Meriland Keith Dillard v. CBS Studios, Inc.
· United States District Court for the Central District of California · Fabricated or misquoted citations
Central District of California on 2026-03-16 found the self-represented party's brief contained three citation defects, including Jorgensen v. CBS, Inc., 728 F.2d 958 (8th Cir. 1984), Lamon v. Godbolt, 2015 WL 13647670 (C.D..... The court denied the stay motion, granted CBS's motion to dismiss without leave to amend, and terminated the case.
- A.C. Appellant v. H.D. AND J.C.
· Superior Court of Pennsylvania · Fabricated or misquoted citations
Superior Court of Pennsylvania on 2026-03-13 in A.C. Appellant v. H.D. AND J.C. found the self-represented party's appellate brief contained three citation defects, including Commonwealth v. Lyons, involving nonexistent authorities, mischaracterized authority. The court affirmed the order dismissing the custody petition with prejudice and did not rely on the defective authorities.
- Albert Taylor v. Las Vegas Metropolitan Police Department, et al.
· United States District Court for the District of Nevada · Fabricated or misquoted citations
District of Nevada on 2026-03-13 in Albert Taylor v. Las Vegas Metropolitan Police Department, et al. found the self-represented party's opposition used hallucinogenic citations to nonexistent cases while opposing dismissal motions. The court warned the self-represented party to verify legal authorities before future filings.
- DSME Construction Co., Ltd.
· Armed Services Board of Contract Appeals · Fabricated or misquoted citations
Armed Services Board of Contract Appeals on 2026-03-13 in DSME Construction Co., Ltd. found counsel's surreply contained five citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court struck the defective filing and warned counsel to verify cited authorities before filing again.
- Suiter v. GM - General Motors, LLC
· United States District Court for the Western District of Virginia · Fabricated or misquoted citations
Western District of Virginia on 2026-03-12 in Suiter v. GM - General Motors, LLC found the self-represented party's brief contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.
- Hartmann v. Davidson
· United States District Court for the Northern District of Texas · Fabricated or misquoted citations
Northern District of Texas on 2026-03-12 in Hartmann v. Davidson found the self-represented party's brief contained one citation defect involving incorrect statutory or rule text. The court dismissed claims or denied relief after identifying the defective authorities in the challenged filing before resolving the pending matter.
- Donaghy v. Zoning Bd. of Review of the Town of North Kingstown
· Rhode Island Superior Court · Fabricated or misquoted citations
Rhode Island Superior Court on 2026-03-12 found counsel's appellate brief contained two citation defects, including Smithfield v. Fanning and Duffy v. Milder, involving nonexistent authorities, fabricated or misattributed quotations. The court remanded the zoning appeal to the board for a continued public hearing and cautioned counsel about likely AI-generated citations.
- Dillon v. Myles Stephenson, et al.
· United States District Court for the Western District of Oklahoma · Fabricated or misquoted citations
Western District of Oklahoma on 2026-03-11 in Dillon v. Myles Stephenson, et al. found counsel's brief contained three citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court admonished counsel to verify cited authorities and avoid repeating the citation defects.
- Donte McClellon v. E. Rickard, Warden of FCI Otisville, et al.
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
Southern District of New York on 2026-03-11 in Donte McClellon v. E. Rickard, Warden of FCI Otisville, et al. found the self-represented party's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, incorrect statutory or rule text. The court warned the self-represented party to disclose AI use when required and to verify future citations.
- Checks Aciek Ateny Nai v. National Asset Mortgage, LLC, et al.
· United States District Court for the Western District of Michigan · Fabricated or misquoted citations
Western District of Michigan on 2026-03-11 in Checks Aciek Ateny Nai v. National Asset Mortgage, LLC, et al. found counsel's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court discharged the show-cause issue and declined Rule 11 sanctions after reviewing the explanation for the defective authorities.
- Traver v. General Motors Financial Company Inc., et al.
· United States District Court for the District of Massachusetts · Fabricated or misquoted citations
District of Massachusetts on 2026-03-11 in Traver v. General Motors Financial Company Inc., et al. found the self-represented party's complaint contained three citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.
- Kateryna Maslovska v. Ekaterina Shigabetdinova
· Appellate Court of Illinois · Fabricated or misquoted citations
Illinois Appellate Court on 2026-03-11 in Kateryna Maslovska v. Ekaterina Shigabetdinova found the self-represented party's brief contained two citation defects involving mischaracterized authority. The court warned both sides to verify authorities and quotations before filing future papers in the challenged filing before resolving the pending matter.
- Samantha Roussell v. The Bank of New York Mellon
· District Court of Appeal of Florida · Fabricated or misquoted citations
Florida District Court of Appeal on 2026-03-11 in Samantha Roussell v. The Bank of New York Mellon found the self-represented party's appellee brief contained two citation defects involving mischaracterized authority, incorrect statutory or rule text, defective exhibits or submissions. The court warned the self-represented party to verify legal authorities before future filings.
- Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law (1)
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
Southern District of New York on 2026-03-10 in Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law (1) found counsel's brief contained one citation defect, including Protégé, involving nonexistent authorities, fabricated or misattributed quotations. The court referred counsel to disciplinary authorities for the defective citations.
- Brown v. State of Mississippi
· Court of Appeals of Mississippi · Fabricated or misquoted citations
Court of Appeals of Mississippi on 2026-03-10 in Brown v. State of Mississippi found counsel's reply brief contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned counsel to verify legal authorities before future filings.
- Michael Platt v. Volunteers of America Ohio & Indiana
· United States District Court for the Southern District of Indiana · Fabricated or misquoted citations
Southern District of Indiana on 2026-03-10 in Michael Platt v. Volunteers of America Ohio & Indiana found the self-represented party's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court struck the defective filing and warned the self-represented party to verify cited authorities before filing again.
- A.K. v. M.R.
· Indiana Court of Appeals · Fabricated or misquoted citations
Indiana Court of Appeals on 2026-03-10 in A.K. v. M.R. found the self-represented party's appellate brief contained four citation defects, including 994 N.E.2d 228, 106 N.E.3d 400 and 212 N.E.3d 768, involving nonexistent authorities, mischaracterized authority. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.
- Tina Rose v. City of West Frankfort et al.
· United States District Court for the Southern District of Illinois · Fabricated or misquoted citations
Southern District of Illinois on 2026-03-10 in Tina Rose v. City of West Frankfort et al. found the self-represented party's filing contained one citation defect involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.
- Helen Allen v. Cass Casper and Disparti Law Group
· United States District Court for the Northern District of Illinois · Fabricated or misquoted citations
Northern District of Illinois on 2026-03-10 in Helen Allen v. Cass Casper and Disparti Law Group found the self-represented party's brief contained two citation defects, including Krause v. Meyers, Krause and Krause v. Meyers', involving nonexistent authorities, fabricated or misattributed quotations. The court ordered the self-represented party to pay $1,500 for the defective authorities.
- In re A.R. and N.R., Minors
· Appellate Court of Illinois · Fabricated or misquoted citations
Illinois Appellate Court on 2026-03-10 in In re A.R. and N.R., Minors found the self-represented party's appellate brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.
- Arno Kuigoua v. Adam Michael Sacks
· California Court of Appeal, Second District · Fabricated or misquoted citations
California Court of Appeal, Second District on 2026-03-10 in Arno Kuigoua v. Adam Michael Sacks found the self-represented party's opening brief contained three citation defects involving nonexistent authorities, defective exhibits or submissions. The court warned the self-represented party to verify legal authorities before future filings.
- Hunter v. TForce Freight Incorporated
· United States District Court for the District of Arizona · Fabricated or misquoted citations
District of Arizona on 2026-03-10 in Hunter v. TForce Freight Incorporated found the self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.
- M7 Indústria e Comércio de Compensados e Laminados v. U.S. Structural Plywood Integrity Coalition, et al.
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
Southern District of New York on 2026-03-09 found counsel's brief contained two citation defects, including NYNEX Corp. v. Discon, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
- Slay v. Ross
· Court of Appeals of Georgia · Fabricated or misquoted citations
Court of Appeals of Georgia on 2026-03-09 in Slay v. Ross found counsel's appellate brief cited four fictitious Georgia authorities, including Waller v. Waller, Johnson v. Johnson, Durden v. Barron, and In re Waitz. The court warned counsel to verify legal authorities before future filings.
- Dewayne Clark v. CoreCivic
· United States District Court for the Western District of Oklahoma · Fabricated or misquoted citations
Western District of Oklahoma on 2026-03-06 in Dewayne Clark v. CoreCivic found the self-represented party's surreply contained five citation defects, including Garrison v. Gambro, Tuckel v. Glover and Lemons v. Portfolio Recovery Assocs, involving fabricated or misattributed quotations, mischaracterized authority. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.
- Kim Elizabeth Harwell v. WestCare Nevada, Inc.
· United States District Court for the District of Nevada · Fabricated or misquoted citations
District of Nevada on 2026-03-06 in Kim Elizabeth Harwell v. WestCare Nevada, Inc. found the self-represented party's brief contained one citation defect, including Saila v. Circle, involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.
- Gregory J. Van Etten v. Stephanie K. Fattman, et al.
· United States District Court for the District of Massachusetts · Fabricated or misquoted citations
District of Massachusetts on 2026-03-06 in Gregory J. Van Etten v. Stephanie K. Fattman, et al. found the self-represented party's motion contained three citation defects, including Ankenbrandt v. Richards and Seminole Tribe v. Florida, involving mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.
- Kattom v. Bondi
· United States District Court for the Western District of Louisiana · Fabricated or misquoted citations
Western District of Louisiana on 2026-03-06 in Kattom v. Bondi found counsel's motion contained two citation defects involving fabricated or misattributed quotations, incorrect statutory or rule text. The court ordered counsel to pay $1,000 for the defective authorities and complete corrective CLE.
- Hatch v. College Ave Student Loans
· United States District Court for the Northern District of Illinois · Fabricated or misquoted citations
Northern District of Illinois on 2026-03-06 in Hatch v. College Ave Student Loans found counsel's brief contained two citation defects, including Jones v. TransUnion and Horan v. Equifax Info. Servs, involving nonexistent authorities, incorrect statutory or rule text. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
- Andre Lamont Goddard, Jr. v. City University of Seattle
· United States District Court for the District of Columbia · Fabricated or misquoted citations
District of Columbia on 2026-03-06 in Andre Lamont Goddard, Jr. v. City University of Seattle found the self-represented party's motion contained five citation defects involving mischaracterized authority, incorrect statutory or rule text. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.
- Lawand Hill v. Sloppy Vinyl, LLC, et al.
· United States District Court for the District of New Jersey · Fabricated or misquoted citations
District of New Jersey on 2026-03-05 found the self-represented party's motion contained three citation defects, including Duff v. Trenton Beverage Co and Jordan v. Fox, involving fabricated or misattributed quotations, incorrect statutory or rule text. The court granted defendants' motion to dismiss, dismissed the complaint without prejudice, and reminded the plaintiff that false authorities may draw Rule 11 sanctions.
- Woodward Harbor L.L.C., et al. v. City of Mandeville
· United States District Court for the Eastern District of Louisiana · Fabricated or misquoted citations
Eastern District of Louisiana on 2026-03-05 in Woodward Harbor L.L.C., et al. v. City of Mandeville found counsel's brief contained three citation defects, including Wood v. City of Utica, Qutb v. Ramsey and Wood v. City, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to pay $1,000 for the defective authorities and complete corrective CLE.
- Joan Pablo Torres Campos v. Leslie Ann Munoz
· California Court of Appeal · Fabricated or misquoted citations
California Court of Appeal on 2026-03-05 found counsel's brief contained two citation defects, including 34 Cal.3d 926, Marriage of Twigg and In re Marriage of Teegarden, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to pay $5,000 for the defective authorities and referred the matter for discipline and complete corrective CLE.
- In the Matter of the Estate of Kuerschner
· Court of Appeals of Arizona · Fabricated or misquoted citations
Arizona Court of Appeals on 2026-03-05 in In the Matter of the Estate of Kuerschner found the self-represented party's appellate briefs contained 25 made-up or substantially erroneous citations, including fake quotes and unsupported propositions. The court dismissed the appeal under ARCAP 25 and awarded appellee reasonable attorney fees and costs for repeated fabricated citations.
- Ryan Adam Dixon v. MultiCare Health System (1)
· United States District Court for the Western District of Washington · Fabricated or misquoted citations
Western District of Washington on 2026-03-04 in Ryan Adam Dixon v. MultiCare Health System (1) found the self-represented party's brief contained five citation defects, including Mazza v. Washoe Cnty, Shirley v. Precision Castparts Corp and Bounds v. Smith, involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.
- Medal v. Amazon.com Services, LLC
· United States District Court for the Western District of Washington · Fabricated or misquoted citations
Western District of Washington on 2026-03-04 in Medal v. Amazon.com Services, LLC found counsel's opening brief included erroneous citations generated by AI-based search engines, combining captions, unrelated citations, and unsupported principles. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
- Jeri'yah Ford v. Troy City School District, et al.
· United States District Court for the Northern District of New York · Fabricated or misquoted citations
Northern District of New York on 2026-03-04 in Jeri'yah Ford v. Troy City School District, et al. found counsel's response contained two citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
- In the Matter of the Estate of CAROL M. CAREY
· Court of Appeals of Washington · Fabricated or misquoted citations
Washington Court of Appeals on 2026-03-03 in In the Matter of the Estate of CAROL M. CAREY found the self-represented party's appellate brief contained six citation defects, including Perez v. Pappas, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered the self-represented party to pay or reimburse $1 in fees or costs for the defective filing.
- In re Lusine Hakhverdyan
· United States Bankruptcy Court for the Central District of California · Fabricated or misquoted citations
United States Bankruptcy Court for the Central District of California on 2026-03-03 in In re Lusine Hakhverdyan found counsel's motion cited Whittaker v. Otto, 2014 WL 37845 (9th Cir.), which the court described as inaccurate or nonexistent. The court denied the debtor's Rule 60 motions after noting an inaccurate or nonexistent Whittaker citation in the debtor's papers.
- Put A Bird On It, LLC v. Seattle Arena Holdings, LLC
· Court of Appeals of Washington · Fabricated or misquoted citations
Washington Court of Appeals on 2026-03-02 in Put A Bird On It, LLC v. Seattle Arena Holdings, LLC found counsel's opening brief included several AI-generated erroneous citations and false quotations with mismatched captions, citations, and legal principles. The court affirmed dismissal of the contract claims with prejudice and noted counsel's AI-based erroneous citations and false quotations.
- Fabian Antonio Thomas v. Officer Skylar Sillivent, et al.
· United States District Court for the Eastern District of Texas · Fabricated or misquoted citations
Eastern District of Texas on 2026-03-02 in Fabian Antonio Thomas v. Officer Skylar Sillivent, et al. found the self-represented party's objection cited United States v. Lopez, 817 F.3d 541, 545 (5th Cir. 2016), which the court described as a phantom case. The court adopted the report and recommendation, granted defendants' motions to dismiss, and dismissed the action with prejudice.
- Derence V. Fivehouse v. United States Department of Defense et al.
· United States District Court for the Eastern District of North Carolina · Fabricated or misquoted citations
Eastern District of North Carolina on 2026-03-02 in Derence V. Fivehouse v. United States Department of Defense et al. found counsel's motion contained seven citation defects involving fabricated or misattributed quotations, incorrect statutory or rule text. The court admonished counsel to verify cited authorities and avoid repeating the citation defects.
- Hardy v. Whitaker
· United States District Court for the Eastern District of Michigan · Fabricated or misquoted citations
Eastern District of Michigan on 2026-03-02 found the self-represented party's brief contained four citation defects, including Patel v. City of Ferndale, 308 F.3d 511, 517 (6th Cir. 2002), Thompson v. City of Lebanon, 813 F.3d.... The court adopted the report and recommendation, dismissed the amended complaint with prejudice, and entered a filing injunction.