Courts on AI / monthly digest
What courts said about AI in May 2026
104 court-authored documents filed this month that substantively discuss generative AI. Fabricated or misquoted citations 104.
- Jaclyn Cocco v. Rosario Palmieri, Jr.
· Supreme Court of Pennsylvania · Fabricated or misquoted citations
On 2026-05-29, in Jaclyn Cocco v. Rosario Palmieri, Jr, Supreme Court of Pennsylvania affirmed and observed that an asserted parental-alienation authority could not be located. A self-represented appellant filed a petition using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.
- Trauger v. Columbia County District Attorney's Office et al.
· United States District Court for the Middle District of Pennsylvania · Fabricated or misquoted citations
On 2026-05-29, in Trauger v. Columbia County District Attorney's Office et al, the Middle District of Pennsylvania warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed opposition papers using nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Garcia v. City of Monte Vista, Colorado et al
· United States District Court for the District of Colorado · Fabricated or misquoted citations
On 2026-05-29, in Garcia v. City of Monte Vista, Colorado et al, the District of Colorado ordered counsel to show cause why sanctions should not issue for relying on an allegedly fabricated autopsy and forensic report. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.
- Christian Lavell Jennings v. Vandergriff Honda
· Court of Appeals of Texas · Fabricated or misquoted citations
On 2026-05-28, in Christian Lavell Jennings v. Vandergriff Honda, Court of Appeals of Texas affirmed the judgment and noted that the appellant's briefing relied on a nonexistent case and fabricated quotations. A self-represented appellant filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.
- Strategic Funding Source, Inc. v. STI-NY, LLC
· Supreme Court of New York · Fabricated or misquoted citations
On 2026-05-28, in Strategic Funding Source, Inc. v. STI-NY, LLC, Supreme Court of New York awarded $2,000 in costs or fees caused by the defective legal authorities. Counsel filed a motion using authorities used for propositions they did not support.
- Boyle, et al. v. Steven Kramer
· United States District Court for the Eastern District of Michigan · Fabricated or misquoted citations
On 2026-05-28, in Boyle, et al. v. Steven Kramer, the Eastern District of Michigan warned that future filings containing fabricated legal authorities may lead to sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.
- Roger Patel et al. v. Chandresh Patel et al.
· United States District Court for the Western District of Kentucky · Fabricated or misquoted citations
On 2026-05-28, in Roger Patel et al. v. Chandresh Patel et al, the Western District of Kentucky warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. Counsel filed a response using quotations that did not appear in the cited source and authorities used for propositions they did not support.
- In re M.H., M.L., and M.H., Minors
· Appellate Court of Illinois, First District · Fabricated or misquoted citations
On 2026-05-28, in In re M.H., M.L., and M.H., Minors, Appellate Court of Illinois, First District ordered mother to show cause within fourteen days why sanctions should not be imposed for fictitious authorities. Counsel filed a response using nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- USA ex rels. v. Barton Associates, Inc.
· United States Court of Appeals for the First Circuit · Fabricated or misquoted citations
On 2026-05-28, in USA ex rels. v. Barton Associates, Inc, the First Circuit affirmed dismissal and noted that appellants misrepresented authorities and quoted language absent from cited cases. Counsel filed a reply brief using quotations that did not appear in the cited source and authorities used for propositions they did not support.
- State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves
· Supreme Court of Oklahoma · Fabricated or misquoted citations
On 2026-05-27, in State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves, Supreme Court of Oklahoma publicly reprimanded the attorney as reciprocal discipline for ChatGPT-generated citations used in federal filings. Counsel filed a motion using authorities used for propositions they did not support.
- Polanco v. Himalayan Real Estate LLC, et al.
· United States District Court for the Eastern District of New York · Fabricated or misquoted citations
On 2026-05-27, in Polanco v. Himalayan Real Estate LLC, et al, the Eastern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant cited Moore v. Alliance Credit Union even though the court found the authority did not exist.
- In the Matter of Kevin A. Julien v. Danielle M. Arthur
· Supreme Court of New York, Appellate Division, Second Department · Fabricated or misquoted citations
On 2026-05-27, in In the Matter of Kevin A. Julien v. Danielle M. Arthur, New York's Second Department imposed a $250 sanction on the self-represented appellant for a brief prepared with unverified generative AI. A self-represented appellant filed an appellate brief using unsupported or inaccurate legal authorities.
- Christ Apostolic Temple, Inc., Dwight Reed and Jordan Reed v. Demetrius Sinegal, et al.
· Iowa Court of Appeals · Fabricated or misquoted citations
On 2026-05-27, in Christ Apostolic Temple, Inc., Dwight Reed and Jordan Reed v. Demetrius Sinegal, et al, Iowa Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a reply brief using nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Robert Hinton Avery v. Danielle Beauzil
· District Court of Appeal of Florida, Fourth District · Fabricated or misquoted citations
On 2026-05-27, in Robert Hinton Avery v. Danielle Beauzil, District Court of Appeal of Florida, Fourth District barred the appellant from future pro se filings in the case unless signed by a Florida Bar member. A self-represented appellant filed a brief using nonexistent or hallucinated authorities, authorities used for propositions they did not support, and a nonexistent.
- Innocent v. Meraki Installers, LLC
· District Court of Appeal of Florida, Fourth District · Fabricated or misquoted citations
On 2026-05-27, in Innocent v. Meraki Installers, LLC, District Court of Appeal of Florida, Fourth District affirmed and referred counsel to the Florida Bar over trial-transcript quotations not found in the record. Counsel filed an initial brief using record or transcript quotations not found in the record, quotations that did not appear in the.
- Eclectic Synergy, LLC v. Seredin
· District Court of Appeal of Florida, Fourth District · Fabricated or misquoted citations
On 2026-05-27, in Eclectic Synergy, LLC v. Seredin, District Court of Appeal of Florida, Fourth District ordered counsel to show cause why sanctions should not issue for an apparently AI-generated emergency stay motion. Counsel filed a response using several nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- SWSZ Holding v. SZ Global
· Supreme Court of Delaware · Fabricated or misquoted citations
On 2026-05-27, in SWSZ Holding v. SZ Global, Supreme Court of Delaware denied the sealing motion without prejudice and directed the movant to refile using only existing, accurately quoted authorities. A self-represented appellant filed a motion using several nonexistent or hallucinated authorities.
- Williamson v. Meyers (derivatively on behalf of Equinix, Inc.)
· United States District Court for the District of Delaware · Fabricated or misquoted citations
On 2026-05-27, in Williamson v. Meyers (derivatively on behalf of Equinix, Inc.), the District of Delaware warned counsel after plaintiff conceded a fictitious citation and withdrew it from the briefing. Counsel filed a motion using at least one nonexistent or hallucinated authority.
- Guo v. Meade Motorcars, L.L.C.
· Court of Appeals of Ohio, Sixth District · Fabricated or misquoted citations
On 2026-05-26, in Guo v. Meade Motorcars, L.L.C, Court of Appeals of Ohio, Sixth District imposed a $100 monetary sanction for the defective legal authorities. A self-represented appellant cited Davis v. Davis, 590 N.E.2d 1372 (Ohio Ct. App. 1990) even though the court found the authority did not exist.
- Hodges v. McGough Enterprises LLC
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
On 2026-05-26, in Hodges v. McGough Enterprises LLC, the Southern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a motion using nonexistent or hallucinated authorities.
- Sample et al v. Hilton Worldwide Holdings, Inc
· United States District Court for the District of New Mexico · Fabricated or misquoted citations
On 2026-05-26, in Sample et al v. Hilton Worldwide Holdings, Inc, the District of New Mexico warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a response using quotations that did not appear in the cited source.
- William C. Maxwell v. Dakota Michael & Chelsey Smith
· United States District Court for the Southern District of Indiana · Fabricated or misquoted citations
On 2026-05-26, in William C. Maxwell v. Dakota Michael & Chelsey Smith, the Southern District of Indiana imposed a $1,000 Rule 11 sanction for non-existent citations and denied the motion for preliminary injunction. A self-represented litigant filed a motion using quotations that did not appear in the cited source and at least 37 nonexistent or hallucinated authorities.
- Jean-Paul B. Kalonji v. State of Indiana
· Indiana Court of Appeals · Fabricated or misquoted citations
On 2026-05-26, in Jean-Paul B. Kalonji v. State of Indiana, Indiana Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant cited Taylor v. State, 133 N.E.3d 708 (Ind. Ct. App. 2019) even though the court found the authority did not exist.
- Sana Hazina Butler v. Fidelity Management & Research Company LLC
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
On 2026-05-22, in Sana Hazina Butler v. Fidelity Management & Research Company LLC, the Southern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant cited Rate Technology Inc. v. Speakeasy Inc even though the court found the authority did not exist.
- A.T.W. v. Commonwealth of Kentucky
· Kentucky Court of Appeals · Fabricated or misquoted citations
On 2026-05-22, in A.T.W. v. Commonwealth of Kentucky, Kentucky Court of Appeals affirmed and noted that the circuit court had already warned mother about non-existent case law. A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.
- Saqib Kafeel v. CJDropshipping
· United States District Court for the Northern District of Illinois · Fabricated or misquoted citations
On 2026-05-22, in Saqib Kafeel v. CJDropshipping, the Northern District of Illinois dismissed the second amended complaint and declined to award fees for AI-hallucinated citations. A self-represented litigant filed a motion using record or transcript quotations not found in the record, quotations that did not appear in.
- Kings Roofing v. Fusion Works
· District Court of Appeal of Florida, Sixth District · Fabricated or misquoted citations
On 2026-05-22, in Kings Roofing v. Fusion Works, District Court of Appeal of Florida, Sixth District ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed an initial brief using quotations that did not appear in the cited source, several nonexistent or hallucinated authorities, and authorities used for propositions they did not support.
- Lagac v. Capital One, N.A.
· United States District Court for the Central District of California · Fabricated or misquoted citations
On 2026-05-22, in Lagac v. Capital One, N.A, the Central District of California warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed opposition papers using quotations that did not appear in the cited source.
- Simmons v. Shahidul Islam
· Court of Appeals of Tennessee · Fabricated or misquoted citations
On 2026-05-21, in Simmons v. Shahidul Islam, Court of Appeals of Tennessee affirmed dismissal and rejected briefing that used apparent AI-hallucinated cases and an inaccurate Rule 19 argument. A self-represented appellant filed a motion using authorities used for propositions they did not support.
- Twigg v. BSN Sports, Inc., et al.
· United States District Court for the Middle District of Pennsylvania · Fabricated or misquoted citations
On 2026-05-21, in Twigg v. BSN Sports, Inc., et al, the Middle District of Pennsylvania ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a motion using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.
- Dalton Gage Hill v. Oklahoma County Criminal Justice Authority
· United States District Court for the Western District of Oklahoma · Fabricated or misquoted citations
On 2026-05-21, in Dalton Gage Hill v. Oklahoma County Criminal Justice Authority, the Western District of Oklahoma magistrate judge recommended denying the motion to vacate and described earlier Rule 11 sanctions proceedings against counsel. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for.
- In re the Marriage of Amy Haddock and Justin Blu Haddock
· District Court of Tulsa County, Oklahoma · Fabricated or misquoted citations
On 2026-05-21, in In re the Marriage of Amy Haddock and Justin Blu Haddock, the Tulsa County district court sanctioned counsel $2,000, ordered attorney-fee proceedings, required a knowledge-base audit, and directed bar referral. Counsel filed a motion using authorities used for propositions they did not support.
- Arron v. Custer, et al.
· United States District Court for the Southern District of Ohio · Fabricated or misquoted citations
On 2026-05-21, in Arron v. Custer, et al, the Southern District of Ohio magistrate judge treated the cited Ohio Supreme Court decision as unverified and recommended remand. A self-represented litigant filed a motion using unsupported or inaccurate legal authorities. The document links the problem to GAI.
- Isaiah Hunter-Bey v. City of Cleveland Law Department
· Court of Appeals of Ohio, Eighth District · Fabricated or misquoted citations
On 2026-05-21, in Isaiah Hunter-Bey v. City of Cleveland Law Department, Court of Appeals of Ohio, Eighth District admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a motion using record or transcript quotations not found in the record and authorities used for propositions they did not support.
- City of Shaker Heights v. Andre D. Thompson
· Court of Appeals of Ohio, Eighth District · Fabricated or misquoted citations
On 2026-05-21, in City of Shaker Heights v. Andre D. Thompson, Court of Appeals of Ohio, Eighth District overruled the assignment of error after finding the cited plea-record authority nonexistent or unrelated. A self-represented appellant cited State v. Banks even though the court found the authority did not exist.
- Lowrey v. City of Rio Rancho et al.
· United States District Court for the District of New Mexico · Fabricated or misquoted citations
On 2026-05-21, in Lowrey v. City of Rio Rancho et al, the District of New Mexico ruled on the merits and separately addressed defective legal authorities in the filing. A self-represented litigant filed a response using authorities used for propositions they did not support.
- That Xiong v. Minga Wofford
· United States District Court for the Eastern District of California · Fabricated or misquoted citations
On 2026-05-21, in That Xiong v. Minga Wofford, the Eastern District of California declined sanctions in light of remedial steps but required counsel to verify all future case and record citations. Counsel cited G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025) even though the court found the authority did not exist.
- Jackie L. Miller v. Regions Bank
· United States District Court for the Northern District of Alabama · Fabricated or misquoted citations
On 2026-05-21, in Jackie L. Miller v. Regions Bank, the Northern District of Alabama disqualified counsel from the case and from appearing before the judge for six months and referred the order to bar authorities. Counsel submitted a filing using quotations that did not appear in the cited source.
- Chapel v. Americredit Financial Services & Experian
· United States District Court for the Northern District of Alabama · Fabricated or misquoted citations
On 2026-05-21, in Chapel v. Americredit Financial Services & Experian, the Northern District of Alabama admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant submitted a filing using quotations that did not appear in the cited source.
- Sherwood v. County of Botetourt, Virginia, et al.
· United States District Court for the Western District of Virginia · Fabricated or misquoted citations
On 2026-05-20, in Sherwood v. County of Botetourt, Virginia, et al, the Western District of Virginia granted dismissal of most claims and warned that any future filing must be supported by real law. Counsel cited Peal v. Commonwealth even though the court found the authority did not exist.
- Landberg v City of New York
· Supreme Court of New York, Appellate Division, Second Department · Fabricated or misquoted citations
On 2026-05-20, in Landberg v City of New York, New York's Second Department ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a brief using unsupported or inaccurate legal authorities. The sanction issue remained pending after the order.
- In re Nicholia Cherry-Crockette
· United States Bankruptcy Court for the District of New Jersey · Fabricated or misquoted citations
On 2026-05-20, in In re Nicholia Cherry-Crockette, the District of New Jersey Bankruptcy Court denied the sanctions motion and rejected authorities that were nonexistent or did not support the debtor's position. A self-represented litigant filed a motion using nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Curtin v. Watts, et al.
· United States District Court for the Middle District of North Carolina · Fabricated or misquoted citations
On 2026-05-20, in Curtin v. Watts, et al, the Middle District of North Carolina warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a brief using quotations that did not appear in the cited source and authorities used for propositions they did not support.
- Brandy Dorsey v. Walter Livramento, III
· Appellate Court of Maryland · Fabricated or misquoted citations
On 2026-05-20, in Brandy Dorsey v. Walter Livramento, III, Appellate Court of Maryland warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed a brief using numerous nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Taiujuan Burches v. Equifax Information Services, LLC, et al.
· United States District Court for the Eastern District of Louisiana · Fabricated or misquoted citations
On 2026-05-20, in Taiujuan Burches v. Equifax Information Services, LLC, et al, the Eastern District of Louisiana warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a motion using nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Davis v. Marion County Juvenile Detention Center
· United States District Court for the Southern District of Indiana · Fabricated or misquoted citations
On 2026-05-20, in Davis v. Marion County Juvenile Detention Center, the Southern District of Indiana magistrate judge recommended a $2,000 sanction against counsel for two AI-generated non-existent citations. Counsel filed a motion using multiple nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Downing v. Dwayne Brown, et al.
· United States Court of Appeals for the Eleventh Circuit · Fabricated or misquoted citations
On 2026-05-20, in Downing v. Dwayne Brown, et al, the Eleventh Circuit struck fabricated-authority portions of the brief and affirmed dismissal. A self-represented appellant filed an appellate brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and nonexistent or hallucinated authorities.
- REDACTED v. United States Citizenship and Immigration Services
· United States District Court for the District of Oregon · Fabricated or misquoted citations
On 2026-05-19, in REDACTED v. United States Citizenship and Immigration Services, the District of Oregon allowed counsel to correct suggested findings after fabricated citations were identified. Counsel filed a response using nonexistent or hallucinated authorities. The document links the problem to GAI.
- Chakma v. Sushi Katsuei, Inc.
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
On 2026-05-19, in Chakma v. Sushi Katsuei, Inc, the Southern District of New York imposed a $2,712 monetary sanction for the defective legal authorities. Counsel filed opposition papers using authorities used for propositions they did not support. The monetary component was $2,712.
- Syreeta LaShawn McNeal v. Vera L. Calvin, et al.
· United States District Court for the Eastern District of Missouri · Fabricated or misquoted citations
On 2026-05-19, in Syreeta LaShawn McNeal v. Vera L. Calvin, et al, the Eastern District of Missouri required the litigant to certify citation verification with every future filing. A self-represented litigant cited Weniger v. Dynamic Recovery Solutions, LLC even though the court found the authority did not exist.
- Harris v. St. Peter Investors, LLC et al.
· United States District Court for the District of Minnesota · Fabricated or misquoted citations
On 2026-05-18, in Harris v. St. Peter Investors, LLC et al, the District of Minnesota warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a motion using quotations that did not appear in the cited source and at least two nonexistent or hallucinated authorities.
- Glenn Wilder and Others v. President & Fellows of Harvard College and Others
· Supreme Judicial Court of Massachusetts · Fabricated or misquoted citations
On 2026-05-18, in Glenn Wilder and Others v. President & Fellows of Harvard College and Others, Supreme Judicial Court of Massachusetts denied pro hac vice admission because counsel had signed AI-hallucinated filings in a prior federal case. Counsel filed a motion using nonexistent or hallucinated authorities.
- Estate of Claxton
· Arizona Court of Appeals · Fabricated or misquoted citations
On 2026-05-18, in Estate of Claxton, Arizona Court of Appeals affirmed and declined to find waiver despite several fictitious or inaccurate citations in the appellant's brief. A self-represented appellant filed a brief using several nonexistent or hallucinated authorities. The document links the problem to GAI.
- Waggeh v. Utility Workers Union of America Local 1-2 et al.
· United States District Court for the Southern District of New York · Fabricated or misquoted citations
On 2026-05-16, in Waggeh v. Utility Workers Union of America Local 1-2 et al, the Southern District of New York publicly admonished counsel after accepting the withdrawal of incorrectly cited cases. Counsel filed a response using authorities used for propositions they did not support.
- Brock et al. v. Hamilton County JFS Children Services et al.
· United States District Court for the Southern District of Ohio · Fabricated or misquoted citations
On 2026-05-15, in Brock et al. v. Hamilton County JFS Children Services et al, the Southern District of Ohio warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a petition using nonexistent or hallucinated authorities.
- Bank of America v. Mapp
· United States District Court for the Middle District of North Carolina · Fabricated or misquoted citations
On 2026-05-15, in Bank of America v. Mapp, the Middle District of North Carolina remanded the collection case and ordered the defendant to show cause within fourteen days why Rule 11 sanctions should not issue. A self-represented litigant filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used.
- Nikko D’Ambrosio v. Meta Platforms Inc.
· United States Court of Appeals for the Seventh Circuit · Fabricated or misquoted citations
On 2026-05-15, in Nikko D’Ambrosio v. Meta Platforms Inc, the Seventh Circuit ordered counsel to show cause by June 5, 2026, why sanctions should not issue for citations to cases that do not exist. Counsel filed a motion using quotations that did not appear in the cited source, at least one nonexistent or hallucinated authority, authorities.
- In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law
· Supreme Court of New York, Appellate Division, First Department · Fabricated or misquoted citations
On 2026-05-14, in In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law, New York's First Department suspended the attorney for three months and imposed a $1,500 sanction for filing an AI-hallucinated judicial-order draft. Counsel filed a brief using numerous nonexistent or hallucinated authorities.
- Stringer v. White Cap Supply Holdings, LLC
· United States District Court for the Middle District of Florida · Fabricated or misquoted citations
On 2026-05-14, in Stringer v. White Cap Supply Holdings, LLC, the Middle District of Florida ordered the filer to show cause why sanctions should not issue for the defective authorities. A self-represented litigant filed a response using record or transcript quotations not found in the record, quotations that did not appear in.
- Oscar Danilo Montealto Garcia v. Todd Lyons, et al.
· United States District Court for the Central District of California · Fabricated or misquoted citations
On 2026-05-14, in Oscar Danilo Montealto Garcia v. Todd Lyons, et al, the Central District of California granted the habeas petition and noted a non-existent case citation in counsel's briefing. A self-represented litigant filed a petition using unsupported or inaccurate legal authorities.
- Jane Doe 1, et al. v. Mount Saint Mary High School Corporation
· United States District Court for the Western District of Oklahoma · Fabricated or misquoted citations
On 2026-05-13, in Jane Doe 1, et al. v. Mount Saint Mary High School Corporation, the Western District of Oklahoma publicly reprimanded counsel, ordered notice to the client, and required self-reporting to the Oklahoma Bar Association. Counsel filed a reply brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used.
- Henri Giovani Morales Jimenez v. Christopher Shanahan
· United States District Court for the Eastern District of New York · Fabricated or misquoted citations
On 2026-05-13, in Henri Giovani Morales Jimenez v. Christopher Shanahan, the Eastern District of New York denied habeas relief and admonished counsel for briefing that relied on an abrogated decision and a nonexistent case. Counsel filed a petition using unsupported or inaccurate legal authorities.
- In re: Latasha Transrina Kebe
· United States Bankruptcy Court for the Southern District of Florida · Fabricated or misquoted citations
On 2026-05-13, in In re: Latasha Transrina Kebe, the Southern District of Florida Bankruptcy Court imposed a Rule 9011 sanction against debtor's counsel equal to ten percent of the reply-fee award. Counsel filed a motion using authorities used for propositions they did not support.
- Christopher Gleason v. Julie Marcus
· District Court of Appeal of Florida, Second District · Fabricated or misquoted citations
On 2026-05-13, in Christopher Gleason v. Julie Marcus, District Court of Appeal of Florida, Second District warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities.
- Joseph Guy v. AFGE
· United States District Court for the Northern District of California · Fabricated or misquoted citations
On 2026-05-13, in Joseph Guy v. AFGE, the Northern District of California ordered the plaintiff to explain why sanctions should not issue for misquoting a discovery case. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.
- Jones v. Department of the Army
· United States Court of Appeals for the Federal Circuit · Fabricated or misquoted citations
On 2026-05-13, in Jones v. Department of the Army, the Federal Circuit warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed a petition using nonexistent or hallucinated authorities. No monetary sanction was imposed in this document.
- Gully v Varghese
· Supreme Court of New York · Fabricated or misquoted citations
On 2026-05-12, in Gully v Varghese, Supreme Court of New York struck the self-represented plaintiff's reply submission because its case citations could not be located. A self-represented litigant filed opposition papers using nonexistent or hallucinated authorities. The document links the problem to GAI.
- Jacobs v. Timberlake
· Louisiana Court of Appeal, Fifth Circuit · Fabricated or misquoted citations
The Louisiana Court of Appeal, Fifth Circuit on 2026-05-12 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities in Jacobs v. Timberlake. Counsel filed a brief with one fabricated case citation, including Harvey v. Harvey.
- Zena L. Powell v. The Borough of Bergenfield
· United States District Court for the District of New Jersey · Fabricated or misquoted citations
The District of New Jersey on 2026-05-12 ordered the self-represented plaintiff to show cause why sanctions or corrective action should not issue for the defective authorities in Zena L. Powell v. The Borough of Bergenfield. The self-represented plaintiff filed an opposition with one false case quotation and one misstated record or submission point.
- Pyle v. Glenn County Sheriff's Department
· United States District Court for the Eastern District of California · Fabricated or misquoted citations
The Eastern District of California on 2026-05-12 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Pyle v. Glenn County Sheriff's Department. The self-represented plaintiff filed a submission with one fabricated or AI-like submission item and one fabricated factual or other assertion, including Sheriff Owens.
- Armstrong v. City of Milwaukee
· United States District Court for the Eastern District of Wisconsin · Fabricated or misquoted citations
The Eastern District of Wisconsin on 2026-05-11 granted the County leave to file a corrected reply brief after the same-day removal of a fictitious citation and found no prejudice in Armstrong v. City of Milwaukee. Counsel filed a reply brief with one fabricated case citation.
- Dorothea Bell v. Kelly Bell
· Superior Court of Pennsylvania · Fabricated or misquoted citations
The Superior Court of Pennsylvania on 2026-05-11 vacated the portion of the custody order awarding primary physical custody, remanded, and noted the mother’s cited case was unlocatable in Dorothea Bell v. Kelly Bell. The self-represented mother filed a brief with one fabricated case citation.
- Burches v. Equifax Information Services, LLC, et al.
· United States District Court for the Eastern District of Louisiana · Fabricated or misquoted citations
The Eastern District of Louisiana on 2026-05-11 ordered the self-represented plaintiff to pay $500 for filing unverified or fabricated authorities in Burches v. Equifax Information Services, LLC, et al. The self-represented plaintiff filed a reply brief with two fabricated case citations, one false case quotation, and one mischaracterized case citation, including Hays v. HCA Holdings.
- DeVore v. McCombie
· United States District Court for the Northern District of Illinois · Fabricated or misquoted citations
The Northern District of Illinois on 2026-05-11 ordered defense counsel to file a declaration explaining how the brief was generated and how Beecham and Alvarez were located in DeVore v. McCombie. Counsel filed a motion with one fabricated case citation and one mischaracterized case citation, including Alvarez v. City of Chicago with page cites.
- Broyles v. McNeal
· Court of Appeals of Georgia · Fabricated or misquoted citations
The Court of Appeals of Georgia on 2026-05-08 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Broyles v. McNeal. The self-represented party filed a brief with one fabricated case citation.
- Kyne v. Ehima
· Connecticut Superior Court · Fabricated or misquoted citations
The Connecticut Superior Court on 2026-05-08 denied the name-change petition and contempt motion, added travel-notice directions, and noted likely AI-generated pleadings and nonexistent authority in Kyne v. Ehima. The self-represented father filed a pleading with two fabricated case citations and one fabricated factual or other assertion.
- Kristina Crist v. Roy Chris West, et al.
· United States District Court for the Western District of Oklahoma · Fabricated or misquoted citations
The Western District of Oklahoma on 2026-05-07 publicly reprimanded counsel, fined counsel $250, and ordered counsel to notify the client of the sanctions order in Kristina Crist v. Roy Chris West, et al. Counsel filed a brief with one fabricated case citation and one mischaracterized case citation.
- Neri v. Board of Education for Albuquerque Public Schools
· United States District Court for the District of New Mexico · Fabricated or misquoted citations
The District of New Mexico on 2026-05-07 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Neri v. Board of Education for Albuquerque Public Schools. The self-represented plaintiff filed a submission with one fabricated case citation and one fabricated or AI-like submission item, including United States v. Stone.
- Stokka v. Stokka
· Supreme Court of North Dakota · Fabricated or misquoted citations
The Supreme Court of North Dakota on 2026-05-07 awarded double costs and $1,000 in attorney fees because the brief cited irrelevant, fictitious, or nonexistent authorities in Stokka v. Stokka. The self-represented appellant filed a brief with one fabricated case citation.
- Joshua Harris v. Pinnacle Bank
· United States District Court for the Northern District of Mississippi · Fabricated or misquoted citations
The Northern District of Mississippi on 2026-05-07 dismissed the case with prejudice as a sanction for repeated fabricated citations and other Rule 11 violations in Joshua Harris v. Pinnacle Bank. The self-represented plaintiff filed a motion with three fabricated case citations, one false case quotation, four fabricated legal rules, and three misstated legal rules.
- Eric Tobler v. Stephen Tobler, et al.
· United States District Court for the Eastern District of Michigan · Fabricated or misquoted citations
The Eastern District of Michigan on 2026-05-07 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Eric Tobler v. Stephen Tobler, et al. The self-represented plaintiff filed a reply brief with one false case quotation, including Bunner v. Blow-Rite Insulation Co.
- Marriage of Nash
· Colorado Court of Appeals · Fabricated or misquoted citations
The Colorado Court of Appeals on 2026-05-07 affirmed the $1,665 attorney-fee sanction and awarded appellate fees and costs after noting nonexistent authorities in Marriage of Nash. The self-represented father filed a motion with one fabricated case citation and one mischaracterized case citation.
- Song Dow Lee, et al. v. HSBC Bank USA, National Association, et al.
· United States District Court for the Central District of California · Fabricated or misquoted citations
The Central District of California on 2026-05-07 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities in Song Dow Lee, et al. v. HSBC Bank USA, National Association, et al. Counsel filed an opposition with one fabricated case citation and one mischaracterized case citation, including Inc. v. Umpqua Holding Corp.
- Boersma v. Davenport
· Oregon Court of Appeals · Fabricated or misquoted citations
The Oregon Court of Appeals on 2026-05-06 ordered the self-represented plaintiff to pay $500 for filing unverified or fabricated authorities in Boersma v. Davenport. The self-represented plaintiff filed an opening brief with one fabricated case citation and one mischaracterized case citation.
- Terrance Anthony Norris v. JPMorgan Chase Bank N.A.
· United States District Court for the Eastern District of New York · Fabricated or misquoted citations
The Eastern District of New York on 2026-05-06 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Terrance Anthony Norris v. JPMorgan Chase Bank N.A. The self-represented plaintiff filed an opposition with one fabricated case citation and two false case quotations, including Inc. v. Homestead Vill. Ltd. P’ship.
- Gregoire v. Board of Trustees of SF BART
· United States District Court for the Northern District of California · Fabricated or misquoted citations
The Northern District of California on 2026-05-06 fined counsel $1,000, ordered live CLE, and required service of the order on the client and the California State Bar in Gregoire v. Board of Trustees of SF BART. Counsel filed an opposition with one fabricated case citation.
- Amanda Adams v. Allen Butler Construction, Inc.
· Texas Court of Appeals · Fabricated or misquoted citations
The Texas Court of Appeals on 2026-05-05 affirmed the order awarding attorney fees and dismissing the case, rejecting arguments supported by nonexistent cases and false quotations in Amanda Adams v. Allen Butler Construction, Inc. The self-represented party filed a brief with one fabricated case citation, one false case quotation, one mischaracterized case citation, and one misstated record or submission point.
- DOE, J. et al v. The Trustees of Columbia University
· Supreme Court of the State of New York · Fabricated or misquoted citations
The New York Supreme Court on 2026-05-05 granted dismissal motions, denied the Article 78 petition, and noted counsel’s withdrawal and apology for AI-fabricated citations in DOE, J. et al v. The Trustees of Columbia University. Counsel filed a reply brief with one fabricated case citation.
- Seeto v. Kendall
· United States District Court for the District of Nevada · Fabricated or misquoted citations
The District of Nevada on 2026-05-05 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Seeto v. Kendall. The self-represented plaintiff filed a brief with one false case quotation, one mischaracterized case citation, and one fabricated factual or other assertion, including Withrow v. Larkin.
- Van Deel v. A-Plus Contracting, LLC
· Missouri Court of Appeals · Fabricated or misquoted citations
The Missouri Court of Appeals on 2026-05-05 dismissed the appeal because the appellant’s brief violated appellate briefing rules and included inaccurate or nonexistent caselaw citations in Van Deel v. A-Plus Contracting, LLC. Counsel filed a brief with two fabricated case citations, including B.M. v. J.S.
- Randolph v. Erick Berscheid Trucking, LLC et al
· United States District Court for the District of Minnesota · Fabricated or misquoted citations
The District of Minnesota on 2026-05-05 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Randolph v. Erick Berscheid Trucking, LLC et al. The self-represented party filed a motion with one fabricated case citation and one false case quotation.
- Jessica Fuller v. Hyde School, et al.
· United States District Court for the District of Maine · Fabricated or misquoted citations
The District of Maine on 2026-05-05 struck the defective opposition, ordered counsel to serve the order on the client, complete CLE, and certify firm AI procedures in Jessica Fuller v. Hyde School, et al. Counsel filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation.
- Moore v. MC Architects Inc., et al.
· United States District Court for the District of Hawaii · Fabricated or misquoted citations
The District of Hawaii on 2026-05-05 ordered counsel to pay $1,000 after oppositions contained multiple record- and case-citation errors tied to AI use. Counsel accepted responsibility for filing the client’s AI-assisted material, and the court imposed the sanction for inadequate verification duties.
- Hannah Renee Payne v. The State
· Supreme Court of Georgia · Fabricated or misquoted citations
The Supreme Court of Georgia on 2026-05-05 vacated and remanded the trial-court order, barred the prosecutor from appearing for six months, and ordered twelve CLE hours in Hannah Renee Payne v. The State. The prosecutor and trial court filed an opposition with two fabricated case citations and two mischaracterized case citations.
- Regan Wilkes, et al. v. Canyons School District, et al.
· United States District Court for the District of Utah · Fabricated or misquoted citations
The District of Utah on 2026-05-04 imposed Rule 11 sanctions and ordered plaintiffs’ counsel to pay defendants $7,000 for expenses caused by non-existent case law in Regan Wilkes, et al. v. Canyons School District, et al. Counsel filed an opposition with three fabricated case citations and one mischaracterized case citation, including A.S. v. Norwalk Public Schools.
- Devin A. Robinson v. Velosio, LLC
· United States District Court for the District of Maryland · Fabricated or misquoted citations
The District of Maryland on 2026-05-04 granted defendants’ motion to dismiss and dismissed the third amended complaint with prejudice after noting non-existent cases and quotations in Devin A. Robinson v. Velosio, LLC. The self-represented party filed a reply brief with one fabricated case citation and one false case quotation.
- Eliott Williamson v. TransUnion LLC, Experian Information Solutions, Inc.
· United States Court of Appeals for the Eleventh Circuit · Fabricated or misquoted citations
The Eleventh Circuit on 2026-05-04 affirmed dismissal with prejudice after the magistrate judge found willful misuse of nonexistent and misquoted cases in Eliott Williamson v. TransUnion LLC, Experian Information Solutions, Inc. The self-represented party filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation.
- Drip Capital, Inc. v. SGM Socher Inc.
· Supreme Court of the State of New York · Fabricated or misquoted citations
The New York Supreme Court on 2026-05-01 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities in Drip Capital, Inc. v. SGM Socher Inc. Counsel filed an opposition with two fabricated case citations, including Gildea v Sheridan.
- Rasheem Carter, et al. v. UZGlobal LLC, et al.
· United States District Court for the District of New Mexico · Fabricated or misquoted citations
The District of New Mexico on 2026-05-01 fined counsel $1,000 payable to the clerk, ordered bar reporting, required proof of AI CLE, and barred passing costs to clients in Rasheem Carter, et al. v. UZGlobal LLC, et al. Counsel filed a brief with four fabricated case citations.
- Johnny Fuselier v. John S. Riscassi
· United States District Court for the Southern District of Mississippi · Fabricated or misquoted citations
The Southern District of Mississippi on 2026-05-01 admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct in Johnny Fuselier v. John S. Riscassi. Counsel filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation, including Rodriguez v. It’s Just Lunch.
- Yasmani Gurri Rubio v. Markwayne Mullin, et al.
· United States District Court for the District of Maryland · Fabricated or misquoted citations
The District of Maryland on 2026-05-01 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Yasmani Gurri Rubio v. Markwayne Mullin, et al. The self-represented party filed a pleading with five false case quotations, including Hahn v. United States.
- Sherdena Rocky Ali v. Carlos Efre Idiokitas
· Kentucky Court of Appeals · Fabricated or misquoted citations
The Kentucky Court of Appeals on 2026-05-01 warned the self-represented appellant to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Sherdena Rocky Ali v. Carlos Efre Idiokitas. The self-represented appellant filed a brief with two fabricated case citations.
- Chamberlain v. City of Albany
· United States District Court for the Middle District of Georgia · Fabricated or misquoted citations
The Middle District of Georgia on 2026-05-01 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Chamberlain v. City of Albany. The self-represented plaintiff filed a submission with one fabricated case citation.
- Richard Paul Smith v. Verra Mobility Corporation et al.
· United States District Court for the Middle District of Florida · Fabricated or misquoted citations
The Middle District of Florida on 2026-05-01 ordered counsel to notify the client about mis-cited and nonexistent cases and required a client-signed certification in Richard Paul Smith v. Verra Mobility Corporation et al. Counsel filed a motion with three fabricated case citations and one mischaracterized case citation, including Morgulis v. BusPatrol Am.