Courts on AI / monthly digest
What courts said about AI in August 2026
76 court-authored documents filed this month that substantively discuss generative AI. Fabricated or misquoted citations 68 · Self-represented litigants using AI 4 · Algorithms in criminal justice 2 · Substantive AI law courts cite 1 · Competence, fees and billing 1.
- State of Hawaiʻi v. Cody Presti
· Intermediate Court of Appeals of Hawaiʻi · Fabricated or misquoted citations
The Hawaiʻi Intermediate Court of Appeals affirms a criminal judgment while documenting numerous nonexistent or misidentified cases in Cody Presti’s self-represented opening brief. The court explains sanction authority for fake citations but declines to apply civil Rule 11 procedures in the direct criminal appeal.
- Reyes v. Bailey
· United States District Court for the District of New Mexico · Fabricated or misquoted citations
The District of New Mexico denies self-represented plaintiff Charles Reyes’s Rule 11 motion. The court holds defendants reasonably said Reyes may have fabricated a case citation because Reyes admitted he miscited a case in his amended complaint, and the remaining alleged misrepresentations did not support sanctions.
- Noble v. WMC Mortgage Corp.
· Appellate Court of Illinois, First District · Fabricated or misquoted citations
The Illinois Appellate Court affirms denial of Sanja Noble’s petition and addresses a hallucinated citation in her self-represented brief. The order says Noble cited Ferguson v. Georges, but the reporter citation corresponded to People v. Mott and did not support the standard of review.
- Booker v. The Kroger Co.
· United States District Court for the Northern District of Georgia · Fabricated or misquoted citations
The Northern District of Georgia sanctions plaintiff’s counsel in Booker v. Kroger after finding fake, false and misleading case authorities and an untruthful denial of AI use. The order imposes an $8,000 court fine and requires documentation of completed ethics and technology CLE.
- State v. Booker
· Ohio Court of Appeals, First Appellate District · Algorithms in criminal justice
The Ohio appellate court considers a suppression challenge arising from ShotSpotter and real-time crime-center surveillance. It describes how police used automated gunshot detection and video to locate suspects before affirming the search and conviction.
- Williams v. Dallas-Fort Worth International Airport Board
· United States District Court for the Northern District of Texas · Fabricated or misquoted citations
The Northern District of Texas dismisses Williams’s Section 1983 claims and warns that plaintiffs’ qualified-immunity briefing relied on nonexistent or inapposite cases. The court identifies Dawkins, Iko and Yates problems and cautions that generative-AI misrepresentations of law may trigger Rule 11 sanctions.
- Kiser v. DeSimone Auto Group
· Superior Court of Pennsylvania · Fabricated or misquoted citations
The Superior Court of Pennsylvania affirms judgment against Paige and Ty Kiser and identifies an unlocatable Com v. Reid citation in counsel’s appellate brief. The memorandum treats the unsupported argument as waived and quotes prior authority warning that counterfeit citations may be chatbot products.
- James v. Conley
· United States District Court for the Southern District of Florida · Fabricated or misquoted citations
The Southern District of Florida recommends denying Miami-Dade County’s Rule 11 motion against James on safe-harbor grounds but says counsel relied for months on unverified AI-generated IACP Training Keys. The recommendation calls the Keys AI hallucinations and recommends referral of four signing attorneys.
- Adams v. Matrix Providers Inc.
· United States District Court for the District of Colorado · Fabricated or misquoted citations
The District of Colorado denies Adams’s post-judgment motions and addresses counsel’s response to a show-cause order over a nonexistent Ricks v. Starbucks citation and other inaccurate authorities. The court admonishes counsel about possible AI-assisted research errors and separately imposes a $1,000 sanction for rule violations.
- Unger v. Unger
· Florida Fourth District Court of Appeal · Self-represented litigants using AI
The Florida appellate court repeats a prior warning to a self-represented former husband after striking his initial brief with leave to amend. The opinion cautions him about using artificial intelligence in documents filed with the court while resolving contempt issues.
- Turgeon v. Federal Home Loan Mortgage Corporation
· United States District Court for the District of New Hampshire · Fabricated or misquoted citations
The District of New Hampshire affirms bankruptcy dismissal and recounts that the bankruptcy court struck Noella Turgeon’s objection because it contained false, hallucinated case citations. The order rejects Turgeon’s due-process challenge, noting the bankruptcy court warned her about misleading filings and gave leave to amend.
- Potterf v. Wessels
· United States District Court for the Eastern District of Michigan · Fabricated or misquoted citations
The Eastern District of Michigan denies the Potterfs’ objections after they acknowledge using artificial intelligence to prepare them. The court identifies false quotations, nonexistent cases and mischaracterized authorities, declines to grant relief on Rule 11-violating objections, and warns that future false citations may bring sanctions.
- Johnson v. Nationstar Mortgage LLC
· United States District Court for the District of Maryland · Fabricated or misquoted citations
The District of Maryland dismisses Johnson’s mortgage-related claims and flags another hallucinated citation from the self-represented plaintiff. The court says Cooke v. Carrington Mortgage Services, as cited to the Fourth Circuit and Westlaw, does not exist, but declines further Rule 11 action because the case is dismissed.
- Shelbert v. Baxter International, Inc.
· United States District Court for the Northern District of Illinois · Fabricated or misquoted citations
The Northern District of Illinois resolves Shelbert’s motion to strike Baxter’s defenses and admonishes plaintiff’s counsel for citing Instituto for propositions the Seventh Circuit opinion does not contain. The court says the motion appeared AI-generated and warns both parties against false or hallucinated citations.
- Fairrow v. Easten
· Arizona Court of Appeals, Division Two · Fabricated or misquoted citations
The Arizona Court of Appeals affirms a family-law fee award and notes that self-represented appellant Brently Easten relied on Napp v. Napp, a case the court says does not exist at the cited location. The court suspects Breitbart-Napp was intended and declines appellate-fee sanctions.
- Ferm v. Agritech Properties
· United States District Court for the District of Utah · Self-represented litigants using AI
The District of Utah adopts a recommendation dismissing Ferm’s case and addresses signs that his objection was drafted with artificial intelligence. The court confines review to one specific objection, describes the remaining pages as AI slop, and cautions the self-represented plaintiff against possible AI-drafted memoranda.
- Kurelko v. Ballard
· United States District Court for the District of New Jersey · Fabricated or misquoted citations
The District of New Jersey denies Kurelko’s motions to disqualify state counsel and notes his first motion contained inaccurate or nonexistent case citations and quotations. The court declines sanctions at that time, admonishes the self-represented plaintiff, and warns that similar conduct may bring monetary penalties.
- AndDone, LLC v. Gaines
· United States District Court for the Western District of Missouri · Fabricated or misquoted citations
The Western District of Missouri enters default judgment against Shante Gaines and recounts an earlier Rule 11 show-cause order over citations to nonexistent cases and quotations in a November 2025 filing. The court notes Gaines did not respond to the show-cause order or comply with discovery obligations.
- United States v. Anderegg
· U.S. Court of Appeals for the Seventh Circuit · Substantive AI law courts cite
The Seventh Circuit addresses criminal charges alleging use of Stable Diffusion to create CSAM-like images. It analyzes how federal child-exploitation statutes apply to AI-generated depictions and reverses dismissal of key counts, making the opinion important for AI criminal-law doctrine.
- Ruiz v. Magellan Financial & Insurance Services
· United States District Court for the District of Arizona · Fabricated or misquoted citations
The District of Arizona publicly reprimands Elizabeth Tate after finding she filed three briefs with fake AI-generated quotations and a fourth with an inaccurate AI-generated case summary. The order says she used ChatGPT, violated Rule 11 and ethics duties, and must report the discipline where required.
- United States v. Aguilera
· U.S. Court of Appeals for the Ninth Circuit · Algorithms in criminal justice
The Ninth Circuit reviews a San Francisco ammunition conviction involving ShotSpotter alerts and witness reports. The opinion affirms suppression rulings tied to the initial police response while vacating the sentence for unrelated sentencing reasons.
- Perez v. Schaal
· Superior Court of California, County of Sacramento · Fabricated or misquoted citations
The Sacramento Superior Court rules on a demurrer and addresses Joseph Perez’s unsupported quotation from Adorh Farms. The court says the quotation does not appear in that opinion or any reported case, flags possible generative AI use, declines sanctions, and warns future fabricated authority may be sanctioned.
- Lohbeck v. Amazon.com Services, LLC
· United States District Court for the Eastern District of California · Fabricated or misquoted citations
The Eastern District of California recommends dismissal of Stephen Lohbeck’s claims and considers Amazon’s Rule 11 argument. The magistrate judge finds two quotations in Lohbeck’s sanctions motion do not appear in the cited cases, declines sanctions because he is self-represented, and warns that future false authority may be sanctionable.
- Disruptive Resources, LLC v. Ballistic Barrier Products Inc.
· United States District Court for the District of Delaware · Competence, fees and billing
The District of Delaware addresses plaintiff’s counsel’s disclosure that StrongSuit generated erroneous claim-construction briefing. The court notes counsel’s candor, withdrawn sections, and defense burden, declines Rule 11 sanctions, and warns that future AI mistakes in the case may result in sanctions.
- Full Standard Properties, LLC v. SJ 6070, LLC
· United States District Court for the Northern District of California · Fabricated or misquoted citations
The Northern District of California grants in part a renewed fee motion and discharges a sanctions order. The order records that plaintiff’s counsel reimbursed SJ 6070 $14,500 for expenses incurred addressing nonexistent cases cited in opposition to an earlier attorneys’ fees motion.
- Kasengela v. Kaiser Foundation Hospitals
· United States District Court for the Central District of California · Fabricated or misquoted citations
The Central District of California grants Cecile Kasengela’s remand motion while addressing non-existent quotations in her self-represented briefing. The court reiterates its standing order on AI-generated hallucinated caselaw, rejects her accusation against Kaiser, and says a lawyer would face significant sanctions.
- Dotson v. Bob Evans Farms, LLC
· United States District Court for the Central District of California · Fabricated or misquoted citations
The Central District of California denies Michael Dotson’s reconsideration application and identifies three quotations misattributed to Mission Power. The court says the language appears in Horne instead, describes the errors as AI-hallucination hallmarks, and orders counsel to show cause about sanctions and bar referral.
- Wilkinson v. Schmelzer
· Iowa Court of Appeals · Self-represented litigants using AI
The Iowa Court of Appeals declines sanctions for a self-represented litigant’s purported generative-AI use because no hallucinated case appears and a nonexistent rule citation might be a typo. The court separately awards attorney fees based on ordinary appellate factors.
- Kaspryak v. Stadarskyy
· Superior Court of Pennsylvania · Fabricated or misquoted citations
The Superior Court of Pennsylvania affirms dismissal of Zoryana Kaspryak’s partition action. The court finds that two citations in her self-represented reply brief are hallucinated, explains that the reporter citations lead to different cases, and concludes her claims are waived for unsupported and fabricated authority.
- Kelly v. Financial Industry Regulatory Authority
· United States District Court for the District of Nevada · Fabricated or misquoted citations
The District of Nevada dismisses William Lee Kelly’s second amended complaint against FINRA and warns him about AI-generated fake authority. The court finds several false quotes and nonexistent citations in his opposition and explains that future Rule 11 violations may lead to monetary or nonmonetary sanctions.
- Mitchell v. HIG Realty Credit Fund, LP
· Court of Appeals of Georgia · Self-represented litigants using AI
The Georgia Court of Appeals flags fictitious and irrelevant cases in a self-represented appellant’s briefing as suggestive of unchecked generative AI. It declines sanctions because the appellee was not hampered, but warns future filings may be sanctioned.
- Wilkinson v. Schmelzer
· Court of Appeals of Iowa · Fabricated or misquoted citations
The Court of Appeals of Iowa affirms a custody order and addresses a sanctions request based on alleged AI use. The court finds no hallucinated case, says it cannot determine whether a nonexistent appellate rule citation is a typo or unchecked AI output, and declines AI-use sanctions.
- Snisko v. Cascade Funding Mortgage Trust HB4
· United States District Court for the Northern District of Illinois · Fabricated or misquoted citations
The Northern District of Illinois affirms a bankruptcy abstention order and identifies false quotations and erroneous legal statements in Peter Snisko’s appellate brief. The court says counsel doubled down after appellee flagged the errors and orders attorney Martin Spencer to show cause regarding fabricated citations and other misrepresentations.
- Mitchell v. HIG Realty Credit Fund, L.P.
· Court of Appeals of Georgia · Fabricated or misquoted citations
The Court of Appeals of Georgia affirms summary judgment for HIG Realty Credit Fund and warns Trentiss Mitchell about citations in his self-represented appellate briefing. The court identifies two non-existent cases and two unrelated cases, says the defects suggest unchecked generative AI, and declines sanctions.
- In re Marriage of Dillon
· California Court of Appeal, Fourth Appellate District, Division One · Fabricated or misquoted citations
The California Court of Appeal affirms an order in Marriage of Dillon and addresses three miscited cases in the respondent’s self-represented brief. The court disregards arguments based on the hallucinated citations, declines sanctions because none were sought, and denies prevailing-party costs on appeal.
- LeDoux v. Outliers, Inc.
· United States District Court for the Western District of Washington · Fabricated or misquoted citations
The Western District of Washington grants summary judgment for Outliers and addresses AI-generated citation tables used in expert materials. The court recounts sanctions against counsel, finds Dr. Holguin’s hallucinated citations undermine his report’s reliability, and excludes that expert opinion under Rule 702 and Daubert.
- In re Marriage of Muriel and Farris
· Court of Appeals of Washington, Division Two · Fabricated or misquoted citations
The Washington Court of Appeals affirms a parenting plan and awards Rebekah Muriel fees for responding to Jonathan Farris’s response brief. The court says the brief twice cited nonexistent Marriage of Sanjuan, surmises AI-assisted drafting, deems the filing frivolous, and sets the fee amount for the commissioner.
- Garcia Perez v. Blanche
· United States District Court for the Western District of Texas · Fabricated or misquoted citations
The Western District of Texas orders more briefing in a habeas case and cautions Gilberto Garcia Perez’s counsel. The order says most cases cited in petitioner’s reply do not exist, lists six hallucinated authorities including one purportedly from the same court, and warns future inaccurate AI citations may be sanctionable.
- Kourradi v. Christopher
· Court of Appeals of Texas, First District · Fabricated or misquoted citations
The Texas First Court of Appeals strikes Manny Kourradi’s fourth self-represented brief and dismisses the appeal. The memorandum identifies multiple unlocatable or mismatched Westlaw-style citations, says the errors are at best partially fabricated, and treats the defective briefing as grounds for dismissal.
- Sani v. Institute for Human Reproduction
· Appellate Court of Illinois, First District · Fabricated or misquoted citations
The Illinois Appellate Court affirms dismissal of Lemna Sani’s complaint and admonishes her about a nonexistent citation in her self-represented opening brief. The court says Helm v. Illinois Central Railroad does not exist and that the reporter citation leads to People v. Hardy, an unrelated criminal case.
- Rivard v. Vermont Department of Corrections
· Superior Court of Vermont, Windham Unit · Fabricated or misquoted citations
The Vermont Superior Court grants Brattleboro’s sanctions motion against Jeffrey Rivard and imposes a civil-division prefiling injunction. The order cites Rivard’s prior non-existent authorities, mismatched Vermont Reports citations, spurious record quotations, and repeated warnings that had not changed his filing conduct.
- Harris v. Wray
· United States District Court for the Southern District of Indiana · Fabricated or misquoted citations
The Southern District of Indiana dismisses Darryl Harris’s complaint without prejudice and warns him about an incorrect citation in a service-extension motion. The court says the Walsh docket number linked to a different case, the Westlaw citation led nowhere, and future Rule 11 violations may be sanctioned.
- Brankle v. Schmell
· Court of Appeals of Indiana · Fabricated or misquoted citations
The Court of Appeals of Indiana affirms the denial of David Brankle’s motion to compel and a $1,546 expenses award. The memorandum quotes the trial court’s finding that Brankle cited nonexistent rules and fictitious cases suggesting ChatGPT use, and holds hallucinated authorities cannot substantially justify the motion.
- Guerra-Quezada v. United States
· United States Court of Appeals for the Fifth Circuit · Fabricated or misquoted citations
The Fifth Circuit resolves consolidated immigration appeals and warns appellants’ counsel about systematically defective authorities. The opinion identifies quotations falsely attributed to Ng Fung Ho, an incorrect circuit attribution for Doe v. McAleenan, and a quotation from an Afroyim dissent misattributed to the majority.
- Boettcher v. Boettcher
· Arizona Court of Appeals, Division One · Fabricated or misquoted citations
The Arizona Court of Appeals grants partial special-action relief in a contempt dispute and addresses a quotation in Father’s filing. The court says neither cited case contains the quoted jurisdictional rule, it cannot find the language in Arizona law, strikes the false quotation, and declines sanctions.
- Davenport v. Churilla
· United States District Court for the Western District of Pennsylvania · Fabricated or misquoted citations
The Western District of Pennsylvania resolves motions in Dyran Davenport’s civil-rights action and warns him about inaccurate filings. The court identifies nonexistent Loder v. City of Philadelphia as an AI-hallucinated citation in his opposition but still accepts his accrual argument based on other relevant authority.
- Rose v. Arts Bonita, Inc.
· United States District Court for the Middle District of Florida · Fabricated or misquoted citations
The Middle District of Florida partly grants Arts Bonita’s motion about generative AI use. The court finds Julia Rose cited a nonexistent Prousalis case, later withdrew it as incorrect or unverifiable, declines sanctions for a single hallucinated citation, and warns future inaccurate authority may be sanctioned.
- JMOR Properties, LLC v. Artist Alley Townhomes, LLC
· District Court of Appeal of Florida, Fourth District · Fabricated or misquoted citations
The Florida Fourth District Court of Appeal refers Barry Leff to the Florida Bar after a certiorari petition cited false AI-draft authority. Counsel says he filed the wrong draft; the court finds the petition misrepresented jurisdictional law, lacked controlling adverse authority, and cited non-existent authority.
- Chapman v. City of Priceville
· United States District Court for the Northern District of Alabama · Fabricated or misquoted citations
The Northern District of Alabama sanctions Scott Morro for false citations, quotations, and legal representations in Chapman v. City of Priceville. The court treats client-drafted filings submitted without verification like unchecked AI work, publicly reprimands Morro, orders notice in pending cases, and directs publication.
- Voyton v. Voyton
· United States District Court for the Middle District of Pennsylvania · Fabricated or misquoted citations
The Middle District of Pennsylvania adopts a recommendation to dismiss Courtney Voyton’s complaint with leave to amend and admonishes her AI use. The memorandum says she misrepresented 42 Pa. Cons. Stat. § 5522 and advanced AI-steered ghost arguments unrelated to the report, requiring future AI-use affidavits.
- Eyong v. 72 Barrow St. Realty Corp.
· Appellate Court of Maryland · Fabricated or misquoted citations
The Appellate Court of Maryland affirms judgment for 72 Barrow St. Realty and taxes costs to Simon Eyong. The per curiam opinion notes earlier orders striking large portions of his self-represented briefs for fictitious legal citations and inaccurate summaries, and leaves a sanctions motion for remand.
- Nesbitt v. Trans Union, LLC
· United States District Court for the Western District of Arkansas · Fabricated or misquoted citations
The Western District of Arkansas sanctions Nicholas Nesbitt in a consumer-credit case by imposing filing restrictions. The court says he relied on AI for legal research and writing, filed at least two motions with fabricated cases, apologized after a Rule 11 show-cause order, and continued filing improper papers.
- Palumbo v. Palumbo
· Court of Chancery of the State of Delaware · Fabricated or misquoted citations
The Delaware Court of Chancery master recommends removing Gregory Palumbo as trustee, denying his accounting petition, and shifting fees. The report says the self-represented disbarred attorney cited Kuroda and Koninklijke for propositions they do not support, treated fictitious quotations as an AI hallmark, and found subjective bad faith.
- WRI Summit REIT LP v. Kuerschner
· Arizona Court of Appeals, Division One · Fabricated or misquoted citations
The Arizona Court of Appeals dismisses Stefanie Kuerschner’s appeal and awards appellate fees and costs. The court says her brief lacked record citations, repeatedly misquoted or misstated cases, included one unlocatable case, and repeated citation problems despite earlier warnings about AI-related errors.
- Hack v. Preston
· United States District Court for the District of Utah · Fabricated or misquoted citations
The District of Utah addresses Jayne Stephens’s declaration that ChatGPT assisted her filings. The order notes a mischaracterized assertion based on an improperly cited Tenth Circuit case, requires future assistance disclosures, and cautions that GenAI-related Rule 11 violations may be sanctioned.
- Brown v. Real Estate Capital of America, LLC
· Supreme Court of New York, New York County · Fabricated or misquoted citations
The New York Supreme Court decides a broker-dispute dismissal motion and denies sanctions requested on reply. The court says plaintiffs attributed a quotation to a case where it did not appear, but even treating it as an AI fabrication did not warrant a monetary sanction.
- Wayne K. Smith, Sr. v. Polk County
· United States District Court for the Western District of North Carolina · Fabricated or misquoted citations
The Western District of North Carolina resolves summary-judgment and spoliation motions and discharges an AI show-cause order. The court says plaintiff’s counsel accepted responsibility for fabricated quotations but did not explain their origin or substantiate claims about an unnamed AI program.
- In the matter of Machinsky
· Massachusetts Land Court, Plymouth District · Fabricated or misquoted citations
The Massachusetts Land Court denies Robert Machinsky’s self-represented motion to dismiss in a registered-land proceeding. A footnote documents false statutory quotation, irrelevant recusal authority, Rule 70 cases that do not address Rule 70, and warns about AI-generated hallucinations and false citations.
- United States v. Smith
· United States District Court for the Northern District of Illinois · Fabricated or misquoted citations
The Northern District of Illinois denies Darren Smith’s § 2255 motion and issues a sanctions show-cause order. The court identifies a nonexistent Johnson case, false quotations from real cases, and nearly a dozen falsified cases or quotations, then orders Smith to explain why monetary sanctions should not issue.
- In re BFI Waste Systems of Tennessee
· United States District Court for the Middle District of Tennessee · Fabricated or misquoted citations
The Middle District of Tennessee sanctions attorney Louis W. Ringger III after a filing contained hallucinated quotations and misleading citations. The order says unchecked AI-generated content contributed to the deficiencies, publicly reprimands Ringger, and orders him to pay $1,500 to the clerk.
- Burgess v. Greater Cleveland Regional Transit Authority
· United States District Court for the Northern District of Ohio · Fabricated or misquoted citations
The Northern District of Ohio rules on Greater Cleveland Regional Transit Authority’s motion to dismiss and flags a Shimola citation. The court says the cited reporter page points to another case, Shimola does not support the proposition, and future hallucinated citations may be sanctioned.
- Kadlaskar v. United States Citizenship and Immigration Services
· United States District Court for the District of Nebraska · Fabricated or misquoted citations
The District of Nebraska grants an EAJA fee request and cautions plaintiff’s counsel over a cited Peterson decision. The order says the Eighth Circuit citation does not exist, a similarly named case lacks the quoted language, and Nebraska’s AI rule requires verification.
- Mohamed Ali v. Saeed Osman
· Supreme Court of North Dakota · Fabricated or misquoted citations
The North Dakota Supreme Court affirms and remands in a divorce dispute and separately sanctions self-represented appellant Mojahid Osman. The court says Osman corrected two nonexistent citations but ignored many unrelated authorities, and awards Sara Ali $1,000 for multiple fictitious or nonexistent citation errors.
- Cain v. Hyatt Corporation
· United States District Court for the Western District of Texas · Fabricated or misquoted citations
The Western District of Texas issues a show-cause order in Cain v. Hyatt. The order says plaintiffs cited nonexistent Henry v. Kroger authority in a dismissal response and requires attorney Daniel Miguel Hernandez to appear under Rule 11(c)(3).
- San Antonio Independent School District v. Becerra
· Texas Court of Appeals, Fourth District · Fabricated or misquoted citations
The Texas Fourth Court of Appeals reverses denial of SAISD’s jurisdiction plea and renders dismissal. Before reaching the merits, the court identifies four hallucinated opinions in Becerra’s brief and cautions counsel that similar future issues will not be tolerated.
- Calenzo v. Waste Management, Inc.
· United States District Court for the Northern District of New York · Fabricated or misquoted citations
The Northern District of New York grants Waste Management’s dismissal motion, allows limited amendment, and warns self-represented plaintiff Mary-Rose Calenzo. The court identifies at least four nonexistent opinions in her opposition and directs her to stop using hallucinated or fabricated case law.
- Ulish Kerry Terrace Booker, III v. U.S. Bank National Association
· United States District Court for the District of Connecticut · Fabricated or misquoted citations
The District of Connecticut admonishes self-represented debtor Ulish Booker in a bankruptcy appeal. After a show-cause hearing, the court finds his briefs contained fabricated cases, erroneous citations, and incorrect quotations produced with Gemini Pro, Perplexity, Cetient Legal AI, and ChatGPT.
- Cristancho v. SWBC Mortgage Corporation
· United States District Court for the Southern District of Texas · Fabricated or misquoted citations
The Southern District of Texas magistrate judge recommends summary judgment for SWBC Mortgage and Cenlar. The recommendation says plaintiffs’ counsel cited fabricated Pointe West and Tractebel cases, misused other authorities, and is reminded of Rule 11 duties.
- Whitehead v. Moore
· Missouri Court of Appeals, Western District · Fabricated or misquoted citations
The Missouri Court of Appeals dismisses self-represented father Zackery Moore’s family-access appeal because he did not supply the record needed for review. A footnote says his brief also contained two nonexistent reporter citations and one misrepresented holding, independently supporting dismissal.
- Barteca Holdings LLC v. Tacobarn Newtown LLC
· United States District Court for the District of Connecticut · Fabricated or misquoted citations
The District of Connecticut sanctions defense counsel Hilary Miller in a trademark dispute. The order says Miller used Open Law, Claude, and ChatGPT, submitted unverified AI-generated legal authorities with nonexistent quotations and erroneous citations, and must pay $3,500 with a grievance referral.
- Moore v. Aldridge Pite LLP
· United States District Court for the Western District of Texas · Fabricated or misquoted citations
The Western District of Texas adopts an R&R and dismisses the remaining defendant without prejudice. The order catalogs repeated invented quotations, unsupported case descriptions, and possible AI use, then warns the self-represented plaintiffs to verify all authorities and quotations in future filings.
- Bisher v. Civic
· Superior Court of Pennsylvania · Fabricated or misquoted citations
The Superior Court of Pennsylvania affirms summary judgment in a medical-malpractice appeal. A footnote identifies three cited cases that do not exist, reminds the self-represented appellants that authority must be pertinent, and warns that substantial brief defects can justify dismissal.
- State v. Davis
· Ohio Court of Appeals, Seventh Appellate District · Fabricated or misquoted citations
The Ohio Seventh District affirms Jacob Davis’s speeding conviction. The opinion says Davis disclosed using generative AI for his nonconforming brief, and a cited Sanchez case does not discuss the indefinite-tolling proposition he raised, possibly reflecting an AI hallucination.
- Forney v. Township of Cary, North Carolina
· United States District Court for the Eastern District of North Carolina · Fabricated or misquoted citations
The Eastern District of North Carolina recommends dismissal of Damon Forney’s employment case as untimely and sanctions attorney Lucas Colantonio. The order says Colantonio repeatedly submitted fabricated authority after a warning, must pay Cary’s response fees, and is referred to the North Carolina State Bar.
- Jabbari v. Omidvar
· United States District Court for the Central District of California · Fabricated or misquoted citations
The Central District of California manages a transferred pro se case by striking improper filings and imposing filing limits. The court says Jabbari’s papers contain AI hallmarks and fabricated legal authorities, then orders him to show cause why Rule 11 or inherent-authority sanctions should not issue.
- Perry v. Social Security Administration, Commissioner
· United States District Court for the Northern District of Alabama · Fabricated or misquoted citations
The Northern District of Alabama dismisses Domeneque Perry’s Social Security claim without prejudice and denies TRO and amendment motions. The court notes the Commissioner raised fabricated citations and misrepresentations in Perry’s TRO motion and warns this is Perry’s only warning before sanctions.