{ "dataset": "SafeLegalAI — US court decisions on generative AI", "license": "CC BY 4.0 for the coding; United States court documents are public domain", "notice": "Provided as is, without warranty of any kind. Not legal advice; no lawyer–client relationship. SafeLegalAI (published by Cognesio LLP) records findings made by courts, regulators and vendors' own published pages; the linked official documents are the record. Third-party names and marks identify their owners' products or bodies and imply no affiliation or endorsement. Terms: https://safelegalai.com/disclaimer", "url": "https://safelegalai.com/courts", "repository": "https://github.com/SafeLegalAI/us-genai-court-opinions", "huggingface": "https://huggingface.co/datasets/safelegalaidata/us-genai-court-opinions", "generated": "2026-09-08T07:15:06.243Z", "version": "0.1.1", "count": 567, "decisions": [ { "ai_passage": "While reviewing appellee’s brief, the court discovered that it contained multiple citations to cases that the court was unable to locate or confirm as legitimate. On June 22, we issued an order requiring appellee to show cause “why the court should not strike its brief for citing nonexistent cases that are possibly the product of artificial intelligence (AI) hallucinations.” The next day, one of appellee’s attorneys at the firm, Loishirl W. Hall, filed a response in her own capacity. Ms. Hall confirmed that four of the brief’s cited authorities did not exist. She acknowledged that these citations were “not legitimate legal authority” and “should not have appeared in a brief filed with this Court.” Ms. Hall explained that she had “used Google’s generative artificial intelligence search tool to assist in locating case authority” and did not verify the existence or accuracy of those citations before filing the brief.", "ai_tool_named": "Google’s generative artificial intelligence search tool", "archive_url": null, "case_name": "Douglas v. Deutsche Bank National Trust Company", "citation": null, "cited_authorities": [ "Abadie v. District of Columbia", "Cason v. Nat’l Consumer Co-op Bank", "Osborne v. District of Columbia", "Woods v. United States" ], "court": "District of Columbia Court of Appeals", "court_code": "dc", "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10965874/douglas-v-deutsche-bank-national-trust-co-published-order/", "date_filed": "2026-09-03", "decision_id": "dc-2026-douglas-v-deutsche-bank-national-trust", "disposition": "The court struck Deutsche Bank's appellee brief and referred the matter to the Office of Disciplinary Counsel.", "docket_number": "24-CV-1099", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": "Google’s generative artificial intelligence search tool", "conduct": "Counsel cited four nonexistent cases in an appellee brief after using Google’s generative AI search tool without verifying the authorities.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": "Official D.C. Courts URL returned 403 to curl; read the matching public-domain PDF from CourtListener storage and recorded its SHA-256.", "primary_topic": "fabricated-citations", "source_url": "https://www.dccourts.gov/sites/default/files/2026-09/Douglas%20v.%20Deutsche%20Bank%20Nat%27l%20Trt%20Co.%2024-CV-1099%20ORDER.pdf", "state": "DC", "summary": "The District of Columbia Court of Appeals strikes Deutsche Bank’s appellee brief after counsel admits that four cited authorities generated through Google’s AI search did not exist. The court also refers the matter to disciplinary counsel and stresses that signed appellate briefs require verified authorities.", "text_sha256": "e69cfc9a0871eeace25dbcf259a2fd6ca276d1d6f3519a4d7407c720d14fc538", "topics": [ "fabricated-citations" ], "tracker_slug": "douglas-v-deutsche-bank-national-trust", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/dc-2026-douglas-v-deutsche-bank-national-trust", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/dc-2026-douglas-v-deutsche-bank-national-trust" }, { "decision_id": "monson-iowa-2026", "case_name": "In re the Marriage of Monson", "court": "Iowa Court of Appeals", "court_code": "iowactapp", "court_level": "state-appellate", "state": "IA", "date_filed": "2026-09-02", "citation": null, "docket_number": "25-1029", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "artificial intelligence tool", "disposition": "The court affirmed the dissolution decree and warned that inaccurate AI-assisted appellate filings waste resources.", "ai_passage": "During our review of Caroline’s appellate briefing, we discovered that she repeatedly cited an Iowa case that does not exist. And she cited other cases and statutes that do exist but do not stand for the propositions for which she cited them. It thus appears likely that she misused an artificial intelligence tool when preparing her briefs. We recognize that Caroline is representing herself. “But we do not have a double standard for those represented by counsel and those who are unrepresented—we expect all to follow our procedures.” Locher & Davis, PLC v. Ruth F. Woller Revocable Tr., No. 23-0944, 2024 WL 4761531, at *4 (Iowa Ct. App. Nov. 13, 2024). And we have repeatedly “stress[ed] that self- represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.” Luke v. Iowa Dep’t of Health & Hum. Servs., 29 N.W.3d 635, 636 (Iowa Ct. App. 2025); see also Nisland Asset Inv., LLC v. Gericke, No. 25-0659, 2026 WL 1162553, at *1 (Iowa Ct. App. Apr. 29, 2026); In re W.G., No. 25-1916, 11 2026 WL 892837, at *2–3 (Iowa Ct. App. Apr. 1, 2026); Goma v. Hundley, No. 25-0619, 2026 WL 892643, at *8 (Iowa Ct. App. Apr. 1, 2026); In re R.A., 24-1629, 2025 WL 2793560, at *2–4 (Iowa Ct. App. Oct. 1, 2025). Submitting inaccurate appellate filings wastes party and judicial resources, hinders the filer’s ability to successfully advocate, and ultimately slows down the process of resolving the appeal.", "cited_authorities": [ "Luke v. Iowa Dep’t of Health & Human Services, 29 N.W.3d 635 (Iowa Ct. App. 2025)", "Locher & Davis, PLC v. Ruth F. Woller Revocable Trust, 2024 WL 4761531 (Iowa Ct. App. Nov. 13, 2024)" ], "summary": "The Iowa Court of Appeals identifies likely AI misuse in a self-represented divorce appellant’s brief, including nonexistent and mischaracterized authorities. The court still considers discernible claims, affirms the decree, and warns that inaccurate AI-assisted filings waste resources.", "lead_source": [ "CourtListener anonymous search pro-se-chatgpt.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10964855/x/", "text_sha256": "2a816438b502b5bce9fdca266d1438ce55a33b5ee2a77afbd685da0c6976bc3d", "source_url": "https://www.iowacourts.gov/courtcases/26168/embed/CourtAppealsOpinion", "archive_url": "https://web.archive.org/web/20260907215503/https://www.iowacourts.gov/courtcases/26168/embed/CourtAppealsOpinion", "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/monson-iowa-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/monson-iowa-2026" }, { "ai_passage": "Of the eleven cases this court was unable to locate, six cases include citations that indicate a volume and reporter that correspond with a different case entirely: • On page 8 of the Opening Brief, Presti relies on “State V. Alves, 45. Haw.296,” but that citation leads to an unrelated case, State v. Pokini, 45 Haw. 295, 367 P.2d 499 (1961). • On page 17 of the Opening Brief, Presti relies on “State v. Bonds, 592 N.W.2d 262 (Minn. 1999),” but that citation leads to an unrelated case in another jurisdiction, Jackson v. DeWitt, 592 N.W.2d 262 (Wis. Ct. App. 1999). • On pages 28-29 of the Opening Brief, Presti relies on “State v. Pune, 94 Hawaiʻi 200 (2000),” but that citation leads to a table of fourteen unreported opinions that does not include State v. Pune. A Westlaw search of “State v. Pune” returns zero results in any jurisdiction. ... In these instances, the relied upon authority simply does not exist. We pause to note that Presti’s Opening Brief is just the next example of the alarming rise of citations to fake cases by attorneys and self-represented litigants in this jurisdiction and nationally.", "ai_tool_named": null, "archive_url": null, "case_name": "State of Hawaiʻi v. Cody Presti", "citation": null, "cited_authorities": [ "State v. Alves", "State v. Pokini, 45 Haw. 295, 367 P.2d 499 (1961)", "State v. Bonds", "Jackson v. DeWitt, 592 N.W.2d 262 (Wis. Ct. App. 1999)", "State v. Pune", "State v. Branch, 636 P.2d 421 (Or. Ct. App. 1981)" ], "court": "Intermediate Court of Appeals of Hawaiʻi", "court_code": "hawapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10964720/state-v-presti/", "date_filed": "2026-08-31", "decision_id": "hawapp-2026-state-v-presti", "disposition": "The court affirmed the judgment and declined to sanction the self-represented criminal appellant for nonexistent citations.", "docket_number": "CAAP-24-0000826", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant relied on multiple nonexistent or mismatched appellate cases, including State v. Pune and State v. Alves.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": null, "primary_topic": "fabricated-citations", "source_url": "https://www.courts.state.hi.us/wp-content/uploads/2026/08/CAAP-24-0000826.pdf", "state": "HI", "summary": "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.", "text_sha256": "983e596930484529baeea338a537e03413d0827deb34b89415509f37bf3325f5", "topics": [ "fabricated-citations" ], "tracker_slug": "state-v-presti", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/hawapp-2026-state-v-presti", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/hawapp-2026-state-v-presti" }, { "ai_passage": "Mr. Reyes appears to argue that Defendants have violated Rule 11 by “misrepresenting the record and the law.” Doc. 61 at 2. He contends that Defendants: (1) misrepresented that he hallucinated a case citation in his pleadings; (2) “failed to comply with 28 U.S.C. § 1446(a) by omitting critical state-court filings from the Notice of Removal”; (3) moved to quash the summons issued for improper service based on false factual assertions; (4) asserted an affirmative defense unsupported by existing law; and (5) failed to specifically controvert his statement of undisputed facts in their response to his motions for summary judgment, as required by Federal Rule of Civil Procedure 56. ... The Court rejects Mr. Reyes’s arguments and denies the motion. First, Mr. Reyes admits that he miscited a case in his Amended Complaint. See Doc. 65. Thus, Defendants’ contention that Mr. Reyes may have fabricated a case was reasonable.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907204225/https://storage.courtlistener.com/recap/gov.uscourts.nmd.505858/gov.uscourts.nmd.505858.87.0.pdf", "case_name": "Reyes v. Bailey", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "28 U.S.C. § 1446(a)", "Fed. R. Civ. P. 56" ], "court": "United States District Court for the District of New Mexico", "court_code": "nmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/docket/69106401/87/reyes-v-lcso/", "date_filed": "2026-08-28", "decision_id": "nmd-2026-reyes-v-bailey", "disposition": "The court denied Reyes's motion for sanctions and denied a motion to strike as moot.", "docket_number": "2:24-cv-00831-KG-KRS", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff admitted misciting a case; defendants characterized the citation as possibly fabricated, and the court found that characterization reasonable.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": "Caption lists Bryce Bailey; CourtListener docket caption is Reyes v. LCSO.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.nmd.505858/gov.uscourts.nmd.505858.87.0.pdf", "state": "NM", "summary": "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.", "text_sha256": "a254ad5274b0457633043494557eafc903fdd71be9c83a76c14dd298b3b52eb0", "topics": [ "fabricated-citations" ], "tracker_slug": "reyes-v-bailey", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/nmd-2026-reyes-v-bailey", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nmd-2026-reyes-v-bailey" }, { "ai_passage": "Arguments that are unsupported by citation do not meet the requirements of Rule 341(h)(7) and are procedurally defaulted. Wing, 2016 IL App (1st) 153517, ¶11. We also note that Noble’s brief contains a “hallucinated” citation on page 10, which occurs when AI-generated responses are used and not verified. See In re Baby Boy, 2025 IL App (4th) 241427, ¶¶ 102-105. She cites Ferguson v. Georges, 389 Ill. App. 3d 543, 553-54 (2010) to state the standard of review for the circuit court’s denial of leave to amend. However, our research has determined that the citation is actually contained within People v. Mott, 389 Ill. App. 3d 539 (2009) and does not address the standard of review relied on.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907204233/https://websitedc.s3.amazonaws.com/documents/Noble_v._WMC_Mortgage_Corp_USA_28_August_2026.pdf", "case_name": "Noble v. WMC Mortgage Corp.", "citation": "2026 IL App (1st) 251168-U", "cited_authorities": [ "Ill. S. Ct. R. 341(h)(7)", "Wing v. Chicago Transit Authority, 2016 IL App (1st) 153517", "In re Baby Boy, 2025 IL App (4th) 241427", "Ferguson v. Georges, 389 Ill. App. 3d 543 (2010)", "People v. Mott, 389 Ill. App. 3d 539 (2009)" ], "court": "Appellate Court of Illinois, First District", "court_code": "illappct", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-28", "decision_id": "illappct-2026-noble-v-wmc-mortgage", "disposition": "The court affirmed the denial of Noble's petition and noted a hallucinated citation in her brief.", "docket_number": "1-25-1168", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant cited Ferguson v. Georges at a reporter location that actually contained People v. Mott and did not support her standard-of-review point.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Could not locate the official Illinois Courts PDF by quick CourtListener and citation searches; read the court-authored PDF from the Charlotin mirror.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2999/Noble_v._WMC_Mortgage_Corp_USA_28_August_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "c3072690fa525569ed483a2c275938f849c2c5c8c6a60586d013ae8b321e737e", "topics": [ "fabricated-citations" ], "tracker_slug": "noble-v-wmc-mortgage", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/illappct-2026-noble-v-wmc-mortgage", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illappct-2026-noble-v-wmc-mortgage" }, { "ai_passage": "This matter is before the Court on its previous Order to Show Cause [ECF 53] directed to counsel for Plaintiff to explain why he should not be sanctioned for using fake or hallucinated case authorities, as well as misrepresenting the content of real case authorities, in his filings with the Court. Because Plaintiff’s counsel, as an officer of the Court, deliberately lied to this Court about his artificial intelligence (AI) use and because Plaintiff’s counsel’s response to the Order to Show Cause [ECF 58] lacks credibility, is evasive, and seeks to divert accountability from his own misconduct, sanctions are warranted. ... The Court’s Order to Show Cause highlighted four purported cases cited by Plaintiff’s counsel that represented the most egregious examples of fake, false, and misleading case authorities. Counsel for Plaintiff is ordered to pay a fine of $1,000 for each of these fake, false, and misleading case authorities. In addition, this fine will be doubled as a result of Plaintiff’s counsel’s lies to this Court. Accordingly, Plaintiff’s counsel’s total fine for his repeated Rule 11 violations is $8,000, payable to the registry of the Court.", "ai_tool_named": null, "archive_url": "http://web.archive.org/web/20260907204250/https://storage.courtlistener.com/recap/gov.uscourts.gand.358237/gov.uscourts.gand.358237.66.0.pdf", "case_name": "Booker v. The Kroger Co.", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Northern District of Georgia", "court_code": "gand", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/docket/73188597/66/booker-v-the-kroger-co/", "date_filed": "2026-08-28", "decision_id": "gand-2026-booker-v-kroger", "disposition": "The court sanctioned plaintiff's counsel $8,000 and ordered proof of completed ethics and technology CLE training.", "docket_number": "1:26-cv-02006-SDG", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel filed four fake, false or misleading case authorities and falsely told the court he had not used AI tools.", "currency": "USD", "monetary_penalty": 8000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": "Court-authored PACER document read from CourtListener RECAP storage. A GovInfo package probe did not locate the order.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.gand.358237/gov.uscourts.gand.358237.66.0.pdf", "state": "GA", "summary": "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.", "text_sha256": "ea403780c57123eac0dfa4f031df36280cd950922273c0674dadacbace1cc4c6", "topics": [ "fabricated-citations" ], "tracker_slug": "booker-v-kroger", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/gand-2026-booker-v-kroger", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gand-2026-booker-v-kroger" }, { "decision_id": "booker-ohio-2026", "case_name": "State v. Booker", "court": "Ohio Court of Appeals, First Appellate District", "court_code": "ohioctapp", "court_level": "state-appellate", "state": "OH", "date_filed": "2026-08-28", "citation": "2026-Ohio-3371", "docket_number": "C-250699", "document_type": "opinion", "topics": [ "criminal-justice-algorithms" ], "primary_topic": "criminal-justice-algorithms", "court_used_ai": false, "ai_tool_named": "ShotSpotter", "disposition": "The court affirmed denial of suppression and affirmed Booker’s conviction.", "ai_passage": "The Cincinnati Police Department deploys surveillance technology to monitor Cincinnati’s residents and visitors. Cincinnati Police Officer Benjamin Williamson testified that ShotSpotter detected the sound of gunshots at the intersection of Vine Street and Green Street, and then on Republic Street, in Cincinnati. To Williamson, the sound and speed of the gunshots suggested a firearm larger than a handgun. Williamson called the Cincinnati Police Department’s Real- Time Crime Center (“Crime Center”), which sent Williamson video footage of a gunman with a bookbag firing a rifle “towards Vine Street.” Williamson testified that the gunman had an accomplice, who was carrying a handgun and wearing a “camouflage jacket.” The two fled and “ducked down behind a tan SUV that was parked” on a public street. He described that area as Cincinnati’s “most violent . . . open-air drug market.", "cited_authorities": [], "summary": "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.", "lead_source": [ "CourtListener anonymous search shotspotter.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10961592/x/", "text_sha256": "a6742652853acdee03763c601c0f0cd2c5057d125a4dbd03ccb4a5b05357f60f", "source_url": "https://www.supremecourt.ohio.gov/rod/docs/pdf/1/2026/2026-Ohio-3371.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/booker-ohio-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/booker-ohio-2026" }, { "ai_passage": "This cannot be undertaken at too broad a level of generality, id., and it certainly cannot be established by citation to nonexistent cases. Here, Plaintiffs make a borderline sanctionable attempt to identify “clearly established” law from five cases. ECF No. 18. Three of these cases—Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997), Yates v. Terry, 817 F.3d 877 (4th Cir. 2016), and Dawkins v. Fields 354 F.3d 392 (5th Cir. 2003)—are either non-existent or mistakenly out-of-circuit and, in any event, inapposite. With respect to Dawkins, this Court cannot even find a case purporting to “clearly establish” law on the matter and wastes its limited judicial resources in doing so. ... The Court cautions that use of generative artificial intelligence that results in repeated misrepresentations of law may qualify for sanctions under Fed. R. Civ. P. 11(b)–(c).", "ai_tool_named": null, "archive_url": null, "case_name": "Williams v. Dallas-Fort Worth International Airport Board", "citation": null, "cited_authorities": [ "Joseph ex rel. Estate of Joseph v. Bartlett, 981 F.3d 319 (5th Cir. 2020)", "Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997)", "Yates v. Terry, 817 F.3d 877 (4th Cir. 2016)", "Dawkins v. Fields, 354 F.3d 392 (5th Cir. 2003)", "Fed. R. Civ. P. 11(b)-(c)", "Fletcher v. Experian Info. Sols., Inc., 168 F.4th 231 (2026)" ], "court": "United States District Court for the Northern District of Texas", "court_code": "txnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/docket/73163191/20/williams-v-dallas-fort-worth-international-airport-board/", "date_filed": "2026-08-27", "decision_id": "txnd-2026-williams-v-dfw-airport-board", "disposition": "The court granted dismissal of the Section 1983 claims with prejudice and dismissed state-law claims without prejudice.", "docket_number": "4:26-cv-00433-P", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiffs cited nonexistent or misidentified cases, including Dawkins, Iko and Yates, to oppose qualified immunity.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": null, "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.txnd.417872/gov.uscourts.txnd.417872.20.0.pdf", "state": "TX", "summary": "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.", "text_sha256": "8d9efb852e55ea3c644f0a493f957a1cac8621bddf44ec9a967ee77b16e523c5", "topics": [ "fabricated-citations" ], "tracker_slug": "williams-v-dfw-airport-board", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/txnd-2026-williams-v-dfw-airport-board", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txnd-2026-williams-v-dfw-airport-board" }, { "ai_passage": "As Burton does not address either Pa.R.E. 404(B)(2) or res gestae, and as Appellants do not provide any discussion of ”Com v. Reid,” this Court’s review of Appellants’ argument to this point is substantially impaired. Further, in light of this unlocatable precedent, “this Court is left to guess whether this counterfeit authority is the product of a chatbot, or if there is a more nefarious explanation for the misinformation.” Commonwealth v. Shie, 307 A.3d 668, 2023 WL 6878610, at *7 n.7 (Pa. Super. 2023)(unpublished); see also Sanders v. United States, 176 Fed.Cl. 163, 169 (Fed. Cl. 2025)(observing \"[i]t is no secret that generative AI programs are known to 'hallucinate' nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs\" (internal citation omitted)).", "ai_tool_named": null, "archive_url": null, "case_name": "Kiser v. DeSimone Auto Group", "citation": null, "cited_authorities": [ "Pa.R.E. 404(B)(2)", "Com v. Reid, 770 A.2d 771 (Pa. Super. 2001)", "Commonwealth v. Burton, 770 A.2d 771 (Pa. Super. 1999)", "Commonwealth v. Shie, 307 A.3d 668, 2023 WL 6878610 (Pa. Super. 2023)", "Sanders v. United States, 176 Fed. Cl. 163 (Fed. Cl. 2025)" ], "court": "Superior Court of Pennsylvania", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-27", "decision_id": "pasuperct-2026-kiser-v-desimone-auto-group", "disposition": "The court affirmed the judgment and deemed one issue waived because it was underdeveloped and partly supported by unlocatable precedent.", "docket_number": "2428 EDA 2025", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Appellants’ counsel relied on unlocatable Com v. Reid authority while arguing evidentiary error, impairing appellate review.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Could not locate the official Pennsylvania appellate PDF by quick CourtListener search; read the court-authored PDF from the Charlotin mirror.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2995/Kiser_P._v._DeSimone_Auto_Group_USA_27_AUgust_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "a5d2a1a822a905e52165eb63fb512f084cd6fb91f253aa1b23a7278e9cebc948", "topics": [ "fabricated-citations" ], "tracker_slug": "kiser-v-desimone-auto-group", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pasuperct-2026-kiser-v-desimone-auto-group", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pasuperct-2026-kiser-v-desimone-auto-group" }, { "ai_passage": "In his Response, Plaintiff concedes that the Keys in the Fifth Amended Complaint that are the subject of the Motion were based on unverified AI-generated research, and although Plaintiff does not state so explicitly, the Keys were AI hallucinations. See id. at 6-7. As explained below, the Court finds Plaintiff’s counsel’s use of and repeated reliance on unverified AI-generated research to be irresponsible and in dereliction of counsel’s responsibilities as officers of the Court. ... While the Court declines to award Defendant monetary sanctions for the procedural reason noted above, the Court cannot ignore that Plaintiff’s counsel admitted to filing the Fifth Amended Complaint without first verifying whether the Keys — documents discovered through unverified AI-generated research — indeed existed and continued their reliance on the Keys for months, despite being unable to confirm their content.", "ai_tool_named": null, "archive_url": null, "case_name": "James v. Conley", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enters., LLC, No. 17-CV-81140, 2025 WL 1440351 (S.D. Fla. May 20, 2025)", "R. Regulating Fla. Bar 4-1.1" ], "court": "United States District Court for the Southern District of Florida", "court_code": "flsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/docket/68032771/261/james-v-conley/", "date_filed": "2026-08-27", "decision_id": "flsd-2026-james-v-conley", "disposition": "The magistrate judge recommended denying Rule 11 sanctions on safe-harbor grounds but referring plaintiff's counsel for disciplinary review.", "docket_number": "1:23-cv-24467-KMM", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel pleaded and relied on unverified AI-generated IACP Training Keys that could not be confirmed to exist.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": null, "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.flsd.658251/gov.uscourts.flsd.658251.261.0.pdf", "state": "FL", "summary": "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.", "text_sha256": "57d6ef2fb1eba559dda36bceb89d466474acbeed4f2c06e492667d43f0f2f441", "topics": [ "fabricated-citations" ], "tracker_slug": "james-v-conley", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/flsd-2026-james-v-conley", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flsd-2026-james-v-conley" }, { "ai_passage": "In her response to the show cause order, Ms. Pearson represents that the nonexistent case, Ricks v. Starbucks, was included in Plaintiff’s briefing inadvertently. By way of explanation, Ms. Pearson offers that at the time briefing was due, she was handling a significant family emergency and required additional help from an unnamed “colleague” and her paralegal to assist in finalizing the briefing. ... However, Ms. Pearson’s response also notes that, with respect to the other legal citations in her briefing, “[o]f these thirty-six [cases cited in the response to Matrix’s summary judgment motion], Ricks is the only case that the Court and [Matrix] believe is fake and potentially AI-generated.” ... Whether these misstatements were the result of the use of an AI legal search, or simply poor and unexacting legal judgment, is unclear. Regardless, they are highly concerning to the Court nonetheless.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907204240/https://storage.courtlistener.com/recap/gov.uscourts.cod.226664/gov.uscourts.cod.226664.134.0.pdf", "case_name": "Adams v. Matrix Providers Inc.", "citation": null, "cited_authorities": [ "Ricks v. Starbucks", "Amarsingh v. Frontier Airlines, Inc., No. 24-1391, 2026 WL 352016 (10th Cir. Feb. 9, 2026)", "Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)" ], "court": "United States District Court for the District of Colorado", "court_code": "cod", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/docket/67675545/134/adams-v-matrix-providers-inc/", "date_filed": "2026-08-27", "decision_id": "cod-2026-adams-v-matrix-providers", "disposition": "The court denied post-judgment motions, admonished counsel over questionable citations, and sanctioned counsel $1,000 for rule violations.", "docket_number": "1:23-cv-01996-CNS-KAS", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel included a nonexistent Ricks v. Starbucks citation and numerous inaccurate citations; the court said possible AI use was unclear.", "currency": "USD", "monetary_penalty": 1000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": "The $1,000 sanction in this order is tied to Rule 11(c)(1), Local Rule 83.1(e), and practice standards; the court also admonishes counsel about citation issues.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.cod.226664/gov.uscourts.cod.226664.134.0.pdf", "state": "CO", "summary": "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.", "text_sha256": "834fa7968af6d009faed54d4b5e9477044c2e4198191cb3c8c6fa4f6a8c07471", "topics": [ "fabricated-citations" ], "tracker_slug": "adams-v-matrix-providers", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/cod-2026-adams-v-matrix-providers", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cod-2026-adams-v-matrix-providers" }, { "decision_id": "unger-fl-2026", "case_name": "Unger v. Unger", "court": "Florida Fourth District Court of Appeal", "court_code": "fladistctapp", "court_level": "state-appellate", "state": "FL", "date_filed": "2026-08-26", "citation": null, "docket_number": "4D2025-2209", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "artificial intelligence", "disposition": "The court affirmed in part, reversed in part, remanded, and repeated a warning about AI use in filings.", "ai_passage": "We disagree with the former husband’s proposed remedy. Although the caselaw holds that “substantive changes in the trial court’s [oral] ruling are not ministerial and are considered void” when a disqualified judge issues an order after disqualification, Godin, 275 So. 3d at 701, we disagree that the entire 2025 written contempt order is void. Because we have the transcript from the 2025 contempt hearing, we can determine what oral determinations were made before the initial judge’s disqualification. Thus, we hold that the proper remedy in this case is to reverse the written contempt order and remand for the initial judge to (1) vacate the 2025 written contempt order, and (2) enter an amended written contempt order which removes the two findings discussed above that the initial judge did not orally announce during the 2025 contempt hearing. Except as discussed above, we reject the former husband’s other arguments raised on appeal. As we warned in our order striking the former husband’s initial brief with leave to amend, we again caution the former husband about the use of artificial intelligence in preparation of documents filed with the court. Affirmed in part, reversed in part, and remanded with instructions.", "cited_authorities": [], "summary": "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.", "lead_source": [ "CourtListener anonymous search pro-se-chatgpt.json" ], "verification": "mirror-read", "notes": "Court-authored PDF read from CourtListener storage fallback after direct Florida media retrieval did not persist in retry metadata.", "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10958310/x/", "text_sha256": "4115e66783f0f029c48683f1f80d4926eac1248cd632fa44ed35515f993cd745", "source_url": "https://flcourts-media.flcourts.gov/content/download/2494385/opinion/Opinion_2025-2209.pdf", "archive_url": "https://web.archive.org/web/20260907215457/https://flcourts-media.flcourts.gov/content/download/2494385/opinion/Opinion_2025-2209.pdf", "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/opinions/unger-fl-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/unger-fl-2026" }, { "ai_passage": "The court then questioned Turgeon regarding her Objection to the Trustee’s motion to dismiss. Specifically, the court asked Turgeon about her use of “false, hallucinated case citations” within her brief. The bankruptcy court explained to Turgeon that the citations she referenced and relied upon in her objection were inaccurate and misleading. Accordingly, her objection to the motion to dismiss would be stricken. Turgeon protested that she had been trying to act in “good faith.” The court responded: “it’s not going well for you because items are not getting noticed, []proper forms are not getting used, and you’re misleading the Court. So I really strongly urge you to get an attorney in this case and to go that route. If you continue to proceed pro se, we’ll continue to monitor the case accordingly.”", "ai_tool_named": null, "archive_url": null, "case_name": "Turgeon v. Federal Home Loan Mortgage Corporation", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of New Hampshire", "court_code": "nhd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/docket/72009448/18/turgeon-v-federal-home-loan-mortgage-corporation/", "date_filed": "2026-08-26", "decision_id": "nhd-2026-turgeon-v-fhlmc", "disposition": "The district court affirmed dismissal of Turgeon's Chapter 13 petition and upheld striking her objection.", "docket_number": "1:25-cv-00510-SM-TSM", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented debtor filed an objection containing false, hallucinated case citations that the bankruptcy court found inaccurate and misleading.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": "District court order quotes and reviews the bankruptcy court's handling of the hallucinated citations.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.nhd.66674/gov.uscourts.nhd.66674.18.0.pdf", "state": "NH", "summary": "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.", "text_sha256": "206ffd976c752adfbbea092c1a06c333bc8305d2992be78fbebb2957e3146012", "topics": [ "fabricated-citations" ], "tracker_slug": "turgeon-v-fhlmc", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/nhd-2026-turgeon-v-fhlmc", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nhd-2026-turgeon-v-fhlmc" }, { "ai_passage": "The Potterfs are not entitled to relief on any of their objections because they failed to take reasonable steps to ensure that the legal citations in the objections were accurate. As the Potterfs acknowledged during the virtual hearing on August 20, 2026, they used artificial intelligence to prepare their objections. Perhaps for that reason, their objections attribute false quotations or non-existent legal principles to their cited cases. For example: • The Potterfs quoted the Supreme Court as saying in United States v. Sineneng-Smith, 140 S. Ct. 1575, 1579 (2020), that federal courts “do not as a rule initiate torts or explore legal pathways on their own, but rather sit as arbiters of legal issues presented and argued by the parties.” ... That quotation does not appear in the Sineneng-Smith case in any form. • The Potterfs argued that “the Sixth Circuit clarified in United States v. Abdi, 827 F.3d 533, 538 (6th Cir. 2016) ...” That case does not appear to exist.", "ai_tool_named": null, "archive_url": null, "case_name": "Potterf v. Wessels", "citation": null, "cited_authorities": [ "United States v. Sineneng-Smith, 140 S. Ct. 1575 (2020)", "United States v. Abdi, 827 F.3d 533 (6th Cir. 2016)", "Van Houten v. City of Fort Worth, 827 F.3d 533 (5th Cir.)", "Hill v. Synder, 814 F.3d 408 (6th Cir. 2016)", "Ability Center of Greater Toledo v. City of Sandusky, 385 F.3d 901 (6th Cir. 2004)", "Tindall v. Wayne County Friend of the Court, 269 F.3d 533 (6th Cir. 2001)" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-26", "decision_id": "mied-2026-potterf-v-wessels", "disposition": "The court overruled objections, adopted the report and recommendation, denied plaintiffs' motions, and warned about future sanctions.", "docket_number": "1:26-cv-10860-MFL-PTM", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": "artificial intelligence", "conduct": "Self-represented plaintiffs used AI to prepare objections with false quotations, nonexistent United States v. Abdi and Hill v. Synder citations, and mischaracterized cases.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "CourtListener found the docket but not this document in the first displayed RECAP results; read the court-authored PDF from the Charlotin mirror.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2952/Potterf_v._Wessels_USA_26_August_2026.pdf", "state": "MI", "summary": "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.", "text_sha256": "0599e9ae4b6c041251373b29b4af3b2a8b92950f0f9166a7c22bb849734f5aea", "topics": [ "fabricated-citations" ], "tracker_slug": "potterf-v-wessels", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-potterf-v-wessels", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-potterf-v-wessels" }, { "ai_passage": "Notwithstanding the foregoing admonition, it appears Plaintiff has once again cited a “hallucinated” case derived perhaps from use of a generative artificial intelligence (“AI”) tool (e.g., ChatGPT, Gemini, etc.). Specifically, Plaintiff cites to “Cooke v. Carrington Mortg. Servs., No. 22-1425 (4th Cir. 2023),” see ECF No. 57 at p. 3. Plaintiff contends this case stands for the proposition that “servicer-imposed charges tied to improper insurance placement constitute a concrete injury.” ... Based on the court’s review, this case does not exist. The court has checked the Fourth Circuit case number—22-1425, and Westlaw citation—2023 WL 3010355—offered by Plaintiff to identify this case; neither directs the court to the referenced opinion. ... While this court has already cautioned Plaintiff that continued citation to hallucinated authorities or the like risks issuance of an order to show cause why he should not face sanctions under Rule 11, the court declines to take further action in the instant matter where Plaintiff’s case will be dismissed in full.", "ai_tool_named": null, "archive_url": null, "case_name": "Johnson v. Nationstar Mortgage LLC", "citation": null, "cited_authorities": [ "Cooke v. Carrington Mortg. Servs., No. 22-1425 (4th Cir. 2023)", "Mezu v. Mezu, 267 Md. App. 354 (2025)", "Noland v. Land of the Free, L.P., 336 Cal. Rptr. 3d 897 (Cal. App. 2025)", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the District of Maryland", "court_code": "mdd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-26", "decision_id": "mdd-2026-johnson-v-nationstar", "disposition": "The court granted defendants' motions to dismiss and declined further action over the latest hallucinated citation.", "docket_number": "1:25-cv-00855-JRR", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff cited nonexistent Cooke v. Carrington Mortgage Services Fourth Circuit and Westlaw authorities after a prior Rule 11 warning.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "CourtListener search found the docket but did not surface this PDF in the displayed RECAP result; read the court-authored PDF from the Charlotin mirror.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2949/Johnson_v._Nationstar_Mortgage_LLC_USA_26_August_2026.pdf", "state": "MD", "summary": "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.", "text_sha256": "c2bc86219428dce58bd3ee99f2f467088f0e26284a232b2c507939335949f2a6", "topics": [ "fabricated-citations" ], "tracker_slug": "johnson-v-nationstar", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdd-2026-johnson-v-nationstar", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdd-2026-johnson-v-nationstar" }, { "ai_passage": "The presumable conclusion was that Tyler had AI review Baxter’s Answer and had it generate his Motion to Strike. While there is not yet a proscription prohibiting this conduct, there is a proscription of filing a brief with citations to cases that do not stand for the asserted proposition. Perez-Castillo v. Blanche, 177 F.4th 837, 848 (7th Cir. 2026). Indeed, “[u]nder this circuit’s standards for professional conduct, lawyers promise that they will not knowingly misrepresent, mischaracterize, misquote, or miscite facts or authorities in any oral or written communication to the court.” ... The Seventh Circuit opinion in Instituto supports neither of these propositions. See Instituto, 858 F.2d at 1265-72. Indeed, the words “affirmative defense” are not even in the opinion. The Court admonishes Tyler for repeatedly citing to a Seventh Circuit decision for a false proposition. AI generated content routinely contains errors—including those that may be difficult to readily ascertain.", "ai_tool_named": null, "archive_url": null, "case_name": "Shelbert v. Baxter International, Inc.", "citation": null, "cited_authorities": [ "Perez-Castillo v. Blanche, 177 F.4th 837 (7th Cir. 2026)", "Instituto Nacional de Comercializacion Agricola (Indeca) v. Continental Illinois National Bank & Trust Co., 858 F.2d 1264 (7th Cir. 1988)", "Instituto Nacional De Comercializacion Agricola (Indeca) v. Cont’l Illinois Nat. Bank & Tr. Co., 576 F. Supp. 985 (N.D. Ill. 1983)" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-26", "decision_id": "ilnd-2026-shelbert-v-baxter-international", "disposition": "The court granted in part and denied in part a motion to strike affirmative defenses and admonished plaintiff's counsel.", "docket_number": "1:26-cv-06266", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel repeatedly cited Instituto for affirmative-defense propositions not found in the Seventh Circuit opinion; the court suspected AI-assisted drafting.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "CourtListener search found the docket but not this memorandum opinion PDF in available RECAP documents; read the court-authored PDF from the Charlotin mirror.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2951/Shelbert_v._Baxter_International_USA_26_August_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "efa875b46f8cbf38ba11f72a0a7940462964769019e821a14e04ab675abcdcc4", "topics": [ "fabricated-citations" ], "tracker_slug": "shelbert-v-baxter-international", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-shelbert-v-baxter-international", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-shelbert-v-baxter-international" }, { "ai_passage": "One such authority is Napp v. Napp, which Easten cites for the proposition that an award must be supported by a record sufficient to permit meaningful review. But that case does not exist—at least not at the citation provided by Easten. We suspect he intended to cite Breitbart-Napp v. Napp, 216 Ariz. 74 (App. 2007). In that case we vacated the trial court’s fee award because of the stale nature of the financial information upon which it was based and the court’s apparent decision to make the award based upon which party prevailed on the merits, an improper basis under § 25-324. Breitbart-Napp, 216 Ariz. 74, ¶ 39. Neither of those considerations apply here. Appels-Meehan v. Appels, 167 Ariz. 182 (App. 1991), upon which Easten also relies, did not involve a review of a trial court’s award of attorney fees.", "ai_tool_named": null, "archive_url": null, "case_name": "Fairrow v. Easten", "citation": null, "cited_authorities": [ "Napp v. Napp", "Breitbart-Napp v. Napp, 216 Ariz. 74 (App. 2007)", "A.R.S. § 25-324", "Appels-Meehan v. Appels, 167 Ariz. 182 (App. 1991)" ], "court": "Arizona Court of Appeals, Division Two", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-26", "decision_id": "azctapp-2026-fairrow-v-easten", "disposition": "The court affirmed the fee award and declined to award appellate fees as a sanction.", "docket_number": null, "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant cited Napp v. Napp for fee-award review, but the court found no such case at the provided citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "CourtListener opinion search did not locate this Arizona memorandum decision; read the court-authored PDF from the Charlotin mirror. The decision does not itself name an AI tool.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2998/ALIYAH_FAIRROW_v._BRENTLY_EASTEN_USA_26_August_2026.pdf", "state": "AZ", "summary": "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.", "text_sha256": "abd52f90a03c2882226ab4fc1d6fdcc4b2d37cbbceea74c89c474382049de960", "topics": [ "fabricated-citations" ], "tracker_slug": "fairrow-v-easten", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azctapp-2026-fairrow-v-easten", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azctapp-2026-fairrow-v-easten" }, { "ai_passage": "Objection also shows signs of drafting by artificial intelligence. Federal courts often strike briefs that do not comply with local rules, which the Tenth Circuit has upheld. Instead, this order confine review to Mr. Ferm’s one meritorious objection. ... The remainder of Mr. Ferm’s Objection is “too long, too verbose, too vague, and too repetitive” to be considered specific enough for de novo review. The last 37 pages of Mr. Ferm’s objection devolves into a series of bullets points that are a clear example of “A.I. Slop.” Mr. Ferm “is cautioned against the possible use of artificial intelligence to draft memorandums.” Christoffersen v. Nucor Corp., No. 4:25-CV-00118-DN-PK, 2026 WL 1623190, at *2 n.15 (D. Utah June 5, 2026).", "ai_tool_named": null, "archive_url": null, "case_name": "Ferm v. Agritech Properties", "citation": null, "cited_authorities": [ "Christoffersen v. Nucor Corp., No. 4:25-CV-00118-DN-PK, 2026 WL 1623190 (D. Utah June 5, 2026)", "Carey v. Breakell, No. 4:25-CV-00108-AMA-PK, 2026 WL 2199063 (D. Utah July 30, 2026)", "Hack v. Preston, No. 4:25-CV-00096-DN, 2026 WL 2279536 (D. Utah Aug. 7, 2026)" ], "court": "United States District Court for the District of Utah", "court_code": "utd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-25", "decision_id": "utd-2026-ferm-v-agritech-properties", "disposition": "The court adopted the report and recommendation, dismissed for lack of personal jurisdiction, and denied remaining motions as moot.", "docket_number": "4:26-cv-00029-DN-PK", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": null, "lead_source": [ "charlotin-cc0" ], "notes": "Included as pro-se AI use rather than fabricated-citations because this order describes AI slop and possible AI drafting, not a specific fabricated authority. The lead date is 2026-08-24; the PDF was filed 2026-08-25.", "primary_topic": "pro-se-ai-use", "source_url": "https://www.damiencharlotin.com/documents/2956/Ferm_v._Agritech_USA_25_August_2026.pdf", "state": "UT", "summary": "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.", "text_sha256": "7e56e65016a68775039c363082c1301db780a77d1f33bcad24ac5f72fee53138", "topics": [ "pro-se-ai-use" ], "tracker_slug": null, "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/utd-2026-ferm-v-agritech-properties", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/utd-2026-ferm-v-agritech-properties" }, { "ai_passage": "Plaintiff’s first motion to disqualify contains several inaccurate or non-existent case citations and quotations. See [Dkt. 15.] “‘[I]t is improper and unacceptable for litigants—including pro se litigants—to submit ‘non-existent judicial opinions with fake quotes and citations.’” Fagan v. Barnhiser, Civ. No. 24-06012 (CCC), 2025 WL 2654994, at *2 (D.N.J. Sept. 17, 2025) (quoting Anonymous v. New York City Dep’t of Educ., Civ. No. 24-4232, 2024 WL 3460049, at *7 (S.D.N.Y. July 18, 2024) (further citations omitted)). “While some Courts have opted to sanction pro se litigants for this conduct, others have chosen to warn, rather than sanction, in these situations.” Id. (citation omitted). At this time, the Court will not impose sanctions. But plaintiff is now on notice: The Court “admonishes [p]laintiff for his improper conduct and warns that he will be subject to sanctions, including monetary penalties, should he [engage in similar conduct] again in the future.” Id.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907204302/https://websitedc.s3.amazonaws.com/documents/KURELKO_v._BALLARD_JR._USA_25_August_2026.pdf", "case_name": "Kurelko v. Ballard", "citation": null, "cited_authorities": [ "Fagan v. Barnhiser, Civ. No. 24-06012 (CCC), 2025 WL 2654994 (D.N.J. Sept. 17, 2025)", "Anonymous v. New York City Dep’t of Educ., Civ. No. 24-4232, 2024 WL 3460049 (S.D.N.Y. July 18, 2024)" ], "court": "United States District Court for the District of New Jersey", "court_code": "njd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-25", "decision_id": "njd-2026-kurelko-v-ballard", "disposition": "The court denied Kurelko's motions to disqualify the New Jersey Office of the Attorney General.", "docket_number": "3:25-cv-11917-ZNQ-JBD", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff filed a disqualification motion with inaccurate or nonexistent case citations and quotations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "CourtListener returned a 429 during this lead's search; after waiting, used the Charlotin mirror. The order does not name an AI tool.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2944/KURELKO_v._BALLARD_JR._USA_25_August_2026.pdf", "state": "NJ", "summary": "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.", "text_sha256": "9fb7fda497717436e439f18e38db5be4da8b14772de1c749116e5c776e5cfd73", "topics": [ "fabricated-citations" ], "tracker_slug": "kurelko-v-ballard", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/njd-2026-kurelko-v-ballard", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/njd-2026-kurelko-v-ballard" }, { "ai_passage": "On November 21, 2025, AndDone filed a motion requesting an order that Gaines show cause why she should not be sanctioned for violations of Federal Rule of Civil Procedure 11 for misrepresentations to the Initial Court including citations to nonexistent cases and quotations contained in a November 18 filing, (Doc. 53). (Doc. 57.) ... The Initial Court also ordered Gaines to show cause why she should not be sanctioned for the Rule 11 violations identified in AndDone’s motion for order to show cause by December 12, 2025. (Doc. 59.) Gaines did not provide further written discovery responses as ordered, she did not appear for her deposition, and she did not respond to the Initial Court’s show cause order.", "ai_tool_named": null, "archive_url": null, "case_name": "AndDone, LLC v. Gaines", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Fed. R. Civ. P. 37" ], "court": "United States District Court for the Western District of Missouri", "court_code": "mowd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/docket/70418866/84/anddone-llc-v-gaines/", "date_filed": "2026-08-25", "decision_id": "mowd-2026-anddone-v-gaines", "disposition": "The court granted Rule 37 fees and default judgment against Gaines, and denied alternative default-judgment motions as moot.", "docket_number": "4:25-cv-00346-RK", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented defendant filed a November 2025 submission with misrepresentations, citations to nonexistent cases, and quotations, then did not answer a Rule 11 show-cause order.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": "This order recounts a prior show-cause order rather than deciding Rule 11 sanctions.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.mowd.183519/gov.uscourts.mowd.183519.84.0.pdf", "state": "MO", "summary": "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.", "text_sha256": "4fb5a625728427da9b8a0332b00b1738890794dfa8c7d3001433e6dde719f276", "topics": [ "fabricated-citations" ], "tracker_slug": "anddone-llc-v-gaines", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/mowd-2026-anddone-v-gaines", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mowd-2026-anddone-v-gaines" }, { "decision_id": "anderegg-ca7-2026", "case_name": "United States v. Anderegg", "court": "U.S. Court of Appeals for the Seventh Circuit", "court_code": "ca7", "court_level": "federal-appellate", "state": null, "date_filed": "2026-08-25", "citation": null, "docket_number": "25-1354", "document_type": "opinion", "topics": [ "substantive-ai-law", "criminal-justice-algorithms" ], "primary_topic": "substantive-ai-law", "court_used_ai": false, "ai_tool_named": "Stable Diffusion", "disposition": "The court reversed dismissal of production and possession counts involving AI-generated CSAM and remanded.", "ai_passage": "Steven Anderegg is charged with pro- ducing, distributing, and possessing visual depictions of mi- nors engaged in sexually explicit conduct and transferring such material to a minor under the age of sixteen. According to the government, Anderegg produced these images using Stable Diffusion, a generative artificial intelligence (“GenAI”) software that allowed him to create hyper-realistic images of prepubescent children engaging in sexually explicit acts. ... When Anderegg moved to dismiss the indictment, the dis- trict court granted the motion as to the possession charge and denied the remainder.", "cited_authorities": [ "18 U.S.C. § 2258A" ], "summary": "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.", "lead_source": [ "user brief", "CourtListener anonymous search" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10957699/x/", "text_sha256": "1fc4da6f11f7296580987a892eee51193fd5310cf09c16615e126d895a46a2f7", "source_url": "https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2026/D08-25/C:25-1354:J:Lee:autconi:T:fnOp:N:3597567:S:0", "archive_url": "https://web.archive.org/web/20260826150534/https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2026/D08-25/C:25-1354:J:Lee:autconi:T:fnOp:N:3597567:S:0", "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/anderegg-ca7-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/anderegg-ca7-2026" }, { "ai_passage": "The first issue to be addressed is whether Ms. Tate’s conduct violated any procedural or ethical rules. It did. Ms. Tate acknowledges that she filed three different briefs in this action that contained fake AI-generated quotations and filed a fourth brief that contained an inaccurate AI-generated case summary. ... In the course of preparing this Motion, Ms. Tate utilized ChatGPT to prepare the draft brief. ChatGPT cited the Ansell v. Green Acres Contracting Co., 347 F.3d 515 (3d Cir. 2003) case to support the proposition that evidence of favorable treatment of the plaintiff or others does not preclude discrimination and may be excluded as irrelevant or misleading. ... Ms. Tate also utilized ChatGPT to assist with the Brief on Impeachment. ... While Ms. Tate confirmed the cases stood for the proposition for which she understood them to when she first prompted ChatGPT to include them in the draft brief, Ms. Tate mistakenly did not correct the misquotations from the Antonakeas or Osazuwa cases.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Ruiz v. Magellan Financial & Insurance Services", "citation": null, "cited_authorities": [ "Ansell v. Green Acres Contracting Co., 347 F.3d 515 (3d Cir. 2003)", "United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001)", "United States v. Osazuwa, 564 F.3d 1169 (9th Cir. 2009)", "Fed. R. Civ. P. 11(b)(2)" ], "court": "United States District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/docket/67863214/179/ruiz-v-magellan-financial-insurance-services/", "date_filed": "2026-08-24", "decision_id": "azd-2026-ruiz-v-magellan-financial", "disposition": "The court issued a formal public reprimand to plaintiff's counsel and required her to report the discipline where required.", "docket_number": "2:23-cv-02090-DWL", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Counsel filed three briefs with fake AI-generated quotations and a fourth with an inaccurate AI-generated summary after using ChatGPT.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0", "courtlistener-search" ], "notes": null, "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.azd.1348340/gov.uscourts.azd.1348340.179.0.pdf", "state": "AZ", "summary": "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.", "text_sha256": "c65f2c3bfbca35bfec9dc6c276031409068ab7a26914fcf194a39e5dbbf584ab", "topics": [ "fabricated-citations" ], "tracker_slug": "ruiz-v-magellan-financial", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/azd-2026-ruiz-v-magellan-financial", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-ruiz-v-magellan-financial" }, { "decision_id": "aguilera-ca9-2026", "case_name": "United States v. Aguilera", "court": "U.S. Court of Appeals for the Ninth Circuit", "court_code": "ca9", "court_level": "federal-appellate", "state": null, "date_filed": "2026-08-24", "citation": null, "docket_number": "25-3366", "document_type": "opinion", "topics": [ "criminal-justice-algorithms" ], "primary_topic": "criminal-justice-algorithms", "court_used_ai": false, "ai_tool_named": "ShotSpotter", "disposition": "The court affirmed Aguilera’s conviction, vacated his sentence, and remanded for resentencing.", "ai_passage": "ShotSpotter is a service that detects gunshots and alerts local police to the precise coordinates where the gunshots were detected. USA V. AGUILERA 5 of 22nd and Capp Streets. Several officers arrived near the El Trebol bar around 2:00 a.m., within minutes of receiving the reports of gunshots at that location. A witness, later identified as Briseno, said he saw the shooter—a Hispanic male wearing a blue jacket—fire into the air and head westbound down 22nd Street. A second person outside El Trebol pointed officers in the same direction and said, “they went that way.” Officers Hurtado and Frisk saw a person walking away in that direction", "cited_authorities": [], "summary": "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.", "lead_source": [ "CourtListener anonymous search shotspotter.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10956638/x/", "text_sha256": "45834207d856daffbcf17224601b1d51834bd18513193c52fa0e6e691e5c10a4", "source_url": "https://cdn.ca9.uscourts.gov/datastore/opinions/2026/08/24/25-3366.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/aguilera-ca9-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/aguilera-ca9-2026" }, { "ai_passage": "Plaintiff quotes Adorh Farms, Co. v. Love (1967) 255 Cal.App.2d 366 at p. 371: “The filing of an answer … effected a waiver of the right to demur.” (Opp., at p. 8: 19–21.) This is at best an incomplete statement of law. “A party objecting to a complaint or cross-complaint may demur and answer at the same time.” (Code Civ. Proc., § 430.30, subd. (c); see § 472a, subd. (a) [“A demurrer is not waived by an answer filed at the same time.”].) More importantly, although the Adorh Farms opinion exists,[3] it does not contain the quoted language. Nor can the court find the quoted language in any other case reported in California or elsewhere. This quotation may be the result of irresponsible use of generative artificial intelligence (“AI”). ... The Court declines to begin the process of imposing sanctions at this time but strongly cautions Plaintiff to take better care in making only good-faith, well-researched, legally sound arguments in future. All citations and quotations submitted to the Court must be verified. Future submissions of fabricated authority may result in sanctions.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907205622/https://websitedc.s3.amazonaws.com/documents/Perez_v._Schaal_USA_21_August_2026.pdf", "case_name": "Perez v. Schaal", "citation": null, "cited_authorities": [ "Adorh Farms, Co. v. Love, 255 Cal.App.2d 366 (1967)", "Code Civ. Proc. § 430.30", "Code Civ. Proc. § 472a", "Noland v. Land of the Free, L.P., 114 Cal.App.5th 426 (2025)", "Hopkins & Carley v. Gens, 200 Cal.App.4th 1401 (2011)" ], "court": "Superior Court of California, County of Sacramento", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-21", "decision_id": "calsuperct-2026-perez-v-schaal", "disposition": "The court ruled on the demurrer and warned the self-represented plaintiff to verify all citations and quotations.", "docket_number": "25CV019484", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff attributed a quotation about waiver of demurrer to Adorh Farms, but the court could not find it in that or any reported case.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/3004/Perez_v._Schaal_USA_21_August_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "2da85cb60cab4db3fe5ff8328cf32bc9d84485775b01d1651f3eb11640e10d1c", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "perez-v-schaal", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calsuperct-2026-perez-v-schaal", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calsuperct-2026-perez-v-schaal" }, { "ai_passage": "Defendant argues Plaintiff has violated Federal Rule of Procedure 11 by misusing generative artificial intelligence (“generative AI”). See Def. Sanctions Opp. at 6-7 (ECF No. 21). Specifically, Defendant argues Plaintiff’s writing contains generative AI hallmarks and that for each case Plaintiff cites with a parenthetical, the quoted language is absent from the cited opinion. ... Defendant is correct that in Plaintiff’s motion for sanctions, Plaintiff attributes quotations to two different cases, but the language Plaintiff quoted does not actually appear in either case. See Def. Sanctions Opp. at 6-7; Pl. Sanctions Mot. at 1. The Court has concerns that Plaintiff’s submissions to the Court have misquotations of cases, which suggest an irresponsible use of generative AI. “Such misquotations, miscitations, and misrepresentations often indicate the presence of artificial intelligence-generated hallucinations.” Doe 1 v. Lai, 2026 WL 1004947, at *1 (C.D. Cal. Feb. 17, 2026). ... Though the Court is concerned by Plaintiff’s misquotations in his sanctions motion that indicate the irresponsible use of generative AI, given Plaintiff’s pro se status, the Court declines at this time Defendant’s invitation to impose sanctions.", "ai_tool_named": null, "archive_url": null, "case_name": "Lohbeck v. Amazon.com Services, LLC", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Doe 1 v. Lai, 2026 WL 1004947 (C.D. Cal. Feb. 17, 2026)", "Lohbeck v. CSL Plasma, Inc., No. 2:26-cv-01493-DJC-CSK" ], "court": "United States District Court for the Eastern District of California", "court_code": "caed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-21", "decision_id": "caed-2026-lohbeck-v-amazon", "disposition": "The magistrate judge recommended dismissal and warned the self-represented plaintiff about misquotations suggesting AI use.", "docket_number": "2:26-cv-02007-DC-CSK", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff’s sanctions motion attributed quotations to two cases, but the quoted language did not appear in either opinion.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2937/Lohbeck_v._Amazon_USA_21_August_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "14902aaa12616361b7133377cf905bce9578bb2db40f3d8e3d31e8700d2dcdeb", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "lohbeck-v-amazon-com-services-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/caed-2026-lohbeck-v-amazon", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/caed-2026-lohbeck-v-amazon" }, { "ai_passage": "After Plaintiff’s counsel disclosed to the Court that the previously filed Joint Claim Construction Brief (“Joint Brief”) (D.I. 105) featured multiple errors due to his use of generative artificial intelligence (“AI”), the Court ordered counsel to show cause in writing as to why the Court should not impose sanctions for counsel’s conduct pursuant to Federal Rule of Civil Procedure 11(b),(c). ... Counsel stated that he used the AI system “Strongsuit” to generate an initial outline of Plaintiff’s reply brief and to pull statements from a deposition that supported Plaintiff’s position on claim construction. ... Plaintiff sought to strike the problematic section of its reply brief, causing Defendants to also strike their subsequent briefing that responded to the inaccurate AI-generated arguments put forth by Plaintiff. ... The Court expects that these events and this Opinion shall serve as a cautionary warning and learning experience for counsel moving forward. The Court warns counsel that any future incidents involving AI mistakes in this case may result in sanctions. Upon consideration of the circumstances as described by counsel, and his appreciation for the gravity of filing erroneous legal arguments drafted by generative AI without proper review, the Court declines to sanction counsel for his conduct.", "ai_tool_named": "Strongsuit", "archive_url": "https://web.archive.org/web/20260907205631/https://websitedc.s3.amazonaws.com/documents/Disruptive_Resources_LLC_v._Ballistic_Barrier_Products_USA_20_August_2026.pdf", "case_name": "Disruptive Resources, LLC v. Ballistic Barrier Products Inc.", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "McCarthy v. United States Drug Enforcement Administration, 171 F.4th 245 (3d Cir. 2026)", "Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)" ], "court": "United States District Court for the District of Delaware", "court_code": "ded", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-20", "decision_id": "ded-2026-disruptive-resources-v-ballistic-barrier", "disposition": "The court declined Rule 11 sanctions but warned counsel that future AI mistakes in the case may result in sanctions.", "docket_number": "1:24-cv-00321-JCG", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": null, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "competence-fees", "source_url": "https://www.damiencharlotin.com/documents/2925/Disruptive_Resources_LLC_v._Ballistic_Barrier_Products_USA_20_August_2026.pdf", "state": "DE", "summary": "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.", "text_sha256": "cd04918cf72a72d1424adc4fda9e708d1ff69e0c9e30039fbcfa2c5822c88cf2", "topics": [ "competence-fees" ], "tracker_slug": "disruptive-resources-v-ballistic-barrier", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ded-2026-disruptive-resources-v-ballistic-barrier", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ded-2026-disruptive-resources-v-ballistic-barrier" }, { "ai_passage": "The Court also ordered Plaintiff’s counsel to show cause why he should not be sanctioned in an amount sufficient to reimburse Defendant for expenses it incurred in addressing nonexistent cases cited by Plaintiff in opposition to the first attorneys’ fees motion. See Order to Show Cause, ECF 30. The parties have resolved that issue informally, and Plaintiff’s counsel has reimbursed Defendant for attorneys’ fees in the amount of $14,500. Accordingly, the Court will discharge the order to show cause.", "ai_tool_named": null, "archive_url": null, "case_name": "Full Standard Properties, LLC v. SJ 6070, LLC", "citation": null, "cited_authorities": [ "Order to Show Cause, ECF 30" ], "court": "United States District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-20", "decision_id": "cand-2026-full-standard-properties-v-sj-6070", "disposition": "The court discharged an order to show cause after plaintiff's counsel reimbursed $14,500 in fees tied to nonexistent cases.", "docket_number": "25-cv-09451-BLF", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel cited nonexistent cases in opposition to the first attorneys’ fees motion, causing defendant to incur response expenses.", "currency": "USD", "monetary_penalty": 14500, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2941/Full_Standard_Properties_USA_20_August_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "2ef1b3bde965743df62758bd0f5f9b0b396c9df4978d62d4d21c70b6561b2dc4", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "full-standard-properties-v-sj-6070", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cand-2026-full-standard-properties-v-sj-6070", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-full-standard-properties-v-sj-6070" }, { "ai_passage": "Lastly, the Court underscores its Standing Order to remind Plaintiff that the inclusion of non-existent quotations in Plaintiff's briefing submitted to this Court is unacceptable. (See Opp'n at 3-4; Order Re Amended Civil Case Standing Order, Dkt. No. 65 at 18-20 (“caution[ing] that unqualified reliance on AI-generated content can result in filings that rely on misrepresentations and hallucinated, nonexistent caselaw”)). While the Court understands that Plaintiff is proceeding pro se, the Court does not condone the submission of misstated case law from any litigant and is concerned by Plaintiff's doubling-down in her Reply where she claims that Kaiser pointed out her incorrect quotations in bad faith to improperly attack her, rather than correcting her citations. ... Quoting paraphrased language generated from artificial intelligence tools, published on websites explaining case law (e.g., law.cornell.edu), or from personal manipulation without appropriate signals (e.g., without bracketing, ellipses, etc.) as if those quotations came directly from the cases themselves is squarely prohibited. If Plaintiff were a lawyer, the Court would be imposing significant sanctions for this conduct.", "ai_tool_named": null, "archive_url": null, "case_name": "Kasengela v. Kaiser Foundation Hospitals", "citation": "2026 WL 2447454", "cited_authorities": [ "Order Re Amended Civil Case Standing Order, Dkt. No. 65", "Chapman v. Horace Mann Property & Casualty Insurance Co., 2025 WL 3724904 (C.D. Cal. Aug. 14, 2025)" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-20", "decision_id": "cacd-2026-kasengela-v-kaiser-foundation", "disposition": "The court remanded the action and admonished the self-represented plaintiff over non-existent quotations in briefing.", "docket_number": "2:26-cv-01666-WLH-CTS", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff submitted non-existent quotations and misstated case law, then accused Kaiser of bad faith instead of correcting the citations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw slip-copy formatting.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2923/CECILE_KASENGELA_v_KAISER_FOUNDATION_HOSPITALS_et_al_USA_20_August_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "5bfa5f1b3f49058e381742f01536e776d944842a7259a4e85401c8fc9c680f2f", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "kasengela-v-kaiser-foundation-hospitals", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-kasengela-v-kaiser-foundation", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-kasengela-v-kaiser-foundation" }, { "ai_passage": "At three different points in his Application, Plaintiff attributes quoted language to Mission Power, 883 F. Supp. at 492, which appears nowhere in the body of the cited case. See Appl. at 7:10–7:15, 10:5–10:8, 10:17–10:22. The discrepancies between the quoted language and the language of the cited case are so significant as to abrogate any assumption that the misattributions are the result of typographical error. Plaintiff’s repeated inclusion of quotations misattributed to Mission Power, which are present in the language of an entirely different case, 1 “bear the hallmarks of hallucinated cases created by artificial intelligence (‘AI’) tools.” Cummins v. Becerra, No. 1:25-CV-01853-DC-AC, 2026 WL 373336, at *1 (E.D. Cal. Feb. 10, 2026) ... Accordingly, the Court SETS an ORDER TO SHOW CAUSE Re: Monetary Sanctions and State Bar Referral of Todd M. Friedman for breach of the duty of candor to the Court.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907205637/https://websitedc.s3.amazonaws.com/documents/Dotson_v._Evans_USa_20_August_2026.pdf", "case_name": "Dotson v. Bob Evans Farms, LLC", "citation": null, "cited_authorities": [ "Mission Power Engineering Co. v. Continental Casualty Co., 883 F. Supp. 488 (C.D. Cal. 1995)", "Horne v. Wells Fargo Bank, N.A., 969 F. Supp. 2d 1203 (C.D. Cal. 2013)", "Cummins v. Becerra, 2026 WL 373336 (E.D. Cal. Feb. 10, 2026)", "Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-20", "decision_id": "cacd-2026-dotson-v-bob-evans-farms", "disposition": "The court denied reconsideration and ordered plaintiff's counsel to show cause about monetary sanctions and a state bar referral.", "docket_number": "2:25-cv-11993-MWC-DSR", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel repeatedly attributed quoted language to Mission Power that the court found in a different case, Horne v. Wells Fargo.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2939/Dotson_v._Evans_USa_20_August_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "64e72447510a303d3b5bee6f1b6468005d57689a6306736cced012b53e48c94b", "topics": [ "fabricated-citations" ], "tracker_slug": "dotson-v-bob-evans-farms-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-dotson-v-bob-evans-farms", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-dotson-v-bob-evans-farms" }, { "decision_id": "wilkinson-iowa-2026", "case_name": "Wilkinson v. Schmelzer", "court": "Iowa Court of Appeals", "court_code": "iowactapp", "court_level": "state-appellate", "state": "IA", "date_filed": "2026-08-19", "citation": null, "docket_number": "25-0799", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "generative AI", "disposition": "The court affirmed, declined AI-use sanctions, and awarded appellate attorney fees on ordinary prevailing-party grounds.", "ai_passage": "In her resistance to Brett’s motion for remand and request for sanctions, Lacey asked our supreme court to impose sanctions on Brett for purported use of generative AI in his briefs. The use of generative AI presents an interesting challenge for modern courts. While Brett is correct that “mere use of [AI] drafting assistance . . . does not constitute sanctionable conduct,” we have stated that “self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.” Luke v. Dep’t of Health & Hum. Servs., No. 24-1421, 2025 WL 2237311, at *1 (Iowa Ct. App. Aug. 6, 2025). The twist is that, absent the presence of a hallucinated case, it is difficult to differentiate poor human drafting from unverified generative AI. Here, we can find no hallucinated case. And it is impossible for us to say with certainty whether Brett’s single reference to the nonexistent “Iowa R. App. P. 6.1004(3)” was a simple typo or the result of unchecked AI use. Thus, we decline to apply sanctions for Brett’s purported use of AI.", "cited_authorities": [ "Luke v. Dep’t of Health & Human Services, 2025 WL 2237311 (Iowa Ct. App. Aug. 6, 2025)" ], "summary": "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.", "lead_source": [ "CourtListener anonymous search pro-se-chatgpt.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10953670/x/", "text_sha256": "509abb1c3ce58c24e92b8d23d1c29ff6a1de4da26dee85a0ddc9288a14c0c364", "source_url": "https://www.iowacourts.gov/courtcases/26716/embed/CourtAppealsOpinion", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/wilkinson-iowa-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wilkinson-iowa-2026" }, { "ai_passage": "Specifically, Appellant cites to “General Fin. Co. v. Archetto, 167 A.2d 306 (Pa. Super. 1961)” and “Lowrey v. Eastaff, 860 A.2d 533 (Pa. Super. 2004).” See id. (some formatting altered). These citations are so nonsensical and disconnected from Appellant’s claims that we conclude that they are hallucinated citations. To the extent that Appellant has employed generative artificial intelligence (“generative AI” or “GAI”) tools to draft her brief, as indicated by her repeated misrepresentations of the meaning of valid statutes and precedential opinions as well as her reliance on hallucinated authority, we note that the use of GAI to draft legal filings (including by pro se litigants), without verification of the accuracy of the content so produced, may lead to misstatements and/or misrepresentations of legal authority. ... We note that the Atlantic Reporter citation “167 A.2d 306” leads to a Pennsylvania Supreme Court opinion, Slott v. Plastic Fabricators, Inc., 167 A.2d 306 (Pa. 1961), not to a Pennsylvania Superior Court opinion captioned “General Fin. Co. v. Archetto” as Appellant states. ... In fact, “Lowrey v. Eastaff” appears to be an entirely fabricated caption, coupled with a hallucinated citation.", "ai_tool_named": null, "archive_url": null, "case_name": "Kaspryak v. Stadarskyy", "citation": "2026 PA Super 185", "cited_authorities": [ "General Fin. Co. v. Archetto, 167 A.2d 306 (Pa. Super. 1961)", "Lowrey v. Eastaff, 860 A.2d 533 (Pa. Super. 2004)", "Saber Healthcare Group, LLC v. Duchene, 350 A.3d 966 (Pa. Super. 2025)", "Slott v. Plastic Fabricators, Inc., 167 A.2d 306 (Pa. 1961)", "General Finance Corp. v. Archetto, 176 A.2d 73 (R.I. 1961)", "Commonwealth v. duPont, 860 A.2d 525 (Pa. Super. 2004)" ], "court": "Superior Court of Pennsylvania", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-19", "decision_id": "pasuperct-2026-kaspryak-v-stadarskyy", "disposition": "The court affirmed dismissal of the partition action and held the appellant waived claims through unsupported and fabricated authority.", "docket_number": "2781 EDA 2025", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant cited General Fin. Co. v. Archetto and Lowrey v. Eastaff with reporter citations that led to different cases or a fabricated caption.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2913/Kaspryak_Z._v._Stadarskyy_USA_19_August_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "85a77d5ed3cb9a5bc69d64c171251ec8b596312c677ba1ae35da792c4fe19b05", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "kaspryak-v-stadarskyy", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pasuperct-2026-kaspryak-v-stadarskyy", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pasuperct-2026-kaspryak-v-stadarskyy" }, { "ai_passage": "FINRA states that Kelly’s opposition to its motion to dismiss contains several nonexistent case citations and quotations that do not appear in Kelly’s cited caselaw. I reviewed the citations in the first few pages of Kelly’s opposition and found several quotes that did not appear in the cited cases. These false quotes appear on page 2, lines 11-12; page 3, lines 3-4; and page 9, line 20 to page 10, line 5 of Kelly’s opposition. ... There has been a rise in fake authority cited in briefs, usually as the result of using generative AI software, like ChatGPT, to draft pleadings. Chavez-DeRemer v. NAB, LLC, No. 2:21-CV-00984-JAD-EJY, 2025 WL 2308676, at *3 (D. Nev. Aug. 11, 2025). Generative AI often invents fake cases and legal precedent in its drafting, and using it is no excuse for not verifying the veracity of citations. ... Going forward, Kelly is reminded of his duty under Federal Rule of Civil Procedure 11(b)(2) and that citing fake cases drafted by generative AI violates this rule. Failure to comply in the future may result in sanctions.", "ai_tool_named": null, "archive_url": null, "case_name": "Kelly v. Financial Industry Regulatory Authority", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Golden Eagle Distributing Corp. v. Burroughs Corp., 801 F.2d 1531 (9th Cir. 1986)", "Whiting v. City of Athens, Tenn., 170 F.4th 455 (6th Cir. 2026)", "Chavez-DeRemer v. NAB, LLC, 2025 WL 2308676 (D. Nev. Aug. 11, 2025)" ], "court": "United States District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-19", "decision_id": "nvd-2026-kelly-v-finra", "disposition": "The court dismissed the second amended complaint and warned Kelly that citing fake cases generated by AI can lead to sanctions.", "docket_number": "2:25-cv-01195-APG-DJA", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff’s opposition contained several nonexistent case citations and false quotations that did not appear in the cited cases.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2924/Kelly_v._Financial_Industry_Regulatory_Authority_USA_19_August_2026.pdf", "state": "NV", "summary": "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.", "text_sha256": "738fd8112072ef8f65eefda935972b03cdb7f69b59676b235d25eeca1bc7798b", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "kelly-v-financial-industry-regulatory-authority", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nvd-2026-kelly-v-finra", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-kelly-v-finra" }, { "decision_id": "mitchell-ga-2026", "case_name": "Mitchell v. HIG Realty Credit Fund, LP", "court": "Court of Appeals of Georgia", "court_code": "gactapp", "court_level": "state-appellate", "state": "GA", "date_filed": "2026-08-19", "citation": null, "docket_number": "A26A0854", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "generative AI", "disposition": "The court affirmed summary judgment and declined sanctions while cautioning Mitchell about future AI-related citation defects.", "ai_passage": "As an initial matter, we note that in his appellate briefing, Mitchell cites five cases that are either fictitious or have nothing to do with the propositions for which they are cited.1 These defects suggest that Mitchell’s briefs were “drafted with the use of unchecked generative AI,”2 and his reliance on non-existent law is a clear impediment to the work of this Court.3 We elect not to sanction Mitchell because HIG has not complained and does not appear to have been hampered in responding to Mitchell’s arguments.4 Nevertheless, we caution Mitchell that any future filings in this Court containing citations to fictitious or plainly inapplicable cases may result in the imposition of sanctions.5 1 Mitchell purports to cite Walker v. Pierce, 315 Ga. App. 524 (2012), and Crenshaw v. Ga. Dep’t of Human Resources, 263 Ga. 722 (1994), which do not exist. He also cites Henson v. Columbus Bank & Trust Co., 144 Ga. App. 80 (240 SE2d 284) (1977), and Stamps v. Nelson, 290 Ga. App. 277 (659 SE2d 697) (2008), which do exist, but have nothing to do with the issues raised in this appeal. 2 Slay v. Ross, 379 Ga. App. 1, 1 (927 SE2d 569) (2026). 3 See Shahid v. Essam, 376 Ga. App. 145, 145–50(1) (918 SE2d 198) (2025).", "cited_authorities": [ "Slay v. Ross, 379 Ga. App. 1 (2026)", "Shahid v. Essam, 376 Ga. App. 145 (2025)" ], "summary": "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.", "verification": "mirror-read", "notes": "Official Georgia e-filing download was blocked; court-authored PDF was read from CourtListener storage fallback.", "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10953742/x/", "text_sha256": "f8214c899415b7f9f79026f819e84e0bf20a7b63e32b5fccc9349206a35e08ee", "source_url": "https://efast.gaappeals.gov/download?filingId=33effe0f-f312-412d-aaae-4ceaee6d5229", "archive_url": "https://web.archive.org/web/20260907215437/https://efast.gaappeals.gov/download?filingId=33effe0f-f312-412d-aaae-4ceaee6d5229", "fetched_at": "2026-09-07T22:15:00Z", "lead_source": [ "CourtListener anonymous search pro-se-chatgpt.json" ], "url": "https://safelegalai.com/courts/opinions/mitchell-ga-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mitchell-ga-2026" }, { "ai_passage": "In her resistance to Brett’s motion for remand and request for sanctions, Lacey asked our supreme court to impose sanctions on Brett for purported use of generative AI in his limited-remand motion and briefs. ... The twist is that, absent the presence of a hallucinated case, it is difficult to differentiate poor human drafting from unverified generative AI. Here, we can find no hallucinated case. And it is impossible for us to say with certainty whether Brett’s single reference to the nonexistent “Iowa R. App. P. 6.1004(3)” was a simple typo or the result of unchecked AI use. Thus, we decline to apply sanctions for Brett’s purported use of AI. But regardless of whether Brett’s briefs were directly drafted by him or a faraway datacenter, he is bound by the same duty to verify his briefs’ accuracy and compliance with our appellate rules.", "ai_tool_named": null, "archive_url": null, "case_name": "Wilkinson v. Schmelzer", "citation": null, "cited_authorities": [ "Luke v. Department of Health & Human Services, 2025 WL 2237311 (Iowa Ct. App. Aug. 6, 2025)", "Iowa R. App. P. 6.1004(3)", "Iowa R. App. P. 6.903" ], "court": "Court of Appeals of Iowa", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-19", "decision_id": "iowactapp-2026-wilkinson-v-schmelzer", "disposition": "The court affirmed, declined AI-use sanctions, and awarded appellate attorney fees and costs on other grounds.", "docket_number": "25-0799", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant cited nonexistent Iowa R. App. P. 6.1004(3), but the court could not tell whether it was a typo or unchecked AI output.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2918/Brett_Thomas_Wilkinson_v._Lacey_Schmelzer_USA_19_August_2026.pdf", "state": "IA", "summary": "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.", "text_sha256": "3eb7fd6e6ab6607789cfe5699a02019f458cd68edacb3808dfe6188944c72ff8", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "wilkinson-v-schmelzer", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/iowactapp-2026-wilkinson-v-schmelzer", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/iowactapp-2026-wilkinson-v-schmelzer" }, { "ai_passage": "Appellant’s brief is replete with false quotations and erroneous statements of law. By way of example, appellant cites In re Chi., Milwaukee, St. Paul & Pac. R.R. Co., 6 F.3d at 1188, for the proposition that the applicable standard of review is de novo. [17] at 18. True, a bankruptcy court’s legal conclusions are reviewed de novo. But this proposition cannot be found in the cited case. To the contrary, In re Chi., Milwaukee, St. Paul & Pac. R.R. Co. makes clear that the proper standard of review for a permissive-abstention case is abuse of discretion. 6 F.3d at 1188. Another example includes apparent quotations that do not appear in the cited cases. See, e.g., [17] at 32 (falsely quoting In re Tarnow, 749 F.2d 464, 465 (7th Cir. 1984)); [17] at 23 (falsely quoting In re Aguirre, 37 F.4th 427, 431 (7th Cir. 2022)); [17] at 26 (falsely quoting In re Boughton, 60 B.R. 373, 376 (N.D. Ill. 1986)); [17] at 39 (falsely quoting In re Chi., Milwaukee, St. Paul & Pac. R.R. Co., 6 F.3d at 1192)). ... I order appellant’s counsel, Martin Spencer, to show cause why he should not be sanctioned for the fabricated legal citations and other misrepresentations.", "ai_tool_named": null, "archive_url": null, "case_name": "Snisko v. Cascade Funding Mortgage Trust HB4", "citation": null, "cited_authorities": [ "In re Chi., Milwaukee, St. Paul & Pacific Railroad Co., 6 F.3d 1184 (7th Cir. 1993)", "In re Tarnow, 749 F.2d 464 (7th Cir. 1984)", "In re Aguirre, 37 F.4th 427 (7th Cir. 2022)", "In re Boughton, 60 B.R. 373 (N.D. Ill. 1986)", "In re Pajian, 785 F.3d 1161 (7th Cir. 2015)", "In re K&R Mining, Inc., 135 B.R. 269 (Bankr. N.D. Ohio 1991)", "Secrease v. Western & Southern Life Insurance Co., 800 F.3d 397 (7th Cir. 2015)" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-19", "decision_id": "ilnd-2026-snisko-v-cascade-funding", "disposition": "The court affirmed the bankruptcy court and ordered appellant's counsel to show cause why he should not be sanctioned.", "docket_number": "25 CV 13339", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Appellant’s counsel filed false quotations and erroneous statements of law, then repeated them in reply after appellee identified the errors.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2910/Snisko_v._Cascade_Funding_Mortgage_Trust_HB4_USA_19_August_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "19b253feed1d8468651cca0df96177abc90529f66a1b05cbabdffbe68c3c2b61", "topics": [ "fabricated-citations" ], "tracker_slug": "snisko-v-cascade-funding-mortgage-trust-hb4", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-snisko-v-cascade-funding", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-snisko-v-cascade-funding" }, { "ai_passage": "As an initial matter, we note that in his appellate briefing, Mitchell cites five cases that are either fictitious or have nothing to do with the propositions for which they are cited.1 These defects suggest that Mitchell’s briefs were “drafted with the use of unchecked generative AI,”2 and his reliance on non-existent law is a clear impediment to the work of this Court.3 We elect not to sanction Mitchell because HIG has not complained and does not appear to have been hampered in responding to Mitchell’s arguments.4 Nevertheless, we caution Mitchell that any future filings in this Court containing citations to fictitious or plainly inapplicable cases may result in the imposition of sanctions.5 ... Mitchell purports to cite Walker v. Pierce, 315 Ga. App. 524 (2012), and Crenshaw v. Ga. Dep’t of Human Resources, 263 Ga. 722 (1994), which do not exist. He also cites Henson v. Columbus Bank & Trust Co., 144 Ga. App. 80 (240 SE2d 284) (1977), and Stamps v. Nelson, 290 Ga. App. 277 (659 SE2d 697) (2008), which do exist, but have nothing to do with the issues raised in this appeal.", "ai_tool_named": null, "archive_url": null, "case_name": "Mitchell v. HIG Realty Credit Fund, L.P.", "citation": null, "cited_authorities": [ "Walker v. Pierce, 315 Ga. App. 524 (2012)", "Crenshaw v. Georgia Department of Human Resources, 263 Ga. 722 (1994)", "Henson v. Columbus Bank & Trust Co., 144 Ga. App. 80 (1977)", "Stamps v. Nelson, 290 Ga. App. 277 (2008)", "Slay v. Ross, 379 Ga. App. 1 (2026)", "Shahid v. Essam, 376 Ga. App. 145 (2025)", "Court of Appeals Rule 7(e)(2)" ], "court": "Court of Appeals of Georgia", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-19", "decision_id": "gactapp-2026-mitchell-v-hig-realty-credit", "disposition": "The court affirmed summary judgment and warned Mitchell that future fictitious or inapplicable citations may result in sanctions.", "docket_number": "A26A0854", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant cited two nonexistent cases and two unrelated cases for propositions in his appellate brief.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2914/TRENTISS_MITCHELL_v._HIG_REALTY_CREDIT_FUND_USA_19_August_2026.pdf", "state": "GA", "summary": "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.", "text_sha256": "71eefc9d5bb356b69a2be63a74fd3a6c60ddd8894f3512f50fee48cf286fa345", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "mitchell-v-hig-realty-credit-fund-l-p", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gactapp-2026-mitchell-v-hig-realty-credit", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gactapp-2026-mitchell-v-hig-realty-credit" }, { "ai_passage": "Wife miscited three cases in her respondent’s brief by attributing to them quotations or legal propositions that do not appear in the cited opinions.3 The miscitations appear to be the result of Wife’s use of generative artificial intelligence without sufficient verification. We have disregarded the arguments in Wife’s brief that are based on the miscited authorities.4 Husband “has considered, but chosen not, to seek sanctions for violations of the relevant rules of court.” (See rule 8.204(a)(1)(B) [requiring that assertions of law in a brief be supported by citation to legal authority]; Noland v. Land of the Free, L.P. (2025) 114 Cal.App.5th 426, 445 [“relying on fabricated legal authority is sanctionable”]; Sheerer v. Panas (2026) 119 Cal.App.5th 367, 371 [it is “a requirement of all attorneys and self-represented litigants responsible for briefs filed in this Court” to “verify citations”].) We decline to sanction Wife. We do, however, find it appropriate because of the hallucinated citations to deny her prevailing party costs on appeal.", "ai_tool_named": null, "archive_url": null, "case_name": "In re Marriage of Dillon", "citation": null, "cited_authorities": [ "Wilkison v. Wiederkehr, 101 Cal.App.4th 822 (2002)", "Brown v. Grimes, 192 Cal.App.4th 265 (2011)", "In re Marriage of Iberti, 55 Cal.App.4th 1434 (1997)", "Cal. Rules of Court, rule 8.204(a)(1)(B)", "Noland v. Land of the Free, L.P., 114 Cal.App.5th 426 (2025)", "Sheerer v. Panas, 119 Cal.App.5th 367 (2026)", "Cal. Rules of Court, rule 8.278" ], "court": "California Court of Appeal, Fourth Appellate District, Division One", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-19", "decision_id": "calctapp-2026-marriage-of-dillon", "disposition": "The court affirmed the order, declined sanctions, but denied respondent prevailing-party costs because of hallucinated citations.", "docket_number": "D085064", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented respondent attributed quotations or propositions to Wilkison, Brown, and Iberti that did not appear in those opinions.", "currency": null, "monetary_penalty": null, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2917/Marriage_of_Dillon_USA_18_AUgust_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "c2e08e2a44efff4c76b5d77206ac6f652a53432050e887d17e98fd8cea827bfe", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "in-re-marriage-of-dillon", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp-2026-marriage-of-dillon", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp-2026-marriage-of-dillon" }, { "ai_passage": "The Court also issued sua sponte sanctions against Plaintiff’s attorney, Ms. Jocelyn Stewart, for generating numerous false citations with artificial intelligence and submitting them to the Court without verification. Dkt. 265. Multiple such citations existed in the expert reports of Mr. James Kababick and Dr. Ronald Shippee, where Plaintiff admitted that “she used Claude or ChatGPT to ‘generate a formatted citation table’ for academic articles and ‘provided the same AI-generated citation table to both experts as an appendix, and neither expert caught the errors in the citation data before signing their reports.’” Dkt. 265 at 7 (quoting Dkt. 245 at 17–18). ... The Court agrees with Defendants and finds that Dr. Holguin’s multiple hallucinated citations “shatter[] his credibility with this Court.” Kohls v. Ellison, No. 24-CV-3754 (LMP/DLM), 2025 WL 66514, at *4 (D. Minn. Jan. 10, 2025). ... This level of involvement from counsel in drafting (with AI) the list of materials supposedly relied upon by Dr. Holguin, and Dr. Holguin’s lack of diligence in verifying the sources that he represented were the basis for his opinion, prevent Plaintiff from meeting her burden to show that Dr. Holguin’s opinion is “based on sufficient facts or data,” is “the product of reliable principles and methods,” or “reflects a reliable application of the principles and methods to the facts of the case.” Fed. R. Evid. 702(b)–(d).", "ai_tool_named": "Claude or ChatGPT", "archive_url": null, "case_name": "LeDoux v. Outliers, Inc.", "citation": null, "cited_authorities": [ "Dkt. 265", "Dkt. 245", "Kohls v. Ellison, 2025 WL 66514 (D. Minn. Jan. 10, 2025)", "Concord Music Group, Inc. v. Anthropic PBC, 2025 WL 1482734 (N.D. Cal. May 23, 2025)", "Fed. R. Evid. 702" ], "court": "United States District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-18", "decision_id": "wawd-2026-ledoux-v-outliers-summary-judgment", "disposition": "The court granted defendants' summary judgment motion and excluded an expert report after finding hallucinated citations undermined reliability.", "docket_number": "3:24-cv-05808-TMC", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": "Claude or ChatGPT", "conduct": "Counsel used Claude or ChatGPT to generate false academic citation tables supplied to experts; Dr. Holguin’s report also contained hallucinated citations.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2902/Ledoux_v._Outliers_USA_August_2026.pdf", "state": "WA", "summary": "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.", "text_sha256": "e5098ff93fc925099a3bfa7b654fc9ae0c899ff9279b6cfc19e3bc45a15c845d", "topics": [ "fabricated-citations", "evidence-authentication" ], "tracker_slug": "ledoux-v-outliers", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wawd-2026-ledoux-v-outliers-summary-judgment", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-ledoux-v-outliers-summary-judgment" }, { "ai_passage": "However, we award appellate attorney fees to Rebekah under RAP 18.9(a) for her time spent reviewing and responding to Jonathan’s response brief. Here, Jonathan’s brief twice cites to Marriage of Sanjuan to support his arguments, but as Rebekah points out in her reply brief, no such case exists. We surmise that Jonathan used artificial intelligence (AI) to assist in writing his brief, which resulted in an “AI hallucination.”13 While Jonathan is entitled to use AI to write his response brief, he is still required to conduct a reasonable inquiry and confirm that the claims he advances are well-grounded in fact and in law. In re Estate of Little, 9 Wn. App. 2d 262, 274 n.4, 444 P.3d 23 (stating that “[w]e hold a pro se litigant to the same standard as an attorney”), review denied, 194 Wn.2d 1006 (2019). In citing to a hallucinated case, Jonathan has submitted a frivolous filing that “is so totally devoid of merit.” A.T., 11 Wn. App. 2d at 171. Accordingly, we award Rebekah appellate attorney fees for time spent reviewing and responding to Jonathan’s response brief in an amount to be determined by the commissioner pursuant to RAP 18.1(f).", "ai_tool_named": null, "archive_url": null, "case_name": "In re Marriage of Muriel and Farris", "citation": null, "cited_authorities": [ "Marriage of Sanjuan", "RAP 18.9(a)", "In re Estate of Little, 9 Wn. App. 2d 262 (2019)", "A.T., 11 Wn. App. 2d 156", "RAP 18.1(f)" ], "court": "Court of Appeals of Washington, Division Two", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-18", "decision_id": "washctapp-2026-muriel-v-farris", "disposition": "The court affirmed the parenting plan and awarded fees for time spent responding to a brief citing a nonexistent case.", "docket_number": "60903-7-II", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "other", "ai_tool": null, "conduct": "Response brief twice cited nonexistent Marriage of Sanjuan; the court surmised AI-assisted drafting and deemed the filing frivolous.", "currency": null, "monetary_penalty": null, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only. The opinion attributes the response brief to Jonathan; the source lead identifies a lawyer.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2894/Muriel_v._Farris_USA_18_August_2026.pdf", "state": "WA", "summary": "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.", "text_sha256": "80df6d4e05c05ac8751eefb1db2d549ea732a44e0c6de7dee1b5fb0a25821d23", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "in-re-marriage-of-muriel-and-farris", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/washctapp-2026-muriel-v-farris", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/washctapp-2026-muriel-v-farris" }, { "ai_passage": "He then cites a variety of cases supporting this contention, the majority of which do not exist.4 The Court will nonetheless consider Petitioner’s due process argument, as it will not punish Petitioner for his counsel’s mistakes. ... The Court notes that an alarming number of cases cited by Petitioner for support in his Reply are nonexistent, “hallucinated” cases, such as Kostak v. Garland, No. 24-cv-11024-ADB, 2025 WL 2472136, at *4–6 (D. Mass. May 22, 2025); Martinez Lopez v. Garland, No. 1:25-cv-00069, 2026 WL 1200000, at *4–5 (D. Colo. Mar. 24, 2026); Cruz-Reyes v. Decker, No. 1:25-cv-01719-MKV, 2025 WL 332315, at *4–6 (S.D.N.Y. Jan. 21, 2025); Castanon Nava v. Garland, No. 2:25-cv-01308-JHC, 2026 WL 1234567, at *5–7 (W.D. Wash. Feb. 11, 2026); Duarte Escobar v. Garland, No. 1:25-cv-00963-MSN-LRV, 2025 WL 7061234, at *2–4 (E.D. Va. Dec. 2, 2025). ... None of these cases exist on Westlaw or on the purported courts’ dockets. Indeed, Petitioner also hallucinates a case purportedly written by this Court: Garcia v. Mullin, No. 1:25-cv-00836-RP, 2026 WL 1045678, at *2–4 (W.D. Tex. Mar. 9, 2026). Petitioner’s counsel is strongly cautioned that future inaccurate citations “hallucinated” by generative artificial intelligence tools may result in sanctions.", "ai_tool_named": null, "archive_url": null, "case_name": "Garcia Perez v. Blanche", "citation": null, "cited_authorities": [ "Kostak v. Garland, 2025 WL 2472136 (D. Mass. May 22, 2025)", "Martinez Lopez v. Garland, 2026 WL 1200000 (D. Colo. Mar. 24, 2026)", "Cruz-Reyes v. Decker, 2025 WL 332315 (S.D.N.Y. Jan. 21, 2025)", "Castanon Nava v. Garland, 2026 WL 1234567 (W.D. Wash. Feb. 11, 2026)", "Duarte Escobar v. Garland, 2025 WL 7061234 (E.D. Va. Dec. 2, 2025)", "Garcia v. Mullin, 2026 WL 1045678 (W.D. Tex. Mar. 9, 2026)", "Fed. R. Civ. P. 11(b)" ], "court": "United States District Court for the Western District of Texas", "court_code": "txwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-18", "decision_id": "txwd-2026-perez-v-blanche", "disposition": "The court ordered additional briefing and cautioned petitioner's counsel that future hallucinated citations may result in sanctions.", "docket_number": "1:26-cv-00786-RP", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Petitioner’s counsel cited multiple nonexistent immigration cases in reply, including a fabricated decision purportedly issued by the same district court.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2919/Perez_v._Blanche_USA_18_August_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "5c8ec9f9a145bde469c9df023b6e518c8f7c4bfe9be8036a42e10166d5233c34", "topics": [ "fabricated-citations" ], "tracker_slug": "garcia-perez-v-blanche", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txwd-2026-perez-v-blanche", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txwd-2026-perez-v-blanche" }, { "ai_passage": "The brief also included incomplete legal citations accompanied by unintelligible numeric strings (e.g., “2990836”). We again struck Kourradi’s appellate brief and ordered Kourradi to file a corrected brief. We admonished Kourradi to ensure that record references and citations to authorities are accurate. See Campbell v. Campbell, No. 03-25-00388-CV, 2026 WL 179402, at *2 n.3 (Tex. App.—Austin Jan. 22, 2026, no pet.) (mem. op.) (admonishing appellant to “take care not to include hallucinated citations, quotations, or authorities of any kind in the materials that he submits for filing in this Court”). ... More concerningly, we are unable to locate the following legal authorities on which Kourradi relies when using the citation format he provides: • Ruth Wheeler v. John Collier Hinson, No. 07-10-00308-CV, 2011 WL 1905858 (Tex. App.—Amarillo May 19, 2011, no pet.) (mem. op.) • David Lee Carpenter, Jr. v. Sharon K. Carpenter, No. 09-11-00414-CV, 2012 WL 2370823 (Tex. App.—Beaumont July 5, 2012, no pet.) (mem. op.) • Brazos Valley Roadrunners, LLC v. Brian Niles, No. 03-21-00523-CV, 2022 WL 1938866, at *4 (Tex. App.—Austin June 1, 2022, no pet.) (mem. op.) ... The database identifiers are non-existent, and the appellate case numbers point us to appeals that involve parties different from the parties listed in the citations provided by Kourradi. ... The nature of the errors suggests that each of the foregoing legal citations is, at best, partially fabricated.", "ai_tool_named": null, "archive_url": null, "case_name": "Kourradi v. Christopher", "citation": null, "cited_authorities": [ "Campbell v. Campbell, 2026 WL 179402 (Tex. App.—Austin Jan. 22, 2026)", "Ruth Wheeler v. John Collier Hinson, 2011 WL 1905858", "David Lee Carpenter, Jr. v. Sharon K. Carpenter, 2012 WL 2370823", "Brazos Valley Roadrunners, LLC v. Brian Niles, 2022 WL 1938866", "George Jamil Wehbe v. State, 2011 WL 1742356", "Tex. R. App. P. 38.1", "Tex. R. App. P. 38.9", "Tex. R. App. P. 42.3" ], "court": "Court of Appeals of Texas, First District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-18", "decision_id": "texapp-2026-kourradi-v-christopher", "disposition": "The court struck Kourradi's fourth brief and dismissed the appeal for want of prosecution.", "docket_number": "01-26-00014-CV", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant filed repeated briefs with unlocatable or mismatched Westlaw-style citations and appellate case numbers.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2915/Manny_Kourradi_v._Wyatt_Brian_Christophe_USA_18_August_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "42b2c481b3cfa5cc8a391eb3720b1f93c9bfeedbf9114ba23de0a31b9c9273e2", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "kourradi-v-christopher", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp-2026-kourradi-v-christopher", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp-2026-kourradi-v-christopher" }, { "ai_passage": "We are particularly troubled by the fact that one of her case citations in her opening brief (as IHR notes) does not exist: “Helm v. Illinois Cent. R.R.” does not appear in any reported case in this state, and the precise citation (again, as IHR points out), “142 Ill. App. 3d 108 (1986),” is for a criminal case entitled, “People v. Hardy,” which again contains no discussion of judicial notice. Although we do not know for certain whether this citation was the result of an artificial intelligence (AI) “hallucination,” Sani should be aware that this court is growing increasingly impatient with the patently improper practice of submitting citations of authority that neither exist nor even arguably support the claim on appeal. See, e.g., Scott v. Illinois Human Rights Comm'n, 2026 IL App (1st) 251462, ¶ 56 (imposing a $15,000 fine on an attorney whose brief contained “10 false citations”). Although Sani is proceeding pro se, she must comply with the same rules and will be held to the same standards as licensed attorneys.", "ai_tool_named": null, "archive_url": null, "case_name": "Sani v. Institute for Human Reproduction", "citation": "2026 IL App (1st) 252264-U", "cited_authorities": [ "Helm v. Illinois Cent. R.R., 142 Ill. App. 3d 108 (1986)", "People v. Hardy, 142 Ill. App. 3d 108 (1986)", "Scott v. Illinois Human Rights Commission, 2026 IL App (1st) 251462" ], "court": "Appellate Court of Illinois, First District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-18", "decision_id": "illappct-2026-sani-v-institute-for-human-reproduction", "disposition": "The court affirmed dismissal and admonished the self-represented appellant about nonexistent or unsupported citations.", "docket_number": "1-25-2264", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant cited nonexistent Helm v. Illinois Cent. R.R.; the reporter citation led to People v. Hardy and did not address judicial notice.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2922/Sani_v_Institute_for_Human_Reproduction_USA_18_August_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "3efa1dc1479694f4c7338edbdca5b02de7424d4753d444d3b2fbabd7882a66df", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "sani-v-institute-for-human-reproduction", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/illappct-2026-sani-v-institute-for-human-reproduction", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illappct-2026-sani-v-institute-for-human-reproduction" }, { "ai_passage": "Plaintiff has himself been admonished by the Court for citing non-existent authority. In his brief, plaintiff cited several purported decisions of this Court, including “Slayton v. Willing, 2010 VT 56, ¶ 14, 188 Vt. 216, 4 A.3d 1155,” “Sorrell v. Wigginton, 154 Vt. 301, 303 (1990),” “Morrison v. City of Montpelier, 2011 VT 9, ¶ 10,” “Thrall v. Rowan, 161 Vt. 451, 456 (1994),” and “EcoScience Corp. v. United States, 156 Vt. 185, 193 (1991),” among others. The Vermont Reports citations provided by plaintiff correspond to entirely different opinions than those named. We were unable to identify any existing case that corresponds to the citations provided in plaintiff's brief. ... Plaintiff's misrepresentation of the record extends to asserting that documents and records contain quotations that simply are not there. ... Plaintiff's practice of citing to non-existent authority and misrepresenting the contents of court records is a waste of limited judicial resources, a waste of the resources of opposing parties and further evidence of his disrespect for the courts of this State. ... Defendant's Motion for Sanctions (# 7) is GRANTED. Plaintiff is hereby ENJOINED from filing any new actions in the Civil Division of the Vermont Superior Court without obtaining prior leave from the court.", "ai_tool_named": null, "archive_url": null, "case_name": "Rivard v. Vermont Department of Corrections", "citation": "2026 WL 2479362", "cited_authorities": [ "Slayton v. Willing, 2010 VT 56", "Sorrell v. Wigginton, 154 Vt. 301 (1990)", "Morrison v. City of Montpelier, 2011 VT 9", "Thrall v. Rowan, 161 Vt. 451 (1994)", "EcoScience Corp. v. United States, 156 Vt. 185 (1991)", "V.R.C.P. 11", "V.R.A.P. 25" ], "court": "Superior Court of Vermont, Windham Unit", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-14", "decision_id": "vtsuperct-2026-rivard-v-vermont-dept-corrections", "disposition": "The court granted a sanctions motion and imposed a prefiling injunction in Vermont Superior Court civil cases.", "docket_number": "26-CV-01521", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff repeatedly cited non-existent Vermont authority, mismatched reporter citations, and spurious quotations from court records.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2953/Rivard_v_Vermont_Dept_of_Corrections_USA_14_August_2026.pdf", "state": "VT", "summary": "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.", "text_sha256": "9c1fa2f02d03afad0b085d8317a8fa080a421ccefc35d5eafd9c60898df70b09", "topics": [ "fabricated-citations", "pro-se-ai-use", "competence-fees" ], "tracker_slug": "rivard-v-vermont-department-of-corrections", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/vtsuperct-2026-rivard-v-vermont-dept-corrections", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/vtsuperct-2026-rivard-v-vermont-dept-corrections" }, { "ai_passage": "In Harris's motion for extension of time to effect service of process, he cites Walsh v. Kreiger, No. 19-cv-1764, 2020 WL 6325983, at 2 (E.D. Wis. Oct. 28, 2020) (citing United States v. McLaughlin, 470 F.3d 698, 700 (7th Cir. 2006)), for the proposition that “good cause” not the stricter “excusable neglect” standard is the appropriate test for Fed. R. Civ. P. 4(m) extensions. Dkt. 15 at 3. While the Court has found McLaughlin and Walsh to be real cases, the Walsh citation is wholly incorrect. The docket number listed following Harris's Walsh cite is linked to a different case in the Eastern District of Wisconsin, and the Westlaw citation leads to nowhere. While Walsh v. Kreiger appears to be a real case and there is an October 28, 2020, order referencing Mclaughlin, the incorrect cite gives the Court pause. ... Because the Court dismisses Harris's complaint in its entirety, it will not order him to show cause at this time. However, Harris is accordingly warned of the possibility of sanctions if any future filings violate Rule 11(b).", "ai_tool_named": null, "archive_url": null, "case_name": "Harris v. Wray", "citation": "2026 WL 2374808", "cited_authorities": [ "Walsh v. Kreiger, No. 19-cv-1764, 2020 WL 6325983 (E.D. Wis. Oct. 28, 2020)", "United States v. McLaughlin, 470 F.3d 698 (7th Cir. 2006)", "Fed. R. Civ. P. 4(m)", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-14", "decision_id": "insd-2026-harris-v-wray", "disposition": "The court dismissed the complaint without prejudice, allowed amendment, and warned Harris about Rule 11 and AI-policy compliance.", "docket_number": "1:26-cv-01342-JRO-MG", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff cited Walsh v. Kreiger with a docket number linked to another case and a Westlaw citation that led nowhere.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2901/Harris_v._Wray_USA_14_August_2026.pdf", "state": "IN", "summary": "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.", "text_sha256": "9817e328b82299f3d39502e28ac318afafc5f8132e6ef3088ae3da9fd920c3fd", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "harris-v-wray", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/insd-2026-harris-v-wray", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-harris-v-wray" }, { "ai_passage": "Brankle’s motion is totally without merit. First, Commercial Court Rules are inapplicable to this case[,] and Brankle should not cite to them again. Brankle’s repeated citations to rules that do not exist or fictitious cases leads the Court to opine that Brankle is using ChatGPT or other form of artificial intelligence to prepare his numerous motions, responses, and notices to the Court which is a violation of Ind. Trial Rule 11(A). ... First, Brankle claims the motion to compel was substantially justified. A party is “substantially justified” in filing a motion to compel “if reasonable persons could conclude that a genuine issue existed as to whether a person was bound to comply with the requested discovery.” Yount v. Carpenter Co. Inc., 219 N.E.3d 127, 132 (Ind. Ct. App. 2023) (quoting Huber v. Montgomery Cnty. Sheriff, 940 N.E.2d 1182, 1186 (Ind. Ct. App. 2010)). A motion riddled with citations to hallucinated authorities is hardly “substantially justified.” ... Brankle does not address the trial court’s findings that he cited to inapplicable Commercial Court Rules and hallucinated authorities.", "ai_tool_named": "ChatGPT or other form of artificial intelligence", "archive_url": "https://web.archive.org/web/20260907205707/https://websitedc.s3.amazonaws.com/documents/Brankle_v._Schmell_USA_14_August_2026.pdf", "case_name": "Brankle v. Schmell", "citation": null, "cited_authorities": [ "Ind. Trial Rule 11(A)", "Ind. Trial Rule 37(A)(4)", "Yount v. Carpenter Co. Inc., 219 N.E.3d 127 (Ind. Ct. App. 2023)", "Huber v. Montgomery County Sheriff, 940 N.E.2d 1182 (Ind. Ct. App. 2010)", "Indiana Appellate Rule 46(A)(8)(a)" ], "court": "Court of Appeals of Indiana", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-14", "decision_id": "indctapp-2026-brankle-v-schmell", "disposition": "The court affirmed a $1,546 expenses award and remanded for appellate attorneys' fees.", "docket_number": "26A-PL-887", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": "ChatGPT or other form of artificial intelligence", "conduct": "Self-represented litigant cited nonexistent Commercial Court Rules and fictitious cases in a motion to compel and related filings.", "currency": "USD", "monetary_penalty": 1546, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2920/Brankle_v._Schmell_USA_14_August_2026.pdf", "state": "IN", "summary": "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.", "text_sha256": "0f98b2251291e09c3d463d74d7a69c4016d33c01dd0208becf04a3bd45da9830", "topics": [ "fabricated-citations", "pro-se-ai-use", "competence-fees" ], "tracker_slug": "brankle-v-schmell", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/indctapp-2026-brankle-v-schmell", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/indctapp-2026-brankle-v-schmell" }, { "ai_passage": "Appellants have not adequately briefed these claims: They are completely unsubstantiated by citations to the record, and the case citations in the briefing are systematically defective. Accordingly, Appellants have forfeited these arguments. ... Troubling to the court is the fact that the briefs filed in both cases by Appellants’ counsel contain significant inaccuracies. Both briefs quote Ng Fung Ho v. White, 259 U.S. 276, 284 (1922), for the proposition that “[N]o deportable alien may be expelled until it has first been determined . . . that he is in fact an alien.” This court’s research has failed to locate this quote in Ng Fung Ho or in any other opinion. Additionally, in Guerra-Vasquez’s opening brief, a parenthetical cites the correct part of Ng Fung Ho but misquotes the majority. Both briefs also attribute the phrase, “[i]t is wrong to deport a United States citizen,” to Ng Fung Ho, but that phrase does not appear in the opinion. ... Federal Rule of Appellate Procedure 28 requires all filed briefs to contain arguments supported by “citations to the authorities,” disallowing citation to nonexistent or fabricated cases. ... The court takes no action now for the foregoing deficiencies, but counsel must take this obligation seriously in the future.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907210437/https://websitedc.s3.amazonaws.com/documents/Quezada_v._USA_USA_14_August_2026.pdf", "case_name": "Guerra-Quezada v. United States", "citation": null, "cited_authorities": [ "Ng Fung Ho v. White, 259 U.S. 276 (1922)", "Doe v. McAleenan, 926 F.3d 910 (7th Cir. 2019)", "Afroyim v. Rusk, 387 U.S. 253 (1967)", "Perez v. Brownell, 356 U.S. 44 (1958)", "Fed. R. App. P. 28", "Fed. R. App. P. 32", "Fed. R. App. P. 38", "Fed. R. App. P. 46", "Garces v. Hernandez, 2025 WL 2401001 (5th Cir. Aug. 19, 2025)" ], "court": "United States Court of Appeals for the Fifth Circuit", "court_code": "ca5", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-14", "decision_id": "ca5-2026-guerra-quezada-v-united-states", "disposition": "The court affirmed one dismissal, remanded the other to dismiss without prejudice, and warned counsel about defective citations.", "docket_number": "25-10372; 25-10555", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Appellants’ counsel filed briefs with false quotations, a misidentified circuit decision, and a quotation attributed to the wrong Supreme Court opinion.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2900/Quezada_v._USA_USA_14_August_2026.pdf", "state": null, "summary": "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.", "text_sha256": "86719d5f7b78bc786652112167654ec3ac58b72004367dd6d8d0c6bfebff6187", "topics": [ "fabricated-citations" ], "tracker_slug": "guerra-quezada-v-united-states", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca5-2026-guerra-quezada-v-united-states", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca5-2026-guerra-quezada-v-united-states" }, { "ai_passage": "Father contends the superior court both lacked jurisdiction to hold him in contempt and abused its discretion by finding him in contempt. He also contends the court imposed improper sanctions. ... In making his jurisdictional argument, Father said, “Arizona appellate courts have consistently held that a trial court may not hold a party in contempt for violating a parenting plan that was never ordered. Without a valid court order, contempt is legally impossible.” He cited two cases for the quote, neither of which contains that language. And we could not find it in any Arizona case. We strike the apparently false quotation. Matter of Est. of Acciavatti, 1 CA-CV 25-0606 PB, 2026 WL 2041963, at *2, ¶ 9 (App. July 15, 2026). But because we identified no additional citation concerns, and opposing counsel raised none (including this one), we decline to impose sanctions. Id. at *4, ¶ 18 (“citing a hallucinated case in a legal filing is sanctionable conduct.”).", "ai_tool_named": null, "archive_url": null, "case_name": "Boettcher v. Boettcher", "citation": null, "cited_authorities": [ "Matter of Estate of Acciavatti, 2026 WL 2041963 (Ariz. App. July 15, 2026)" ], "court": "Arizona Court of Appeals, Division One", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-14", "decision_id": "azctapp-2026-boettcher-v-boettcher", "disposition": "The court accepted special action jurisdiction, granted relief in part, and struck an apparently false quotation.", "docket_number": "1 CA-SA 26-0121", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Petitioner’s filing attributed a jurisdictional quotation to two cases, but neither case contained it and the court could not find it in Arizona law.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2899/BOETTCHER_v._BOETTCHER_USA_14_August_2026.pdf", "state": "AZ", "summary": "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.", "text_sha256": "64a76c382bf74eed8516a6e6f5068c52ced2516ed100f86a06e7385241f96ab9", "topics": [ "fabricated-citations" ], "tracker_slug": "boettcher-v-boettcher", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azctapp-2026-boettcher-v-boettcher", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azctapp-2026-boettcher-v-boettcher" }, { "ai_passage": "Moreover, the Court acknowledges that Plaintiff’s briefs appear to include at least one AI hallucinated citation. Plaintiff has also made unsupported, and to the extent unsupportable, arguably outrageous allegations about Defendants and their counsel. ... Plaintiff has proffered and the Court has seen no evidence to suggest that either of these allegations is at all true. Plaintiff is sternly warned that he must confirm the accuracy of both asserted facts and law cited in his filings to this Court. The Court will not countenance inaccurate or inflammatory allegations. ... The Court notes that Plaintiff appears to have cited an AI-hallucinated case in support of his argument on this point. See Br. in Opp. at 2 (citing the nonexistent case “Loder v. City of Philadelphia, 838 F.3d 311 (3d Cir. 2016)”). Nonetheless, Plaintiff has also cited relevant caselaw, and indeed, the Court finds that Plaintiff’s interpretation is the better one.", "ai_tool_named": null, "archive_url": null, "case_name": "Davenport v. Churilla", "citation": null, "cited_authorities": [ "Loder v. City of Philadelphia, 838 F.3d 311 (3d Cir. 2016)" ], "court": "United States District Court for the Western District of Pennsylvania", "court_code": "pawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-12", "decision_id": "pawd-2026-davenport-v-churilla", "disposition": "The court dismissed several claims, allowed amendment on some, and warned Davenport about false authority and allegations.", "docket_number": "3:25-cv-00330-RJC", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff cited nonexistent Loder v. City of Philadelphia in support of his statute-of-limitations argument.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2898/DAVENPORT_v._CHURILLA_et_al_USA_12_August_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "5f23de9bfc074d8c8353f3a29240c9fef0c4bf63fa09f22d8719ae3d512847a5", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "davenport-v-churilla", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pawd-2026-davenport-v-churilla", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pawd-2026-davenport-v-churilla" }, { "ai_passage": "In her response to Arts Bonita's motion to dismiss, Rose cited Prousalis v. Bert's Bikes & Fitness, No. 8:18-cv-1234, 2019 WL 13202785 (M.D. Fla. 2019). That case does not exist. Once Arts Bonita caught the error, it asked Rose to join an agreed order on generative AI use. The City signed on, but Rose refused, telling counsel that as a pro se litigant she did not want to limit her own access to research and accessibility tools and promised to keep reviewing her filings for accuracy herself. ... Rose eventually filed a notice withdrawing the citation, admitting only that the citation was “incorrect or unverifiable.” ... Rose's conduct falls near the bottom of that range—i.e., a single hallucinated citation. Even so, a fabricated citation is never harmless since it forces the opposing party and the Court to “waste time and money in exposing the deception.” ... A sanction is not yet warranted, but the record supports an admonishment. This is the only warning Rose will receive for her infraction.", "ai_tool_named": null, "archive_url": null, "case_name": "Rose v. Arts Bonita, Inc.", "citation": "2026 WL 2329753", "cited_authorities": [ "Prousalis v. Bert's Bikes & Fitness, 2019 WL 13202785 (M.D. Fla. 2019)", "Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enterprises, LLC, 2025 WL 1440351 (S.D. Fla. May 20, 2025)", "Kendrick v. Secretary, Florida Department of Corrections, 2022 WL 2388425 (11th Cir. July 1, 2022)", "O'Brien v. Flick, 2025 WL 242924 (S.D. Fla. Jan. 10, 2025)", "Mata v. Avianca, Inc., 678 F. Supp. 3d 433 (S.D.N.Y. 2023)", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Middle District of Florida", "court_code": "flmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-12", "decision_id": "flmd-2026-rose-v-arts-bonita", "disposition": "The court partly granted an AI-use motion by warning Rose; it declined to impose a broader AI-use order.", "docket_number": "2:26-cv-484-KCD-KRH", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff cited nonexistent Prousalis v. Bert's Bikes & Fitness, then withdrew it as incorrect or unverifiable.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2831/Rose_v_Arts_Bonita_Inc_USA_12_August_2026.pdf", "state": "FL", "summary": "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.", "text_sha256": "2e0acf6c6f33a7325d92281c09c5d638f8132ce1366d969ea836aa9a03ed71bd", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "rose-v-arts-bonita-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/flmd-2026-rose-v-arts-bonita", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flmd-2026-rose-v-arts-bonita" }, { "ai_passage": "Counsel filed a certiorari petition in this case that is riddled with false citations and arguments, including an unsupported allegation that this Court has “repeatedly entertained, and granted, certiorari review of orders vacating clerk’s defaults.” The petition cited a non-existent case allegedly from this Court and cited other cases that do not support this proposition. ... Counsel’s response acknowledges the false citations identified in our order and identifies additional false citations. Counsel accepts responsibility for his deficient filing but alleges that he did not mean to mislead this Court and merely submitted the wrong draft. Counsel explains that his normal process is to have artificial intelligence (“AI”) software research and draft the initial document, and he then verifies every citation and revises the draft. Counsel allegedly did that in this case and removed all the fake and false citations, but while he was making final edits, he inadvertently worked from the wrong version and ended up filing the AI’s initial draft with this Court. ... Thus, counsel’s petition misrepresented the law and cited non-existent authority for the opposite proposition. ... Accordingly, we refer this matter to the Florida Bar for consideration of disciplinary proceedings.", "ai_tool_named": null, "archive_url": null, "case_name": "JMOR Properties, LLC v. Artist Alley Townhomes, LLC", "citation": null, "cited_authorities": [ "Fla. R. Jud. Admin. 2.515(d)(2)", "Fla. R. App. P. 9.410(a)", "Leibman v. Sportatorium, Inc., 374 So. 2d 1124 (Fla. 4th DCA 1979)", "Eclectic Synergy, LLC v. Seredin, 51 Fla. L. Weekly D1061 (Fla. 4th DCA May 27, 2026)", "Hessert v. Hessert, 431 So. 3d 610 (Fla. 6th DCA 2026)", "Russell v. Mells, 426 So. 3d 913 (Fla. 2d DCA 2025)", "R. Regulating Fla. Bar 4-1.1", "R. Regulating Fla. Bar 3-7.18" ], "court": "District Court of Appeal of Florida, Fourth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-12", "decision_id": "fladistctapp-2026-jmor-properties-v-artist-alley", "disposition": "The court referred petitioner's counsel to the Florida Bar after a certiorari petition contained false AI-draft citations.", "docket_number": "4D2026-1787", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": "artificial intelligence software", "conduct": "Petitioner's counsel filed an AI initial draft containing a nonexistent Fourth DCA case and other false citations supporting certiorari jurisdiction.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2839/JMOR_Properties_LLC_v._Artist_Alley_Townhomes_LLC_et_al._USA_12_August_2026.pdf", "state": "FL", "summary": "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.", "text_sha256": "8ae7ec98c7005eaeae7e4a16003f0b4125a0c85f9a0b3c71a4b8bfbd36a4b73f", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "jmor-properties-v-artist-alley", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp-2026-jmor-properties-v-artist-alley", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp-2026-jmor-properties-v-artist-alley" }, { "ai_passage": "The court finds, based upon its own careful review and Morro's admission, (doc. 34 at 1–2), that the purported citations, quotations, and representations of law in the filings at issue were fabricated. Accordingly, by citing nonexistent cases and attributing nonexistent quotations and propositions of law to actual authorities, Morro made false statements of law. Morro admits that his nonlawyer client drafted the filings at issue and that Morro submitted the filings to the court without ensuring that the assertions within were legally correct. Transcript of 8/6/2026 Show Cause Hearing at 5–10. This is no different than submitting AI-generated work product to the court without thoroughly checking it. Morro signed the filings, and he is responsible for them. ... Morro presented to the court numerous citations, purported quotations, and representations that either do not exist or are unsupported by the cited law. ... Accordingly, the court will not, in this instance, refer this matter to the Alabama State Bar, order a monetary fine, disqualify Attorney Morro from this case, or suspend him from practice in the Northern District of Alabama, though he is WARNED that each of these options is on the table should he commit a similar infraction in the future. ... The court PUBLICLY REPRIMANDS Attorney Scott Thomas Morro.", "ai_tool_named": null, "archive_url": null, "case_name": "Chapman v. City of Priceville", "citation": "2026 WL 2350902", "cited_authorities": [ "Fed. R. Civ. P. 11", "Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251 (11th Cir. 2003)", "Miller v. Regions Bank, 2026 WL 1430381 (N.D. Ala. May 21, 2026)", "Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025)" ], "court": "United States District Court for the Northern District of Alabama", "court_code": "alnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-12", "decision_id": "alnd-2026-chapman-v-city-of-priceville", "disposition": "The court publicly reprimanded attorney Scott Morro and ordered notice to opposing counsel and presiding judges in pending cases.", "docket_number": "5:26-cv-84-HDM", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel filed nonexistent cases and false quotations/propositions drafted by his client without reading and verifying the cited authorities.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2836/Chapman_v._City_of_Priceville_USA_12_August_2026.pdf", "state": "AL", "summary": "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.", "text_sha256": "e55eeecb5e6d7ad41969d6e6cd8c14c184753b0f6594fdc5ba6ab65c35c3a7ec", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "chapman-v-city-of-priceville", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/alnd-2026-chapman-v-city-of-priceville", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alnd-2026-chapman-v-city-of-priceville" }, { "ai_passage": "Prior to addressing the merits of the allegations against Skibitsky, plaintiff is admonished for misrepresenting the law. The statute cited by plaintiff in Paragraph 43 has nothing to do with the alleged conduct by Skibitsky. Rather, the statute referenced requires a person to file a formal written notice of their intent to sue a state governmental unit for personal injury or property damage within six months of the incident. 42 PA. CONS. STAT. § 5522(a). It is improper to misstate the law in this manner. See FED. R. CIV. P. 11 (b). Therefore, plaintiff's future filings in this court will require an affidavit regarding Al usage. ... Courtney's objections also argue about the non-applicability of Younger abstention, the Rooker-Feldman doctrine, and quasi-judicial immunity. However, the R&R issued by Chief Magistrate Judge Bloom in this case did not include a discussion about any of these areas of the law. The only conclusion that may be reached is that the generative Al service used by the plaintiff steered her in the wrong direction. The result is a misleading document and a waste of judicial resources filtering out “ghost arguments” to reach matters on their merits. ... Given the seriousness of the misrepresentations in her complaint and in her objections to the R&R, the plaintiff is forewarned that future unchecked Al usage will result in sanctions, up to and including striking pleadings and dismissing claims with prejudice.", "ai_tool_named": null, "archive_url": null, "case_name": "Voyton v. Voyton", "citation": "2026 WL 2322660", "cited_authorities": [ "42 Pa. Cons. Stat. § 5522(a)", "Fed. R. Civ. P. 11", "Younger abstention", "Rooker-Feldman doctrine", "Jones v. Kankakee County Sheriff's Department, 164 F.4th 967 (7th Cir. 2026)" ], "court": "United States District Court for the Middle District of Pennsylvania", "court_code": "pamd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-11", "decision_id": "pamd-2026-voyton-v-voyton", "disposition": "The court adopted the report and recommendation, dismissed with leave to amend, and required future AI-use affidavits.", "docket_number": "3:26-cv-27", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff misrepresented a Pennsylvania notice statute and filed AI-steered ghost arguments about doctrines not discussed in the R&R.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2844/Voyton_v._Voyton_USA_11_AUgust_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "fb560027581915a5bd9774d3eefcc31903cc4df291206c6fbedd19d1f1b2ca53", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "voyton-v-voyton", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pamd-2026-voyton-v-voyton", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pamd-2026-voyton-v-voyton" }, { "ai_passage": "72 Barrow has moved for sanctions against Mr. Eyong under Rules 1-341 and 8-504, arguing that his citation to fictional legal authority in his opening brief and his reply brief; the lack of legal authority for his positions; and his failure to prepare a record extract justify an award of reasonable attorneys’ fees and costs. On remand, the circuit court may entertain a motion under Rule 1-341(a) concerning fees incurred by 72 Barrow in defending this appeal. ... JUDGMENT OF THE CIRCUIT COURT FOR MONTGOMERY COUNTY AFFIRMED. COSTS TO BE PAID BY APPELLANT. ... This Court previously entered an order striking large portions of Mr. Eyong's opening brief and his reply brief because it contained fictitious citations to legal authority and inaccurate summaries of the holdings of other cases. We limit our consideration of the issues to the portions of the briefs that have not been stricken.", "ai_tool_named": null, "archive_url": null, "case_name": "Eyong v. 72 Barrow St. Realty Corp.", "citation": "2026 WL 2321382", "cited_authorities": [ "Md. Rule 1-341", "Md. Rule 8-504", "Litty v. Becker, 104 Md. App. 370 (1995)" ], "court": "Appellate Court of Maryland", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-11", "decision_id": "mdapp-2026-eyong-v-72-barrow-st-realty", "disposition": "The court affirmed judgment for the landlord, taxed costs to appellant, and noted a remand sanctions motion could be considered.", "docket_number": "1910, Sept. Term, 2025", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant’s opening and reply briefs contained fictitious legal citations and inaccurate summaries of case holdings.", "currency": null, "monetary_penalty": null, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2896/Eyong_v_72_Barrow_St_Realty_Corp_USA_11_August_2026.pdf", "state": "MD", "summary": "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.", "text_sha256": "3b4f630cf1aaafc13ac36b0ff463b9a3abb1b0d651e4884e64ca68731b537192", "topics": [ "fabricated-citations", "pro-se-ai-use", "competence-fees" ], "tracker_slug": "eyong-v-72-barrow-st-realty-corp", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdapp-2026-eyong-v-72-barrow-st-realty", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdapp-2026-eyong-v-72-barrow-st-realty" }, { "ai_passage": "Since then, Plaintiff has filed numerous replies without leave of Court, repetitive notices and motions, and at least two motions relying on fabricated cases. ... On July 17, 2026, the undersigned ordered Plaintiff to show cause why he should not be sanctioned under Federal Rule of Civil Procedure 11(b) for citing nonexistent case law in his motions. (Doc. 131). Plaintiff apologized to the Court for relying on artificial intelligence to assist him in conducting legal research and writing pleadings. (Doc. 132). Plaintiff assured the Court that he would never again submit a filing containing fabricated cases. ... Most concerning to the Court is Plaintiff’s reliance on artificial intelligence for legal research and writing, which facilitates rapid filing of numerous documents, many containing fabricated caselaw and misrepresentation of federal rules, within just a few hours. ... IT IS HEREBY ORDERED that the Clerk of Court is DIRECTED to accept no further pleadings or motions from Plaintiff without prior approval from the Court or pursuant to a Court Order.", "ai_tool_named": null, "archive_url": null, "case_name": "Nesbitt v. Trans Union, LLC", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Bass v. General Motors Corp., 150 F.3d 842 (8th Cir. 1998)", "Vallejo v. Amgen, Inc., 903 F.3d 733 (8th Cir. 2018)" ], "court": "United States District Court for the Western District of Arkansas", "court_code": "arwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-11", "decision_id": "arwd-2026-nesbitt-v-trans-union", "disposition": "The court imposed filing restrictions on Nesbitt and denied defendants' request for a Rule 16 conference.", "docket_number": "5:26-CV-05085-DCF", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff relied on AI and filed at least two motions with fabricated cases plus many improper filings misrepresenting rules.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2840/Nesbitt_v._Transunion_USA_11_AUgust_2026.pdf", "state": "AR", "summary": "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.", "text_sha256": "cf25b688b7186f5ed8cb5e33fa3aa60601f80c75e29b83fd762d8defc3bf0161", "topics": [ "fabricated-citations", "pro-se-ai-use", "competence-fees" ], "tracker_slug": "nesbitt-v-trans-union-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/arwd-2026-nesbitt-v-trans-union", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arwd-2026-nesbitt-v-trans-union" }, { "ai_passage": "Moreover, many of the cases cited by Respondent in support of his proposition neither expressly state nor even suggest the statements for which he invokes them. Respondent cites Kuroda v. SPJS Holdings, LLC for the proposition that (1) the proper procedural retort to a confusing claim is a Rule 12(e) motion for a more definite statement, (2) that Delaware courts routinely reject “objections as to style” in pleadings, (3) “[e]ven if the pleading is imperfect, dismissal is not warranted where the defendant is on notice of the claim,” and (4) that Delaware courts evaluate “based on their substance, not the heading under which they appear.” 2009 WL 4345724 (Del. Ch. Dec. 1, 2009). Unfortunately for Respondent, Kuroda never discusses Rule 12(e) nor stands for any of these principles. Respondent even purports to cite Kuroda on two occasions in his post-trial briefing, yet the cited words never appear in the Kuroda decision. Respondent’s invocation of Koninklijke v. Philips Electronics N.V. fares no better. ... Inclusion of fictitious quotations from cases constitutes one of the hallmarks of Artificial Intelligence usage. ... Abuse of AI in litigation filings comprises an “abuse of the adversary system” and is sanctionable conduct. ... Respondent misrepresented law to the court, knowing it was material to the present issues, and failed to correct his statement. ... This concert of action supports my finding that Respondent conducted this litigation with subjective bad faith. As a result, I shift fees and costs to the Petitioners.", "ai_tool_named": null, "archive_url": null, "case_name": "Palumbo v. Palumbo", "citation": null, "cited_authorities": [ "Kuroda v. SPJS Holdings, LLC, 2009 WL 4345724 (Del. Ch. Dec. 1, 2009)", "Koninklijke v. Philips Electronics N.V., 2009 WL 4345724 (Del. Ch. Dec. 1, 2009)", "An v. Archblock, 2025 WL 1024661 (Del. Ch. Apr. 4, 2025)", "Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)", "Shawe v. Elting, 157 A.3d 142 (Del. 2017)", "Johnston v. Arbitrium (Cayman Islands) Handels AG, 720 A.2d 542 (Del. 1998)" ], "court": "Court of Chancery of the State of Delaware", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-10", "decision_id": "delch-2026-palumbo-v-palumbo", "disposition": "The master recommended trustee removal, denial of respondent's accounting petition, and fee shifting under the bad-faith exception.", "docket_number": "2024-0661-DH", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented respondent cited Kuroda and Koninklijke for unsupported propositions and fictitious quotations in post-trial briefing.", "currency": null, "monetary_penalty": null, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2832/Stephen_J._Palumbo_et_al._v._Gregory_M._Palumbo_USA_10_August_2026.pdf", "state": "DE", "summary": "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.", "text_sha256": "930a755ec28bc4223cd88c843d5df429fc4703e8c21409f07baf3a90ffa921cc", "topics": [ "fabricated-citations", "pro-se-ai-use", "competence-fees" ], "tracker_slug": "palumbo-v-palumbo", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/delch-2026-palumbo-v-palumbo", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/delch-2026-palumbo-v-palumbo" }, { "ai_passage": "Stefanie’s opening brief does not include a single citation to the record. Her opening brief also consistently misquotes cases and cites cases for propositions either not mentioned or directly contradicted by the case. And one case she cites appears not to exist. ... On page 27, the brief quotes State ex rel. Dep’t of Econ. Sec. v. Burton, 205 Ariz. 27, 30, ¶ 14 (App. 2003) as saying that an appellate court will find an abuse of discretion if a ruling was “manifestly unreasonable, or exercised on untenable grounds, or for untenable reasons.” But Burton contains none of that language. ... On page 48, the brief cites Cruz v. Superior Court (Ramirez), 172 Ariz. 462, 464 (App. 1992). We cannot locate a case with this name in the Arizona appellate courts. ... These citation errors are consistent with the misuse of generative AI. ... Dismissal of Stefanie’s appeal is warranted under ARCAP 25 because she continued to violate ARCAP 13 despite receiving repeated warnings about its requirements and of the consequences for failing to comply.", "ai_tool_named": null, "archive_url": null, "case_name": "WRI Summit REIT LP v. Kuerschner", "citation": null, "cited_authorities": [ "State ex rel. Department of Economic Security v. Burton, 205 Ariz. 27 (App. 2003)", "Bennett v. Baxter Group, Inc., 223 Ariz. 414 (App. 2010)", "Brown v. U.S. Fidelity & Guaranty Co., 194 Ariz. 85 (App. 1998)", "Cruz v. Superior Court (Ramirez), 172 Ariz. 462 (App. 1992)", "Takieh v. O'Meara, 252 Ariz. 51 (App. 2021)", "ARCAP 13", "ARCAP 25", "Matter of Estate of Acciavatti, 2026 WL 2041963 (Ariz. App. July 15, 2026)" ], "court": "Arizona Court of Appeals, Division One", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-10", "decision_id": "azctapp-2026-wri-summit-reit-v-kuerschner", "disposition": "The court dismissed the appeal under ARCAP 25 and awarded appellees reasonable appellate fees and taxable costs.", "docket_number": "1 CA-CV 25-0854", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant filed briefs with false quotations, unsupported propositions, and an unlocatable Arizona case despite prior warnings.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2835/Summit_Reit_USA_10_August_2026.pdf", "state": "AZ", "summary": "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.", "text_sha256": "e9948cde362c2a1864b319d1d8c7be32de3ae42586fe8f77b24b52c011df78f1", "topics": [ "fabricated-citations", "pro-se-ai-use", "competence-fees" ], "tracker_slug": "wri-summit-reit-lp-v-kuerschner", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azctapp-2026-wri-summit-reit-v-kuerschner", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azctapp-2026-wri-summit-reit-v-kuerschner" }, { "ai_passage": "Ms. Stephens filed the Declaration on August 3, 2026, and declared, under penalty of perjury, that she had used a generative artificial intelligence (“GenAI”) tool known as ChatGPT. She confirms that she utilized ChatGPT “for assistance with research, organization, drafting, editing, and formatting.” Her candor is appreciated, but necessitates a caution. ... Ms. Stephens has acknowledged using ChatGPT, a GenAI tool that is widely known for its potential to produce inaccurate or fabricated information, commonly referred to as “AI hallucinations.” Although the use of GenAI is not inherently improper, it presents a risk that filings may contain unsupported or inaccurate legal authority if not carefully verified. In her reply memorandum, supporting her motion to dismiss for insufficient service, Ms. Stephens includes a mischaracterized legal assertion relying on a case that was improperly cited. Briefing has not yet crossed the threshold to warrant sanctions, but the risks of AI hallucinations in future filings concern the court. Accordingly, this order serves as a caution that sanctions under Rule 11 of the Federal Rules of Civil Procedure may be imposed if the use of GenAI results in violations of the Federal Rules of Civil Procedure.", "ai_tool_named": "ChatGPT", "archive_url": "https://web.archive.org/web/20260907211204/https://websitedc.s3.amazonaws.com/documents/Hack_v._Preston_et_al_USA_7_August_2026.pdf", "case_name": "Hack v. Preston", "citation": null, "cited_authorities": [ "Picon-Diaz v. Bondi, No. 25-9530, 2026 WL 412348 (10th Cir. Feb. 13, 2026)", "Moore v. City of Del City, No. 25-6002, 2025 WL 3471341 (10th Cir. Dec. 3, 2025)", "Hukill v. Oklahoma Native Am. Domestic Violence Coal.", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the District of Utah", "court_code": "utd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-07", "decision_id": "utd-2026-hack-v-preston", "disposition": "The court required future assistance declarations and cautioned the self-represented defendant about Rule 11 sanctions.", "docket_number": "4:25-cv-00096-DN", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": "ChatGPT", "conduct": "Self-represented defendant used ChatGPT and filed a reply with an improperly cited and mischaracterized Tenth Circuit case.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2845/Hack_v._Preston_et_al_USA_7_August_2026.pdf", "state": "UT", "summary": "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.", "text_sha256": "cf940a0a220742822fa7132c824f9d09e1187647e044cfd03e688888076eaf72", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "hack-v-preston", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/utd-2026-hack-v-preston", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/utd-2026-hack-v-preston" }, { "ai_passage": "Movants alternatively seek dismissal of plaintiffs' claims and an award of attorney fees, on the additional ground that plaintiffs' opposition assertedly includes a quotation fabricated by artificial intelligence. (NYSCEF No. 30 at 5-6, 9.) Movants do not identify the basis for this court's authority to impose the requested sanction. Movant's request for sanctions is denied. ... Movants have identified a quotation in plaintiffs' opposition papers that does not appear in the case to which the opposition attributes it. But even if this court were to conclude that the challenged quotation is an AI fabrication, rather than the product of ordinary human error, movants' sanctions request is based on a single quotation erroneously attributed to a single case; and the passage of the opposition in which the quotation appears merely provides additional, supplemental support for an argument that rests on properly cited authority. The court is unpersuaded, in these circumstances, that a § 130-1.1 monetary sanction would be warranted.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907211209/https://websitedc.s3.amazonaws.com/documents/Brown_v_Real_Estate_Capital_of_Am._LLC_USA_7_August_2026.pdf", "case_name": "Brown v. Real Estate Capital of America, LLC", "citation": "2026 N.Y. Slip Op. 51211(U); 2026 WL 2291696", "cited_authorities": [ "22 NYCRR 130-1.1", "Matter of Julien v. Arthur, 2026 NY Slip Op 03308", "Tewari v. Tsoutsouras, 75 NY2d 1 (1989)", "Napoli v. Bern, 171 AD3d 489 (1st Dept 2019)" ], "court": "Supreme Court of New York, New York County", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-07", "decision_id": "nysupct-2026-brown-v-real-estate-capital-of-america", "disposition": "The court dismissed one claim against two defendants and denied a reply-requested sanctions award over an alleged AI-fabricated quotation.", "docket_number": "Index No. 165361/2025", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiffs’ opposition attributed a quotation to a cited case that the court says did not contain it.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2841/Brown_v_Real_Estate_Capital_of_Am._LLC_USA_7_August_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "d3d1ae0e8d392d2980e29557fab3b22f519b30100ce0c7aeb750e9742edc3790", "topics": [ "fabricated-citations" ], "tracker_slug": "brown-v-real-estate-capital-of-america-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-brown-v-real-estate-capital-of-america", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-brown-v-real-estate-capital-of-america" }, { "ai_passage": "On June 3, 2026, the Court directed counsel for the Plaintiff to show cause in writing as to why she should not be sanctioned for failure to comply with the Court’s Standing Order Regarding the Use of Artificial Intelligence. [Doc. 98 at 15]. The Court specifically directed counsel for the Plaintiff to explain both the origin of the fabricated quotations in briefing she filed with the Court and her repeated failure to provide timely certifications that complied with the Court’s Standing Order. ... Counsel represented that she “does not use AI to conduct legal research,” and that “[t]o ensure the accuracy of citations . . . [she] runs briefs through LexisNexis brief analysis” and fixes any error that appears “alarming.” ... Moreover, counsel has not explained the origin of the fabricated quotations other than to accept responsibility for them and assert that they were not produced by an artificial intelligence program. How such fabricated quotations could have appeared in the Plaintiff’s filings at all therefore remains a mystery. Finally, while counsel asserts that the artificial intelligence program embedded in her practice cannot hallucinate, she has provided no corroboration for that assertion, nor has she even provided the name of the artificial intelligence program that she uses. As a result, the Court finds that counsel’s response has fallen well short of the Court’s expectations. Nevertheless, because counsel has accepted responsibility for the errors in the Plaintiff’s filings, the Court will discharge the Show Cause Order. Counsel for the Plaintiff is cautioned, however, that any similar shortcomings in future filings will result in sanctions.", "ai_tool_named": null, "archive_url": null, "case_name": "Wayne K. Smith, Sr. v. Polk County", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Standing Order Regarding the Use of Artificial Intelligence" ], "court": "United States District Court for the Western District of North Carolina", "court_code": "ncwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-07", "decision_id": "ncwd-2026-smith-v-polk-county", "disposition": "The court discharged an AI-use show-cause order without sanctions but cautioned plaintiff's counsel about future filings.", "docket_number": "1:24-cv-00037-MR-WCM", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel filed briefing with fabricated quotations and did not submit timely AI-use certifications required by the court’s standing order.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2834/Wayne_Smith_v._Polk_County_USA_7_August_2026.pdf", "state": "NC", "summary": "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.", "text_sha256": "b1fef82f51373434f75c85769f9bb9d250733f79c6f9f9e2ed7acd5c750c6ece", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "wayne-k-smith-sr-v-polk-county", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ncwd-2026-smith-v-polk-county", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ncwd-2026-smith-v-polk-county" }, { "ai_passage": "In addition to this false quotation, a review of other legal citations in defendant's filings uncovered several additional inaccuracies and questionable string citations that may be attributable to use of generative artificial intelligence (“AI”) tools or large language models (“LLMs”). On page 3 of defendant's Motion to Recuse, he writes: “The appearance of bias or improper ex parte communications is sufficient to require recusal, even absent a showing of actual bias. Commonwealth v. Eddington, 71 Mass. App. Ct. 138, 144-145 (2008); Commonwealth v. Gogan, 389 Mass. 255, 259 (1983); Commonwealth v. LeBlanc, 475 Mass. 820, 822-823 (2016).” While Eddington and Gogan address the issue of recusal, both affirm that recusal was not required under the applicable standard and circumstances. However, LeBlanc is entirely irrelevant. LeBlanc concerns whether leaving the scene of property damage requires proof that the accident occurred on a public way. It does not mention recusal at all. ... The presence of fabricated quotations and inaccurate citations strongly suggests that defendant used unverified or unreliable sources, such as AI tools or LLMs (like ChatGPT, Claude, Gemini, or Copilot) when drafting his filings. While this does not bear directly on the outcome of this S-case, the court documents this issue on the record to serve as a warning to defendant and other litigants (and an alert to judicial officers in related proceedings) about the serious risks of AI-generated “hallucinations” and false citations when AI tools or LLMs are used without adequate oversight.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907211216/https://websitedc.s3.amazonaws.com/documents/Machinsky_USA_7_August_2026.pdf", "case_name": "In the matter of Machinsky", "citation": "2026 WL 2295072", "cited_authorities": [ "Commonwealth v. Eddington, 71 Mass. App. Ct. 138 (2008)", "Commonwealth v. Gogan, 389 Mass. 255 (1983)", "Commonwealth v. LeBlanc, 475 Mass. 820 (2016)", "Mass. R. Civ. P. 70", "Peterson v. Hopson, 306 Mass. 597 (1940)", "King v. Driscoll, 424 Mass. 1 (1996)" ], "court": "Massachusetts Land Court, Plymouth District", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-07", "decision_id": "masslandct-2026-in-re-machinsky", "disposition": "The court denied the self-represented defendant's motion to dismiss and warned about fabricated quotations and inaccurate citations.", "docket_number": "26 SBQ 09293 04 - 001 (LER)", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented defendant filed a false statutory quotation and inaccurate or irrelevant case citations in motion papers.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2838/Machinsky_USA_7_August_2026.pdf", "state": "MA", "summary": "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.", "text_sha256": "5bae2e806262fd450665e4fbe755796f76364aae7dab77c8234101c6c08983f2", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "in-the-matter-of-machinsky", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/masslandct-2026-in-re-machinsky", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/masslandct-2026-in-re-machinsky" }, { "ai_passage": "Smith also cites United States v. Jones, 965 F.3d 149 (2d Cir. 2020) as a case that “reversed a sentence,” Smith’s Br. at 2, but Jones both did not involve challenges to the sentence and affirmed the defendant’s conviction, 965 F.3d at 153. In his reply brief, Jones cites “United States v. Johnson, 605 F.3d 728, 731 (7th Cir. 2010),” for the proposition that prosecutorial exaggeration is improper. Smith’s Reply Br. at 15. But Johnson does not appear to exist. Smith also references United States v. Abbas, 560 F.3d 660 (7th Cir. 2009), for the proposition that a miscalculated guidelines range “infects the entire sentencing process.” Smith’s Reply Br. at 15. Abbas is a real case and discusses sentencing, but it lacks the quote that Smith attributes to the decision. ... One concern remains: potential sanctions against Smith for submitting false citations and quotations. By the Court’s count, Smith falsified entire cases or quotations nearly a dozen times. Falsifying information “undermines the most basic foundations of our judicial system” and “imposes unjust burdens on the opposing party, the judiciary, and honest litigants.” ... So the Court issues a rule for Smith to show cause why he should not be subject to monetary sanctions for the fabricated legal citations. Smith’s response is due on or before September 4, 2026.", "ai_tool_named": null, "archive_url": null, "case_name": "United States v. Smith", "citation": null, "cited_authorities": [ "United States v. Aviles-Colon, 536 F.3d 1 (1st Cir. 2008)", "United States v. Jones, 965 F.3d 149 (2d Cir. 2020)", "United States v. Johnson, 605 F.3d 728 (7th Cir. 2010)", "United States v. Abbas, 560 F.3d 660 (7th Cir. 2009)", "Secrease v. Western & Southern Life Insurance Co., 800 F.3d 397 (7th Cir. 2015)", "Fed. R. Civ. P. 11", "Alexander v. United States, 121 F.3d 312 (7th Cir. 1997)", "Smith v. Gilmore, 111 F.3d 55 (7th Cir. 1997)" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-07", "decision_id": "ilnd-2026-united-states-v-smith", "disposition": "The court denied Smith's § 2255 motion and ordered him to show cause about monetary sanctions for fabricated citations.", "docket_number": "1:25-cv-05215; 1:21-cr-00703-2", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented § 2255 movant submitted nearly a dozen false citations or quotations, including nonexistent United States v. Johnson.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2833/United_States_of_America_v._Smith_USA_7_August_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "c955205039f0d95c4b69a606af16275229840e03974ccf267085266982dab5c3", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "united-states-v-smith", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-united-states-v-smith", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-united-states-v-smith" }, { "ai_passage": "On July 30, 2026, the Court ordered several of plaintiff's attorneys to show cause why they should not be sanctioned-under either or both of Rule 11 of the Federal Rules of Civil Procedure and the Court's inherent authority-for filing a document at Doc. No. 293 that contained hallucinated quotations and misleading citations. ... Ringger has confirmed the Court's suspicion that a major factor in the deficiencies at Doc. No. 293-plus others that he identified (Doc. No. 328 at 6)-was the failure to check content generated through tools using artificial intelligence. ... The novel danger with artificial intelligence is how much easier a Rule 11 violation becomes when using it. Submitting false legal authority by conventional means requires either willfulness or a failure by multiple professionals involved in the preparation of a document. ... This is where Ringger fell short, with quotations that did not exist and with legal citations that gave the impression that an argument in his favor had support when it did not. This conduct must be swiftly addressed and deterred. For those reasons, Ringger must be sanctioned. ... Attorney Ringger has violated Rule 11 and is hereby publicly reprimanded through this order. Ringger also is assessed a monetary sanction of $1,500.00, payable to the Clerk of the Court within 30 days after entry of this order.", "ai_tool_named": null, "archive_url": null, "case_name": "In re BFI Waste Systems of Tennessee", "citation": "2026 U.S. Dist. LEXIS 175482; 2026 LX 497566", "cited_authorities": [ "Fed. R. Civ. P. 11", "Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)", "Safe Choice, LLC v. City of Cleveland, 2025 WL 2958211 (N.D. Ohio Oct. 17, 2025)", "Rivera v. Triad Props. Corp., 829 F. Supp. 3d 983 (N.D. Ala. 2026)", "Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341 (E.D.N.Y. 2025)" ], "court": "United States District Court for the Middle District of Tennessee", "court_code": "tnmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-06", "decision_id": "tnmd-2026-in-re-bfi-waste-systems", "disposition": "The court publicly reprimanded attorney Louis W. Ringger III and imposed a $1,500 Rule 11 monetary sanction.", "docket_number": "3:22-cv-00605", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Attorney filed a document containing hallucinated quotations and misleading citations after failing to check AI-generated content.", "currency": "USD", "monetary_penalty": 1500, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2765/In_re_BFI_Waste_Sys._of_Tenn._2026_U.S._Dist._LEXIS_175482.Pdf", "state": "TN", "summary": "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.", "text_sha256": "f7d22517b8415ae6235705e5580b675f5484635ac861747a262292368515749b", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "in-re-bfi-waste-systems", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/tnmd-2026-in-re-bfi-waste-systems", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tnmd-2026-in-re-bfi-waste-systems" }, { "ai_passage": "The Court first addresses GCTRA’s reliance on Shimola. First, “State ex rel. Shimola v. City of Cleveland” is not found at “70 Ohio St.3d 40” as cited by GCRTA. That citation is to State ex rel. Hopkins v. Indus. Comm’n of Ohio, 70 Ohio St.3d 36, 635 N.E.2d 1257 (Ohio 1994). And that case was a workers’ compensation case that has nothing to do with parties pursing inconsistent remedies. Second, “State ex rel. Shimola v. City of Cleveland” is a real case, which can be found at 70 Ohio St.3d 100, 637 N.E.2d 325 (Ohio 1994). But Shimola involved the entry of default judgment and there was no discussion of whether the plaintiff was pursuing inconsistent remedies. ... This citation bears the hallmarks of a hallucinated case citation. Given GCRTA’s other frivolous arguments in their Opposition, the Court strongly suspects that AI was used to draft the Opposition. This undersigned has issued sanctions in the past for Rule 11 violations related to improper AI use. Safe Choice, LLC v. City of Cleveland, No. 1:24-cv-02033-PAB, 2025 U.S. Dist. LEXIS 214410, at *11–12 (N.D. Ohio Oct. 30, 2025). GCRTA is expressly warned that the undersigned will not hesitate to do so again in this case if further briefing contains frivolous arguments and hallucinated case citations. This remains true even if these were merely human errors made without the use of AI.", "ai_tool_named": null, "archive_url": null, "case_name": "Burgess v. Greater Cleveland Regional Transit Authority", "citation": null, "cited_authorities": [ "State ex rel. Shimola v. City of Cleveland, 70 Ohio St.3d 100 (Ohio 1994)", "State ex rel. Hopkins v. Indus. Comm’n of Ohio, 70 Ohio St.3d 36 (Ohio 1994)", "Safe Choice, LLC v. City of Cleveland, No. 1:24-cv-02033-PAB" ], "court": "United States District Court for the Northern District of Ohio", "court_code": "ohnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-06", "decision_id": "ohnd-2026-burgess-v-greater-cleveland-rta", "disposition": "The court warned GCRTA that future frivolous arguments and hallucinated citations could draw sanctions.", "docket_number": "1:24-cv-01217-PAB", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Defendant cited Shimola at a reporter page for a different case and represented Shimola as supporting a proposition it did not discuss.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2890/Burgess_v._Greater_Cleveland_Regional_Transit_Authority_USA_6_August_2026.pdf", "state": "OH", "summary": "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.", "text_sha256": "a4487c9b0423339f9b1f0e994ef53ebddc8fa81340effd57c9817d042b1d12c6", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "burgess-v-greater-cleveland-regional-transit-authority", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohnd-2026-burgess-v-greater-cleveland-rta", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohnd-2026-burgess-v-greater-cleveland-rta" }, { "ai_passage": "Plaintiff cites one case in her initial brief in support of the Motion for Attorney Fees. Filing No. 27-1 at 2. Plaintiff quotes Peterson v. U.S. Retirement Board, 785 F.2d 245 (8th Cir. 1986) as follows: Agency action found to be arbitrary and capricious or unsupported by substantial evidence is virtually certain not to have been substantially justified under the Act. Only the most extraordinary special circumstances could permit such an action to be found to be substantially justified under the Act. ... However, that case does not exist. The Court found a portion of this particular quotation in a footnote in Jackson v. Bowen, 807 F.2d 127, n. 5 (8th Cir. 1986) that Plaintiff incorrectly cites in her reply brief. ... While this apparent “hallucinated” case does not necessarily misstate the law, Plaintiff's counsel's reliance on it certainly undermines his credibility with this Court. ... A case of a similar name with a different citation, Peterson v. U.S. Railroad Retirement Board, 780 F.2d 1361 (8th Cir. 1985), does not contain the quoted language. 785 F.2d 245 does not exist. Counsel is cautioned that under the ABA Canons of Professional Ethics he has a duty of candor to the Court to not knowingly make false statements of fact or law to the Court and to correct any such false statement. In addition, counsel has an obligation under Fed. R. Civ. P. 11(b)(2) that the legal authority cited in his filings are based on “an inquiry reasonable the circumstances.” Finally, NECivR 7.1(d)(2) specifically admonishes that “parties are required, if using generative artificial intelligence programs, to verify the contents of their filings. Any filing not properly verified may be stricken and/or sanctions may be imposed on the filing party.”", "ai_tool_named": null, "archive_url": null, "case_name": "Kadlaskar v. United States Citizenship and Immigration Services", "citation": "2026 WL 2267773", "cited_authorities": [ "Peterson v. U.S. Retirement Board, 785 F.2d 245 (8th Cir. 1986)", "Jackson v. Bowen, 807 F.2d 127 (8th Cir. 1986)", "Peterson v. U.S. Railroad Retirement Board, 780 F.2d 1361 (8th Cir. 1985)", "Fed. R. Civ. P. 11", "NECivR 7.1(d)(2)" ], "court": "United States District Court for the District of Nebraska", "court_code": "ned", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-06", "decision_id": "ned-2026-kadlaskar-v-uscis", "disposition": "The court awarded EAJA fees and cautioned plaintiff's counsel about a hallucinated Eighth Circuit citation.", "docket_number": "4:25CV3025", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel cited a nonexistent Eighth Circuit Peterson decision and quoted language that appeared elsewhere in a legislative-history footnote.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2779/GIRIJA_KADLASKAR_Plaintiff_v_UNITED_STATES_CITIZENSHIP_AND_IMMIGRATION_SER_USA_Gg2IhwZ.pdf", "state": "NE", "summary": "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.", "text_sha256": "0fa0753eb8b6669339cdd83aa4d24eed6d53f7b7973c60ead70d1147bda5e134", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "kadlaskar-v-united-states-citizenship-and-immigration-services", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ned-2026-kadlaskar-v-uscis", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ned-2026-kadlaskar-v-uscis" }, { "ai_passage": "We conclude Osman’s appeal is not completely frivolous; therefore, we do not sanction under N.D.R.App.P 38 as requested. Nevertheless, while Osman corrected two nonexistent citations, he failed to acknowledge numerous other citations wholly unrelated to the propositions for which they were cited. Under N.D.R.App.P. 28(b)(2) and (7), a party’s brief must provide citations to authorities, and under Rule 28(l), the brief must be accurate and free from irrelevant matters. Under N.D.R.App.P. 13, this court “may take appropriate action against any person failing to perform an act required by rule or court order.” We conclude a sanction is appropriate based on the multiple fictitious or nonexistent citation errors in his opening brief. See City of Dickinson v. Helgeson, 2026 ND 34, ¶¶ 16, 19, 31 N.W.3d 672 (awarding $500 as a sanction for misconduct based on fake or nonexistent legal citations); Stokka v. Stokka, 2026 ND 94, ¶¶ 4-5, 35 N.W.3d 207 (citing Helgeson and imposing costs and attorney’s fees of $1,000, noting the “few legal authorities cited” were “either irrelevant, fictitious, or nonexistent”). We therefore award Ali sanctions in the amount of $1,000.", "ai_tool_named": null, "archive_url": null, "case_name": "Mohamed Ali v. Saeed Osman", "citation": "2026 ND 156", "cited_authorities": [ "N.D.R.App.P. 13", "N.D.R.App.P. 28", "N.D.R.App.P. 38", "City of Dickinson v. Helgeson, 2026 ND 34", "Stokka v. Stokka, 2026 ND 94" ], "court": "Supreme Court of North Dakota", "court_code": "nd", "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-06", "decision_id": "nd-2026-ali-v-osman", "disposition": "The court affirmed and remanded, awarding Ali $1,000 in sanctions for citation errors in Osman's opening brief.", "docket_number": "20260029", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant filed an opening brief with multiple fictitious or nonexistent citations and citations unrelated to the stated propositions.", "currency": "USD", "monetary_penalty": 1000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2774/Ali_v._Osman_USA_August_2026.pdf", "state": "ND", "summary": "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.", "text_sha256": "7428bf20eee90bdc3f169cdfedcdb5d5329e8e32888c1695d488fb36ccb3736c", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "mohamed-ali-v-saeed-osman", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nd-2026-ali-v-osman", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nd-2026-ali-v-osman" }, { "ai_passage": "Plaintiffs cited nonexistent case Henry v. Kroger Co., No. 4:19-cv-00630, 2019 WL 6311295 (E.D. Tex. Nov. 25, 2019), in their Response to Defendant’s Motion for Partial Dismissal. Dkt. 9 at 7. Under Rule 11(b), an attorney certifies that legal citations in papers presented to the Court are correct “to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances.” Plaintiffs’ counsel are “duty-bound to check and certify that all factual contentions and statements of law are warranted and nonfrivolous.” Duncan v. Gridhawk, LLC, No. MO:25-CV-00394-DC, 2025 WL 3515411, at *2 (W.D. Tex. Dec. 6, 2025). The Court held a hearing on July 29, 2026, during which Plaintiffs’ counsel Lino Ochoa represented that he did not prepare or review the response before it was filed. The Court ORDERS Plaintiffs’ other attorney of record, Daniel Miguel Hernandez, to appear and show cause under Rule 11(c)(3) why the conduct described in this Order has not violated Rule 11(b) at 2 p.m. Wednesday, August 19, 2026 in Courtroom 6 on the Sixth Floor of the United States Courthouse, 501 W. 5th Street, Austin, Texas 78701.", "ai_tool_named": null, "archive_url": null, "case_name": "Cain v. Hyatt Corporation", "citation": null, "cited_authorities": [ "Henry v. Kroger Co., No. 4:19-cv-00630, 2019 WL 6311295", "Fed. R. Civ. P. 11", "Duncan v. Gridhawk, LLC, No. MO:25-CV-00394-DC, 2025 WL 3515411 (W.D. Tex. Dec. 6, 2025)" ], "court": "United States District Court for the Western District of Texas", "court_code": "txwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-05", "decision_id": "txwd-2026-cain-v-hyatt", "disposition": "The court ordered plaintiffs' counsel Daniel Miguel Hernandez to appear and show cause under Rule 11.", "docket_number": "1:25-cv-02053-ADA-SH", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiffs’ response cited nonexistent Henry v. Kroger Co. authority in opposing partial dismissal.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2940/Cain_USa_5_August_2026.pdf", "state": "TX", "summary": "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).", "text_sha256": "c36faaf0cf4a987765642c887afd73c2c8ae11c30c5e21d974811563fa197b70", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "cain-v-hyatt-corporation", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txwd-2026-cain-v-hyatt", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txwd-2026-cain-v-hyatt" }, { "ai_passage": "We begin by noting that Becerra’s appellee’s brief cites eight judicial opinions, four of which appear to be hallucinations created by generative artificial intelligence: “Alief Independent School District v. Lozano, 543 S.W.3d 118 (Tex. App.—Houston [14th Dist.] 2018, pet. denied),” cited on page 23 of Becerra’s brief, does not exist. The citation 543 S.W.3d 118 leads to a 2018 opinion from a Missouri court of appeals. ... “Hoffman v. ESD 48, No. 01-14-00676-CV (Tex. App.—Houston [1st Dist.] 2015, pet. denied),” cited on page 22 of Becerra’s brief, does not exist. ... “Neely v. West Orange-Cove Consol. ISD, No. 09-17-00196-CV (Tex. App.—Beaumont 2018, no pet.),” cited on page 21 of Becerra’s brief, does not exist. ... “Cutrer v. Tarrant County College District, 943 F.3d 265 (5th Cir. 2019),” cited on page 21 of Becerra’s brief, appears to be an attempt to cite a Fifth Circuit opinion styled Cutrer v. Tarrant County Local Workforce Development Board, 943 F.3d 265 (5th Cir. 2019). Becerra’s brief states that Cutrer “involved a college student’s expressive conduct and campus restrictions[.]” This is not correct. ... Reliance on fictitious citations and inaccurate representations about the contents of an opposing party’s brief are inconsistent with both of these duties. In light of these hallucinations, we have considered whether to strike Becerra’s brief “and proceed as if [she] had failed to file a brief.” ... However, we will proceed to the merits of this appeal without taking further action on this issue. We nevertheless caution Becerra’s counsel that we will not tolerate similar issues in any future appearances before this court.", "ai_tool_named": null, "archive_url": null, "case_name": "San Antonio Independent School District v. Becerra", "citation": null, "cited_authorities": [ "Alief Independent School District v. Lozano, 543 S.W.3d 118", "Hoffman v. ESD 48, No. 01-14-00676-CV", "Neely v. West Orange-Cove Consol. ISD, No. 09-17-00196-CV", "Cutrer v. Tarrant County Local Workforce Development Board, 943 F.3d 265 (5th Cir. 2019)", "Suday v. Suday, 2026 WL 100418", "AGiza v. Franklin, 2025 WL 2058089", "Tex. R. App. P. 38.9" ], "court": "Texas Court of Appeals, Fourth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-05", "decision_id": "txapp-2026-san-antonio-isd-v-becerra", "disposition": "The court reversed and rendered dismissal while admonishing Becerra's counsel about hallucinated authorities.", "docket_number": "04-25-00724-CV", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Appellee’s counsel cited three nonexistent Texas appellate opinions and misdescribed a real Fifth Circuit Cutrer employment case as school-law authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2781/San_Antonio_Independent_School_District_v._Laura_Becerra_USA_5_August_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "c95b6ca34123fa834a719e88a6be1bd513821eceb92625c584896c6e2ade442d", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "san-antonio-independent-school-district-v-becerra", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txapp-2026-san-antonio-isd-v-becerra", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txapp-2026-san-antonio-isd-v-becerra" }, { "ai_passage": "As a final matter, the undersigned has been unable to locate or verify several of the cases cited by Plaintiff in support of her opposition to Defendant's motion to dismiss. Specifically, Plaintiff's opposition includes citations to at least four nonexistent judicial opinions: LPD New York, LLC v. Adidas Am., Inc., 2020 WL 1501881 (S.D.N.Y. Mar. 30, 2020); Powell v. Monarch Recovery Mgmt., Inc., 2017 WL 102666 (E.D.N.Y. Mar. 23, 2017); Robertson v, Waste Management, Inc., 2019 WL 1238839 (D. Colo. Mar. 18, 2019); and Snyder v. Ply Gem Indus., Inc., 827 F. Supp. 2d 472 (E.D.N.Y. 2011). ... “Although in ‘some circumstances courts will make some allowances for a pro se [p]laintiff's failure to cite to proper legal authority,’ it is ‘no more acceptable for a pro se litigant to submit briefs with fake case citations than it is for a lawyer to do so.’ ” ... Accordingly, the Court directs Plaintiff to refrain from any further use of hallucinated or fabricated case law in submissions before this Court. Plaintiff is further advised that any future filings containing citations to nonexistent cases may result in sanctions, including the striking of such filings from the record, the imposition of filing restrictions, the issuance of monetary sanctions, or the dismissal of this action.", "ai_tool_named": null, "archive_url": null, "case_name": "Calenzo v. Waste Management, Inc.", "citation": "2026 WL 2253803", "cited_authorities": [ "LPD New York, LLC v. Adidas Am., Inc., 2020 WL 1501881", "Powell v. Monarch Recovery Mgmt., Inc., 2017 WL 102666", "Robertson v. Waste Management, Inc., 2019 WL 1238839", "Snyder v. Ply Gem Indus., Inc., 827 F. Supp. 2d 472", "Hodges v. McGough Enters. LLC, 2026 WL 1470246", "Park v. Kim, 91 F.4th 610 (2d Cir. 2024)" ], "court": "United States District Court for the Northern District of New York", "court_code": "nynd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-05", "decision_id": "nynd-2026-calenzo-v-waste-management", "disposition": "The court dismissed one defendant, allowed amendment in part, and warned Calenzo about nonexistent case citations.", "docket_number": "1:24-cv-01499 (AMN/PJE)", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff cited at least four nonexistent judicial opinions in opposition to a motion to dismiss.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2771/MARY-ROSE_F_CALENZO_Plaintiff_v_WASTE_MANAGEMENT_INC_et_al_Defendants_USA_5_Au_vfD7vB4.pdf", "state": "NY", "summary": "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.", "text_sha256": "7f62bc679e45553e4b608b884b9d53260308ffcbb5e4e79f7633367f7432a8c0", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "calenzo-v-waste-management-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nynd-2026-calenzo-v-waste-management", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nynd-2026-calenzo-v-waste-management" }, { "ai_passage": "On June 25, 2026, this Court issued an Order to Show Cause after discovering that Booker III’s briefs were riddled with cases that do not exist, incorrect quotes, and erroneous citations. Specifically, in its Show-Cause Order, the Court identified the following hallucinations: ... BCB Contracting Services, LLC v. United States, 104 B.R. 771, 775 (S.D. Ariz. 2021) [was a] Nonexistent case. Page 771 of Volume 104 of the Bankruptcy Reporter lands in the middle of In re Crouch, a bankruptcy case from West Virginia (104 B.R. 770). ... Mathews v. Dillon, 489 U.S. 567 (1989) [was a] Nonexistent case. Page 567 lands in the middle of a case called Coit Independence Joint Venture v. Federal Sav. and Loan Ins. Corp. (489 U.S. 561). That case explicitly does not discuss due process. The Court could not find any case called “Mathews v. Dillon.” ... In sum, the Court was able to identify at least two inaccurate quotes, four erroneous citations, and six fabricated cases. These hallucinations clearly indicated to the Court the use of generative artificial intelligence (“AI”) in the preparation of these briefs. ... At the hearing, Booker III again apologized to the Court and admitted that he had used several generative AI programs—including Gemini Pro, Perplexity, Cetient Legal AI, and ChatGPT—to prepare his filings. ... For the foregoing reasons, Booker III is ADMONISHED for violating Rule 11 and is WARNED that any future filing containing fabricated authorities, inaccurate quotations, erroneous citations, or other AI-generated hallucinations—or any future failure to conduct a reasonable, human-based verification of authorities before filing—may result in substantially more severe sanctions, including monetary sanctions, the striking of filings, dismissal of claims or appeals, or any other sanction authorized by Rule 11 or the Court’s inherent authority.", "ai_tool_named": "Gemini Pro, Perplexity, Cetient Legal AI, and ChatGPT", "archive_url": null, "case_name": "Ulish Kerry Terrace Booker, III v. U.S. Bank National Association", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Fed. R. Bankr. P. 9011", "BCB Contracting Services, LLC v. United States, 104 B.R. 771", "Mathews v. Dillon, 489 U.S. 567", "Coit Independence Joint Venture v. Federal Sav. and Loan Ins. Corp., 489 U.S. 561", "Mata v. Avianca, Inc.", "Mattox" ], "court": "United States District Court for the District of Connecticut", "court_code": "ctd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-05", "decision_id": "ctd-2026-booker-v-us-bank", "disposition": "The court admonished Booker for violating Rule 11, warned him, and affirmed the bankruptcy court orders on appeal.", "docket_number": "25-CV-1205 (VDO)", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": "Gemini Pro; Perplexity; Cetient Legal AI; ChatGPT", "conduct": "Self-represented appellant filed briefs with at least two inaccurate quotations, four erroneous citations, and six fabricated cases generated through AI tools.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2784/Booker_USA_5_August_2026.pdf", "state": "CT", "summary": "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.", "text_sha256": "0e30c6e03f9ad75567cc6bc767e668ebb2bdeb54e2f637844d435ecbece41402", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "in-re-booker-d-conn", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ctd-2026-booker-v-us-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ctd-2026-booker-v-us-bank" }, { "ai_passage": "Plaintiffs cite Pointe West Center, LLC v. It’s Alive, Inc., 796 S.W.2d 830, 838–39 (Tex. App.—Houston [1st Dist.] 1990, writ denied), and Motten v. Chase Home Financial, 821 F. Supp. 2d 988, 1008 (S.D. Tex. 2011), for the proposition that a cause of action for wrongful initiation of foreclosure proceedings exists. Pointe West is a fabricated cite, and Motten states that “courts in Texas do not recognize an action for attempted wrongful foreclosure.” 831 F. Supp. 2d at 1007 (quotation omitted). Plaintiffs’ counsel is reminded that every submission to the court represents that “the claims, defenses, and other legal contentions” within “are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law.” Fed. R. Civ. P. 11(b)(2). “[S]ubmitting a brief riddled with fabricated quotations and assertions is . . . an abuse [of the judicial process].” Fletcher v. Experian Info. Sols., Inc., 168 F.4th 231, 234 (5th Cir. 2026). ... Plaintiffs argue that “the prior material breach doctrine does not bar a plaintiff’s contract claim where the defendant’s own breach caused or contributed to the plaintiff’s non-performance.” Dkt. 34 at 13. In support, Plaintiffs cite Restatement (Second) of Contracts § 237 cmt. d (1981), and Tractebel Energy Marketing, Inc. v. E.I. Du Pont De Nemours & Co., 118 F. Supp. 2d 737, 744 (S.D. Tex. 2000). The use of these citations is either the product of incredibly shoddy legal work or an outright misrepresentation to the court. The Tractebel case is fabricated, and the referenced Restatement provision says nothing of the sort.", "ai_tool_named": null, "archive_url": null, "case_name": "Cristancho v. SWBC Mortgage Corporation", "citation": null, "cited_authorities": [ "Pointe West Center, LLC v. It’s Alive, Inc., 796 S.W.2d 830", "Motten v. Chase Home Financial, 821 F. Supp. 2d 988", "Fed. R. Civ. P. 11", "Fletcher v. Experian Info. Sols., Inc., 168 F.4th 231 (5th Cir. 2026)", "Restatement (Second) of Contracts § 237", "Tractebel Energy Marketing, Inc. v. E.I. Du Pont De Nemours & Co., 118 F. Supp. 2d 737" ], "court": "United States District Court for the Southern District of Texas", "court_code": "txsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-04", "decision_id": "txsd-2026-cristancho-v-swbc-mortgage", "disposition": "The magistrate judge recommended granting defendants' summary-judgment motion and admonished plaintiffs' counsel over fabricated authorities.", "docket_number": "3:24-cv-00110", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiffs’ counsel cited fabricated Pointe West and Tractebel cases and invoked a Restatement provision for a proposition it did not contain.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2787/Cristancho_et_al_v._SWBC_Mortgage_Corporation_et_al_USA_4_August_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "9e13e4a199d5dcc628e82a01b641dbf408431087ab924af898824afaceeed9d6", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "cristancho-v-swbc-mortgage-corporation", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txsd-2026-cristancho-v-swbc-mortgage", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txsd-2026-cristancho-v-swbc-mortgage" }, { "ai_passage": "Therefore, we dismiss Father’s appeal for failure to provide this Court with the required record on appeal necessary to resolve the questions raised in his appeal. ... There are numerous other briefing deficiencies with Father’s appellate brief that would also independently support dismissal of Father’s appeal. ... Father’s brief includes two citations to cases that do not exist in the reporter he cites, and he additionally cites one case for a legal proposition that cannot be reasonably inferred from that case. Citing non-existent case law or misrepresenting the holdings of an existing case is “a flagrant violation of the duties of candor Appellant owes to this Court,” which warrants dismissal of an appeal. See Kruse v. Karlen, 692 S.W.3d 43, 52 (Mo. App. E.D. 2024).", "ai_tool_named": null, "archive_url": null, "case_name": "Whitehead v. Moore", "citation": null, "cited_authorities": [ "Kruse v. Karlen, 692 S.W.3d 43 (Mo. App. E.D. 2024)", "Missouri Rule 84.04" ], "court": "Missouri Court of Appeals, Western District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-04", "decision_id": "moctapp-2026-whitehead-v-moore", "disposition": "The court dismissed the self-represented father's appeal for failure to provide a required record.", "docket_number": "WD88216", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant’s brief cited two cases that did not exist in the cited reporters and misrepresented another case’s holding.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2785/Rachel_Whitehead_vs._Zackery_Todd_Moore_Jr._USA_4_August_2026.pdf", "state": "MO", "summary": "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.", "text_sha256": "345a135d6bb3449b8a86371d5d6fd6e8c689a01e84a0d01b652d59f9366edf50", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "whitehead-v-moore", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/moctapp-2026-whitehead-v-moore", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/moctapp-2026-whitehead-v-moore" }, { "ai_passage": "This Order addresses the Court’s previously issued Order to Show Cause concerning defense counsel Hilary Miller’s use of unverified generative artificial intelligence (“AI”) in this matter. Having considered counsel’s written response to the Order to Show Cause and his representations made at the show-cause hearing, the Court concludes that sanctions are warranted and imposes the sanctions set forth below. ... Upon review of the Motions, the Court discovered numerous case quotes that do not exist, erroneous citations, and misrepresentations of the law. ... On June 25, 2026, the Court held a show-cause hearing, at which Attorney Miller reiterated those representations and further explained the circumstances under which the AI-generated material was incorporated into his briefing. Attorney Miller clarified that this matter is the first and only matter in which he utilized artificial intelligence. As for his writing process, Attorney Miller explained that he first wrote the brief himself conventionally. Then, in an attempt to improve it, he used a tool called Open Law, which he paid for, for suggestions on arguments and additional cases. He also used Claude and Chat GPT for additional suggestions. Concerned about the risk of AI hallucinations, Attorney Miller then cross-checked the citations in the brief to determine whether they existed and were cited correctly ... Balancing these considerations, the Court concludes that a monetary sanction of $3,500, together with a referral of this matter to the Grievance Committee pursuant to Local Rule 83(c)(2), is appropriate. ... For the foregoing reasons, the Court concludes that Attorney Miller’s submission of unverified AI-generated legal authorities warrants sanctions under Rule 11 and, accordingly, imposes a $3,500 monetary sanction and refers this matter to the Grievance Committee pursuant to Local Rule 83(c)(2).", "ai_tool_named": "Open Law; Claude; Chat GPT", "archive_url": null, "case_name": "Barteca Holdings LLC v. Tacobarn Newtown LLC", "citation": null, "cited_authorities": [ "Ashcroft v. Iqbal, 556 U.S. 662 (2009)", "Streetwise Maps, Inc. v. VanDam, Inc., 159 F.3d 739 (2d Cir. 1998)", "Landscape Forms, Inc. v. Columbia Cascade Co., 113 F.3d 373 (2d Cir. 1997)", "Yurman Design, Inc. v. PAJ, Inc., 262 F.3d 101 (2d Cir. 2001)", "Chambers v. Time Warner, Inc., 282 F.3d 147 (2d Cir. 2002)", "Friedl v. City of New York, 210 F.3d 79 (2d Cir. 2000)", "Fonte v. Board of Managers of Continental Towers Condominium, 848 F.2d 24 (2d Cir. 1988)", "Cortec Industries, Inc. v. Sum Holding L.P., 949 F.2d 42 (2d Cir. 1991)", "Fed. R. Civ. P. 11", "D. Conn. L. Civ. R. 83(c)(2)" ], "court": "United States District Court for the District of Connecticut", "court_code": "ctd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-04", "decision_id": "ctd-2026-barteca-v-tacobarn", "disposition": "The court imposed a $3,500 Rule 11 sanction, referred counsel to the Grievance Committee, and required corrected briefing.", "docket_number": "26-CV-250 (VDO)", "document_type": "order", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": "Open Law; Claude; Chat GPT", "conduct": "Defense counsel used Open Law, Claude, and ChatGPT and filed motions with nonexistent case quotes, erroneous citations, and misstatements of law.", "currency": "USD", "monetary_penalty": 3500, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2763/Barteca_v._Tacobarn_USA_4_August_2026.pdf", "state": "CT", "summary": "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.", "text_sha256": "f8a2fc4239dccf8fdd27913d6d756ad6a9ce91df9a5fa05c06f1eb1671ba0235", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "barteca-v-tacobarn", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ctd-2026-barteca-v-tacobarn", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ctd-2026-barteca-v-tacobarn" }, { "ai_passage": "They are the latest installment in a sustained series of filings marked by misstatements of law, mischaracterizations of the record, fabricated quotations, and demands untethered to any rule of procedure. ... Although Plaintiffs certified that they verified each citation contained in those objections (Doc. 76 at 26), the Court identified multiple instances in which Plaintiff attributed propositions to cases that did not support them. ... That motion attributed purported quotations to multiple judicial decisions in which the quoted language does not appear. It also included several misstatements of law and case holdings. ... This conduct is unacceptable. When a litigant places quotation marks around words and attributes those words to a judicial decision, they represent to the Court that the decision contains those words. When the decision does not, the filing misleads the Court. Repeatedly presenting invented quotations and inaccurate descriptions of authority consumes scarce judicial resources, burdens opposing parties, and undermines the adjudicative process. ... Whether those defects in Plaintiffs’ submissions were generated by artificial intelligence, copied from an unreliable source, or created by Plaintiffs themselves is immaterial. A litigant may use whatever tools it chooses, but it may not file misleading legal arguments. ... The Court declines at this time to initiate sanctions proceedings or impose filing restrictions. However, Plaintiffs are expressly WARNED that every future submission to this Court must comply fully with Federal Rule of Civil Procedure 11. Before filing any paper, Plaintiffs must personally verify that every cited authority exists, that every quotation appears in the cited source, that every description of the record is accurate, and that every legal contention is warranted by existing law or a nonfrivolous argument for changing it.", "ai_tool_named": null, "archive_url": null, "case_name": "Moore v. Aldridge Pite LLP", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Western District of Texas", "court_code": "txwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-03", "decision_id": "txwd-2026-moore-v-aldridge-pite", "disposition": "The court dismissed the final remaining claims without prejudice and expressly warned plaintiffs about future Rule 11 compliance.", "docket_number": "MO:25-CV-00326-DC", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiffs repeatedly filed invented quotations, unsupported case descriptions, and legal misstatements after prior warnings.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2777/Moore_et_al_v._Federal_National_Mortgage_Association_et_al_USA_6_August_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "32b4e0735c9e93f8453444e2e0090ca9a54e3b1a56a2aeb37840f55dda6086ae", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "moore-v-aldridge-pite-llp", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txwd-2026-moore-v-aldridge-pite", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txwd-2026-moore-v-aldridge-pite" }, { "ai_passage": "Appellants cite to two cases—one which is non-existent—for the rules that summary judgment may not be entered where discovery is incomplete or credibility issues remain. See id. at 40 (citing Gibson v. Bicknell, 668 A.2d 1370 (Pa. Super. 1995), and Washington v. Baxter, 719 A.2d 733 (Pa. 1998)). ... This cited case does not exist.Elsewhere in their brief, Appellants cite to Gonzalez v. Procaccio Bros. Trucking Co., 268 A.3d 528 (Pa. Super. 2021), and In re Estate of Pittman, 636 A.2d 1166 (Pa. Super. 1994), which also do not exist. We remind Appellants that litigants must cite to “pertinent” authority. See Pa.R.A.P. 2119(a). Such misstatements and/or misrepresentations, if further disseminated, undermine the accuracy and reliability of the law Appellants purport to reference. Moreover, we remind Appellants that we may dismiss an appeal if the brief defects are substantial. See Pa.R.A.P. 2101.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907212817/https://websitedc.s3.amazonaws.com/documents/Bisher_B._v._Lehigh_Valley_Health_Network__USA_3_August_2026.pdf", "case_name": "Bisher v. Civic", "citation": null, "cited_authorities": [ "Gibson v. Bicknell, 668 A.2d 1370 (Pa. Super. 1995)", "Gonzalez v. Procaccio Bros. Trucking Co., 268 A.3d 528 (Pa. Super. 2021)", "In re Estate of Pittman, 636 A.2d 1166 (Pa. Super. 1994)", "Pa.R.A.P. 2119(a)", "Pa.R.A.P. 2101" ], "court": "Superior Court of Pennsylvania", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-03", "decision_id": "pasuperct-2026-bisher-v-civic", "disposition": "The court affirmed summary judgment and admonished self-represented appellants over nonexistent and misleading appellate citations.", "docket_number": "2582 EDA 2025", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellants cited three nonexistent Pennsylvania cases and other misrepresented authority in an appellate brief.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2775/Bisher_B._v._Lehigh_Valley_Health_Network__USA_3_August_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "8b3aaccf559e3cae9fccbe8499e1ae0fe17fa7ef7aa3aa86a4c973d3cf530880", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "bisher-v-civic", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pasuperct-2026-bisher-v-civic", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pasuperct-2026-bisher-v-civic" }, { "ai_passage": "A further problem on appeal is that Appellant has filed a non-conforming brief, well outside of the limits set by the Rules of Appellate Procedure. The brief is set in a small font, single spaced, and if converted to 12-point font and double-spaced would well exceed 35 pages and 9,000 words (the word count is over 12,000). Appellant has also notified this Court that he used generative Artificial Intelligence (AI) to create his brief. Since Appellant is not an attorney, he cannot determine whether AI has produced viable legal arguments. Since he has not tested most of his arguments at the trial court level, he seeks for this Court to determine the legitimacy of his AI documents and arguments. ... It is not clear what argument Appellant is trying to make regarding the Sanchez case, cited above. The issue in Sanchez was whether the defendant was being held solely on the pending charge. More specifically, the question in that case was whether a detainer filed by the Bureau of Immigration and Customs Enforcement nullified the triple count provision of R.C. 2945.71(E). This is not an issue in the instant matter. Sanchez does not discuss the topic Appellant raises and does not mention indefinite tolling. His citation to this immaterial case may have been as a result of a “hallucination” by Appellant’s AI queries.", "ai_tool_named": null, "archive_url": null, "case_name": "State v. Davis", "citation": "2026-Ohio-2993", "cited_authorities": [ "State v. Sanchez, 2006-Ohio-4478", "R.C. 2945.71(E)", "State ex rel. Neil v. French, 2018-Ohio-2692" ], "court": "Ohio Court of Appeals, Seventh Appellate District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-03", "decision_id": "ohioctapp-2026-state-v-davis", "disposition": "The court affirmed Davis's speeding conviction and taxed costs against him.", "docket_number": "25 CO 0050", "document_type": "opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant used AI and cited Sanchez for an indefinite-tolling proposition the opinion did not discuss.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2783/State_v._Davis_USA_3_August_2026.pdf", "state": "OH", "summary": "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.", "text_sha256": "76afaac51163e202efe53b7275fe91faaabfab9465f3f2e3f45dbdca7ffb3589", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "state-v-davis", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohioctapp-2026-state-v-davis", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohioctapp-2026-state-v-davis" }, { "ai_passage": "The record provides clear and convincing evidence that Colantonio engaged in conduct that justifies imposing sanctions under the court's inherent authority. First, Colantonio provided erroneous case citations repeatedly even after being warned. Colantonio has admitted that the citation was erroneous. ... Thus the record establishes by clear and convincing evidence that Colantonio knowingly submitted a pleading containing fabricated authority and citations on multiple occasions and even after being warned. This conduct constitutes an abuse of the judicial process that is utterly inconsistent with the orderly administration of justice and undermines the integrity of the judicial process. Colantonio's repeated conduct also establishes that he acted in bad faith when he submitted his response. Thus the court may sanction Colantonio under its inherent authority. ... The record in this case shows that a significant sanction is warranted. The submission of fabricated authority imposes substantial costs on the opposing party, the court, and the judicial process. ... After considering Colantonio's conduct and the need to deter similar conduct from him and other litigants, the court orders that he pay the attorney's fees incurred by the Town of Cary as a result of his brief. These fees include, but are not limited to, drafting its reply brief and attending the show cause hearing. ... Further, the Clerk of Court is directed to send a copy of this order and a transcript of the April 16, 2026 hearing (D.E. 18) to the North Carolina State Bar for whatever action it deems appropriate, including consideration of whether disciplinary or disability-related measures are warranted.", "ai_tool_named": null, "archive_url": null, "case_name": "Forney v. Township of Cary, North Carolina", "citation": "2026 WL 2439988", "cited_authorities": [ "United States v. Shaffer Equipment Co., 11 F.3d 450 (4th Cir. 1993)", "Six v. Generations Federal Credit Union, 891 F.3d 508 (4th Cir. 2018)", "Jimenez v. DaimlerChrysler Corp., 269 F.3d 439 (4th Cir. 2001)", "Roadway Express, Inc. v. Piper, 447 U.S. 752 (1980)", "Chambers v. NASCO, Inc., 501 U.S. 32 (1991)", "In re McDonald, 489 U.S. 180 (1989)" ], "court": "United States District Court for the Eastern District of North Carolina", "court_code": "nced", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-03", "decision_id": "nced-2026-forney-v-township-of-cary", "disposition": "The court recommended dismissal, ordered counsel to pay Cary's response fees, and referred the matter to the North Carolina State Bar.", "docket_number": "5:25-CV-00738-M", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel repeatedly submitted fabricated authority and erroneous citations after a prior warning in related litigation.", "currency": null, "monetary_penalty": null, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2921/Damon_Forney_Plaintiff_v_Township_of_Cary_North_Carolina_USA_3_August_2026.pdf", "state": "NC", "summary": "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.", "text_sha256": "cc71b2996b4ff26304616cf5d7d0a226057f3159f79079a1912d6d09d5d92449", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "forney-v-township-of-cary", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nced-2026-forney-v-township-of-cary", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nced-2026-forney-v-township-of-cary" }, { "ai_passage": "The court also ORDERS Plaintiff to Show Cause (“OSC”) in writing, on or before August 17, 2026, why sanctions should not be imposed under Federal Rule of Civil Procedure Rule 11 and the court's inherent authority, for Plaintiff's submission of frivolous and vexatious filings and/or false and fabricated legal citations. ... Plaintiff's filings bear hallmarks often associated with the use of generative AI programs, including the prompts Plaintiff used to generate results from these programs, tonal and textual inconsistencies, and the inclusion of fabricated and unsubstantiated (commonly referred to as “hallucinated”) legal authorities. ... Plaintiff is reminded that generative AI tools are known to “hallucinate” and fabricate legal citations and case law that do not exist or are incorrectly applied. Plaintiff bears the duty to verify the accuracy, existence, and validity of every legal citation and reference submitted to the court, and is warned that the submission of false, fabricated, and AI “hallucinated” legal authorities will result in the imposition of sanctions, which could include: (a) monetary sanctions to compensate Defendants for any and all attorney's fees and costs reasonably incurred in responding to documents that contain such statements; (b) monetary sanctions exceeding $1,000 payable to the court; and sanctions under Rule 11(b).", "ai_tool_named": null, "archive_url": null, "case_name": "Jabbari v. Omidvar", "citation": "2026 WL 2227350", "cited_authorities": [ "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-03", "decision_id": "cacd-2026-jabbari-v-omidvar", "disposition": "The court struck improper filings, restricted further filings, and ordered Jabbari to show cause why sanctions should not issue.", "docket_number": "2:26-cv-03553-FLA (DTBx)", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff filed vexatious papers with fabricated and unsubstantiated legal authorities showing hallmarks of generative-AI use.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2773/ALI_JABBARI_Plaintiff_v_PARVIZ_OMIDVAR_et_al_Defendants_USA_3_August_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "0a9872b672f14cce4abab425eaf2d6e7a6773a96d51ce94dea467a1917b795b1", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "jabbari-v-omidvar", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-jabbari-v-omidvar", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-jabbari-v-omidvar" }, { "ai_passage": "The SSA raised an issue of “fabricated citations” and misrepresentations in Ms. Perry’s motion for a temporary restraining order. See Doc. 30; Doc. 33 at 23–24. The court is aware that Ms. Perry has been warned by another court against such practices. The court warns Ms. Perry that fabricated citations and misrepresentations will not be tolerated. This is the only warning Ms. Perry will receive. Ms. Perry should expect that any future instances of fabricated citations and misrepresentations, in this case or any case in this court, will be sanctioned.", "ai_tool_named": null, "archive_url": null, "case_name": "Perry v. Social Security Administration, Commissioner", "citation": null, "cited_authorities": [ "Doc. 30", "Doc. 33" ], "court": "United States District Court for the Northern District of Alabama", "court_code": "alnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-08-03", "decision_id": "alnd-2026-perry-v-social-security-administration", "disposition": "The court dismissed Perry's claim without prejudice, denied her TRO-related motions, and warned against fabricated citations.", "docket_number": "2:26-cv-00048-AMM", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T13:15:21.976-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff’s temporary-restraining-order motion drew an SSA objection for fabricated citations and misrepresentations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2778/Perry_v._Social_Security_Administration_Commissioner_USA_5_August_2026.pdf", "state": "AL", "summary": "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.", "text_sha256": "dc095a57d107066cb4ea3ff52d40d9fad1de791f15ba72744bcc2ce563957718", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "perry-v-social-security-administration-commissioner", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/alnd-2026-perry-v-social-security-administration", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alnd-2026-perry-v-social-security-administration" }, { "ai_passage": "At the March 26, 2026 hearing, the Court advised Ms. Mahar's counsel that one of the cases he cited in support of this proposition does not exist. ECF No. 61, Transcript of Mar. 26, 2026 hearing, at 9-10. Despite extensive efforts, the Court was unable to locate any case by the alleged name, and its case citation within the response returned a completely unrelated case that is criminal in nature. See ECF No. 34, at 4 (citing the non-existent case titled In re Coastal Carolina Fruit Company). ... In support of this argument, Ms. Mahar's counsel cites three cases for which the United States District Court and Westlaw case numbers, as well as the decision dates, are incorrect. See ECF No. 34, at 2 (cases of Jennings v. RoundPoint Mortgage Servicing Corporation; Mastin v. Ditech Financial, LLC; and Heflin v. PHH Mortgage Corporation). The Court advised Ms. Mahar's counsel of the discovery of the incorrect case information at the March 26, 2026 hearings. ECF No. 61, at 9-10. The Court further advised counsel of a fourth case name contained in the pleading that was nonexistent (the citation for which related to a criminal case). Id. at 10; see n.12, supra.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907213124/https://websitedc.s3.amazonaws.com/documents/Mahar_USA_31_July_2026.pdf", "case_name": "In re Mahar", "citation": "2026 WL 2220314", "cited_authorities": [ "In re Coastal Carolina Fruit Company", "Jennings v. RoundPoint Mortgage Servicing Corporation", "Mastin v. Ditech Financial, LLC", "Heflin v. PHH Mortgage Corporation", "28 U.S.C. § 1334" ], "court": "United States Bankruptcy Court for the Eastern District of Virginia", "court_code": "vaeb", "court_level": "federal-bankruptcy", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-31", "decision_id": "vaeb-2026-in-re-mahar", "disposition": "The bankruptcy court dismissed the adversary complaint without prejudice for lack of subject-matter jurisdiction.", "docket_number": "25-72454-SCS; Adv. No. 25-07027-SCS", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel cited a nonexistent bankruptcy case and three existing-case names with incorrect court, Westlaw, or date information.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2780/Mahar_USA_31_July_2026.pdf", "state": "VA", "summary": "The Eastern District of Virginia bankruptcy court dismisses Alicia Mahar’s adversary complaint for lack of jurisdiction. Footnotes note that counsel cited a nonexistent In re Coastal Carolina Fruit Company decision and supplied incorrect court, Westlaw, or date information for three other mortgage cases.", "text_sha256": "ee492af02a507c78ea0b8cb8afe6b4ddd5b9a242cecde8db6a297cf58904e2f7", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "in-re-mahar", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/vaeb-2026-in-re-mahar", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/vaeb-2026-in-re-mahar" }, { "ai_passage": "Outside the jury’s presence, the trial judge referred to a written memorandum defense counsel filed regarding the admissibility of said items. During the ensuing colloquy between the trial judge and defense counsel, the trial judge stated that defense counsel’s memorandum misstated the holdings of several cases, whereupon defense counsel admitted that the memorandum was produced by artificial intelligence and he did not read the cases cited therein. The trial judge overruled defense counsel’s objection and admitted the items into evidence. ... Counsel described the amount of discovery in Appellant’s case as “insurmountable” and stated that he used artificial intelligence (AI) to transcribe long videos into written form to make it easier to review them with Appellant. ... Counsel also testified that he used AI to generate memoranda regarding legal issues. ... Appellant argues that trial counsel provided ineffective assistance by ... presenting an inaccurate AI-prepared memorandum to the trial court ... Assuming without deciding that counsel’s performance was deficient, we conclude that Appellant fails to establish that, but for counsel’s alleged errors and omissions, the outcome of his trial would have been different.", "ai_tool_named": "artificial intelligence", "archive_url": null, "case_name": "Higgins v. State", "citation": null, "cited_authorities": [ "Strickland v. Washington, 466 U.S. 668 (1984)", "Texas Rule of Evidence 403" ], "court": "Texas Court of Appeals, Twelfth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-31", "decision_id": "txapp-2026-higgins-v-state", "disposition": "The court affirmed Higgins's conviction and rejected ineffective-assistance arguments, including complaints about an inaccurate AI-prepared memorandum.", "docket_number": "12-25-00090-CR", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": "artificial intelligence", "conduct": "Defense counsel filed an AI-produced memorandum misstating several case holdings and admitted he had not read the cited cases.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2721/Higgins_v._Texas_USA_July_2026.pdf", "state": "TX", "summary": "The Texas Twelfth Court of Appeals affirms Kevin Higgins’s conviction. The opinion recounts defense counsel’s admission that an AI-produced evidentiary memorandum misstated case holdings because counsel did not read the cited cases, but holds Higgins did not establish Strickland prejudice.", "text_sha256": "2ff26520304ed5c10dd879a7476e82438f6230d06a7c88223bdbc6cd29b95180", "topics": [ "fabricated-citations", "competence-fees", "criminal-justice-algorithms" ], "tracker_slug": "higgins-v-state", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txapp-2026-higgins-v-state", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txapp-2026-higgins-v-state" }, { "ai_passage": "Perhaps recognizing that Smith does not support his argument, Williams resorts to providing a non-existent quotation from the case: “The Ninth Circuit held that officers cannot ‘prevent a suspect from making an unambiguous request for counsel by cutting him off.’ ” Reply, ECF 172 at 9. This Court admonishes Williams's counsel for misquoting Smith, but at the same time, this Court does not endorse Agent Pasquale's interruption of Williams. ... At the hearing, Williams's counsel stated that this error was not a result of using generative AI but rather an inadvertent mistake. This Court reminds Williams's counsel that he is responsible for not only his own contributions but also his client's contributions to any of his submissions.", "ai_tool_named": null, "archive_url": null, "case_name": "United States v. Karnezis", "citation": "2026 WL 2212298", "cited_authorities": [ "United States v. Smith, 860 F.2d 1533 (9th Cir. 1988)", "McNeil v. Wisconsin, 501 U.S. 171 (1991)", "United States v. Rodriguez, 518 F.3d 1072 (9th Cir. 2008)", "Miranda v. Arizona, 384 U.S. 436 (1966)" ], "court": "United States District Court for the District of Oregon", "court_code": "ord", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-31", "decision_id": "ord-2026-united-states-v-karnezis", "disposition": "The court granted in part a suppression motion and admonished Williams's counsel for a non-existent quotation in briefing.", "docket_number": "3:23-cr-00067-IM", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Defense counsel submitted a non-existent quotation from a Ninth Circuit Miranda case in suppression briefing.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only. The court records counsel's statement that the non-existent quotation was an inadvertent mistake rather than generative AI.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2760/USA_v._Karnezis_USA_31_July_2026.pdf", "state": "OR", "summary": "The District of Oregon partially suppresses statements in a criminal case. In resolving the Miranda arguments, the court notes that defense briefing supplied a quotation that does not appear in Smith and admonishes counsel, while recording counsel’s statement that the mistake was not caused by generative AI.", "text_sha256": "25b0aec6dd0a2c276343c06c3ef7806a3b058872ff35ce08d7754b7edee07a77", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "united-states-v-karnezis", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ord-2026-united-states-v-karnezis", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ord-2026-united-states-v-karnezis" }, { "ai_passage": "As a final matter, the Court addresses Defendants’ concern that Plaintiff's opposition brief contained citations and quotations to non-existent case authority, which they attribute to his use of artificial intelligence (“AI”). Dkt. No. 55 (“Forrest Defs. Repl.”) at 1–2; Dkt. No. 58 (“Shook Defs. Repl.”) at 1. The Shook Defendants urge the Court to sanction Plaintiff, including by striking his opposition and treating the motions as unopposed. ... Forrest Defendants do not seek sanctions pursuant to Rule 11 given that Plaintiff is pro se, but express frustration at the unnecessary resources they spent verifying his inaccurate citations. ... Whether this Court has adopted an individual rule regarding the use of AI or not, Rule 11 requires parties to certify that their legal contentions “are warranted by existing law.” Fed. R. Civ. P. 11. Even though he is proceeding pro se, Plaintiff “is required to comply with the Local Rules and Federal Rules of Civil Procedure.” McClellon v. Rickard, 2026 WL 686499, at *9 (S.D.N.Y. Mar. 11, 2026). Accordingly, whether the deficiencies in Plaintiff's filings stem from his use of AI or some other source, the Court cautions him that future submissions to any court must contain only accurate citations and representations. If they do not—because of AI hallucinating case citations or otherwise—he may be sanctioned, id., although the Court declines to do so now.", "ai_tool_named": null, "archive_url": null, "case_name": "Santana v. Shook Hardy & Bacon", "citation": "2026 WL 2212887", "cited_authorities": [ "Fed. R. Civ. P. 11", "McClellon v. Rickard, 2026 WL 686499 (S.D.N.Y. Mar. 11, 2026)" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-31", "decision_id": "nysd-2026-santana-v-shook-hardy-bacon", "disposition": "The court compelled arbitration, stayed the case, and cautioned Santana that future inaccurate citations may bring sanctions.", "docket_number": "25-CV-5088 (RA)", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff filed an opposition brief allegedly containing citations and quotations to nonexistent case authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2726/Santana_v._Shook_Hardy__Bacon_USA_31_July_2026.pdf", "state": "NY", "summary": "The Southern District of New York compels arbitration and stays a pro se employment case. The opinion separately addresses defendants’ concern that Santana’s opposition used nonexistent case authority attributed to AI, declines sanctions for now, and warns that future inaccurate citations may be sanctioned.", "text_sha256": "cb61e8e151a1bbf89699f717f17f9c8365dbe04a0e31081dcd0f6a190c63630b", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "santana-v-shook-hardy-bacon", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-santana-v-shook-hardy-bacon", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-santana-v-shook-hardy-bacon" }, { "ai_passage": "First, Plaintiff's objections contain numerous factitious citations. For example, Plaintiff quotes 9 U.S.C. § 5, but the quote is inaccurate. Additionally, Plaintiff purportedly cites cases such as “Cottman Transmission Sys., Inc. v. Metro. Pontiac GMC, Inc., 351 F. Supp. 2d 343, 347 (E.D. Pa. 2004)” and “McMahon v. RMS Electronics, Inc., 951 F. Supp. 923, 925 (S.D.N.Y. 1997),” but these cases do not exist. ... As set forth previously in this opinion, Plaintiff's objections contained factitious citations. These factitious citations appear to be created by generative artificial intelligence (“AI”) tools. ... Nevertheless, “a pro se litigant must not provide the Court with erroneous and factitious citations and has an obligation to review documents filed with the Court to make certain they are scrupulously accurate.” ... The Court warns Plaintiff that, in the future, even one factitious citation will not be tolerated and that she may be sanctioned if future filings contain factitious citations, including but not limited to striking of filings or monetary penalties. The Court warns Plaintiff that factitious citations include case citations to nonexistent cases, but also case citations that, while real, do not stand for their asserted proposition. Plaintiff has an obligation to ensure that she does not submit any factitious citations in the future.", "ai_tool_named": null, "archive_url": null, "case_name": "Al-Ali v. CVS Pharmacy, Inc.", "citation": "2026 WL 2211604", "cited_authorities": [ "9 U.S.C. § 5", "Cottman Transmission Sys., Inc. v. Metro. Pontiac GMC, Inc., 351 F. Supp. 2d 343 (E.D. Pa. 2004)", "McMahon v. RMS Electronics, Inc., 951 F. Supp. 923 (S.D.N.Y. 1997)", "United States v. Hayes, 763 F. Supp. 3d 1054 (E.D. Cal. 2025)", "Everett J. Prescott, Inc. v. Beall, 2025 WL 2084353 (D. Me. July 24, 2025)", "Whiting v. City of Athens, 170 F.4th 455 (6th Cir. 2026)", "Ali v. IT People Corp., Inc., 2025 WL 2682622 (E.D. Mich. Sept. 19, 2025)" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-31", "decision_id": "mied-2026-al-ali-v-cvs-pharmacy", "disposition": "The court overruled objections and warned Al-Ali that future factitious citations may lead to struck filings or monetary sanctions.", "docket_number": "24-13046", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff filed objections with inaccurate statutory text, nonexistent cases, and real cases that did not support asserted propositions.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2754/Al_Ali_v._CSV_USA_31_July_2026.pdf", "state": "MI", "summary": "The Eastern District of Michigan overrules arbitration-related objections and warns Natashah Al-Ali. The order identifies nonexistent cases and an inaccurate statutory quotation, says the factitious citations appear AI-created, and states that even one future factitious citation may trigger sanctions.", "text_sha256": "d9f49c25ef85b9e92dc7e577ea528a70d37b5f7ac02a36b049a194553e5f0652", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "al-ali-v-cvs-pharmacy-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-al-ali-v-cvs-pharmacy", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-al-ali-v-cvs-pharmacy" }, { "ai_passage": "In addition to the factual inaccuracies discussed above, JAAW offered, in support of its protest arguments, citations to five bid protest decisions--two decisions of our Office and three decisions of the U.S. Court of Appeals for the Federal Circuit. ... Based on these inaccurate legal citations, the Army posited that JAAW’s protest “bears indicia consistent with the use of a large-language model or other artificial intelligence (AI)” tool. ... The Army correctly notes that two citations in JAAW’s July 2, 2026 GAO protest require correction. JAAW acknowledges these errors and takes full responsibility: 1. Tyco Electronics Corp., B-411937: The Army was unable to locate this decision. JAAW has independently verified that this citation as presented does not correspond to a published GAO decision. JAAW withdraws this citation. ... 2. Impresa Construzioni Geom. Domenico Garufi v. United States, 238 F.3d 1324 (Fed. Cir. 2001): The Army correctly notes that this case addresses a contractor responsibility determination, not solicitation ambiguity. JAAW withdraws the citation as applied to the ambiguity argument. ... while there is nothing inherently wrong with the proper and competent use of AI tools in the legal arena, this evolving technology has many glitches--including hallucinations--and must only be used with close, careful supervision, fact-checking, and citation-checking. ... Here, because we dismiss the protest for failing to set forth a factually sufficient basis of protest, we do not exercise our right to impose sanctions for JAAW’s submission of one non-existent citation and one wholly irrelevant citation. The protester, however, is advised that any future submissions of filings to our Office with citations to non-existent or wholly irrelevant authority may, after a review of the totality of the circumstances, result in the imposition of sanctions.", "ai_tool_named": null, "archive_url": null, "case_name": "Matter of The JAAW Group, LLC", "citation": null, "cited_authorities": [ "Tyco Electronics Corp., B-411937", "Impresa Construzioni Geom. Domenico Garufi v. United States, 238 F.3d 1324 (Fed. Cir. 2001)", "KE System Servs., Inc., B-423881", "Raven Investigations & Sec. Consulting, LLC, B-423447", "4 C.F.R. § 21.1(c)(4)" ], "court": "Government Accountability Office", "court_code": null, "court_level": "federal-specialty", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-31", "decision_id": "gao-2026-jaaw-group", "disposition": "GAO dismissed the protest on factual insufficiency and warned that future nonexistent or irrelevant citations may lead to sanctions.", "docket_number": "B-424433.22", "document_type": "opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Protester submitted one nonexistent GAO decision citation and one Federal Circuit citation unrelated to the solicitation-ambiguity proposition asserted.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2722/JAAW_Group_B-424433.22_July_31_2026.pdf", "state": null, "summary": "GAO dismisses JAAW’s bid protest as factually insufficient and separately addresses AI-associated citation problems. The decision notes one nonexistent GAO citation and one irrelevant Federal Circuit citation, declines sanctions because dismissal rests on other grounds, and warns future filings may be sanctioned.", "text_sha256": "13f11b896b23b3d9b455dc91417375245c2afaa40f3447a420f80e81fe91ca70", "topics": [ "fabricated-citations", "rules-by-opinion" ], "tracker_slug": "matter-of-the-jaaw-group-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gao-2026-jaaw-group", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gao-2026-jaaw-group" }, { "ai_passage": "Smith’s briefs include false legal citations, of which her citation to Gielow is one example. Specifically, and as noted throughout this opinion, some citations misrepresent the content of the cited cases and statutes, and some citations are to legal authorities that exist but are wholly unrelated to the proposition for which they are cited. The inclusion of false legal citations in Smith’s briefing violates WIS. STAT. RULE 809.19(1)(e) and (4)(b). This court cautions Smith not to repeat this violation in any future filings in this or any court. I offer an additional note of caution—if the root of the problem is that Smith used generative AI for legal research and trusted it to provide accurate results, she should be aware that there are many reported instances in which generative AI has hallucinated nonexistent cases and misreported the holdings of existing cases. ... While many if not most of Smith’s arguments are not supported by the record or by citations to relevant authority, I cannot conclude that the entire appeal is frivolous. Accordingly, I deny First Community’s motion.", "ai_tool_named": null, "archive_url": null, "case_name": "First Community Credit Union v. Smith", "citation": null, "cited_authorities": [ "Gielow v. Napiorkowski, 2003 WI App 249", "WIS. STAT. RULE 809.19(1)(e)", "WIS. STAT. RULE 809.19(4)(b)", "WIS. STAT. RULE 809.25", "Thompson v. Ouellette, 2023 WI App 7" ], "court": "Wisconsin Court of Appeals, District IV", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-30", "decision_id": "wiscapp-2026-first-community-credit-union-v-smith", "disposition": "The court affirmed and denied the respondent's frivolous-appeal fee motion, while cautioning Smith about false citations.", "docket_number": "2025AP1045", "document_type": "opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant filed briefs with false legal citations, including misrepresented case and statutory authorities and irrelevant authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2727/First_Community_v._Smith_USA_30_July_2026.pdf", "state": "WI", "summary": "The Wisconsin Court of Appeals affirms in a credit-union dispute and denies a frivolous-appeal fee request. A footnote says Ashley Smith’s briefs contain false legal citations, warns against repetition, and cautions that generative AI can hallucinate nonexistent cases or misreport holdings.", "text_sha256": "79cbb9ce567a592167403050c126f175a683d6f402db6dbc8042c8ee70dc363f", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "first-community-credit-union-v-smith", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wiscapp-2026-first-community-credit-union-v-smith", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wiscapp-2026-first-community-credit-union-v-smith" }, { "ai_passage": "Before addressing the substance of Defendants’ Motion, the Court calls attention to certain concerns it has regarding the Opposition Plaintiff’s counsel filed on March 10, 2026. In reviewing the Opposition, the Court located a number of case citations suggesting that the improper use of artificial intelligence may have occurred here. For example, the Opposition cites to “Larsen v. Davis Cnty. Sch. Dist., 2017 UT App 27, ¶¶ 14–16, 392 P.3d 1008 (Utah Ct. App. 2017)” and “Dale v. Bennett, 921 P.2d 466, 469 (Utah 1996)[,]” but the Court has been unable to locate these cases as cited on Westlaw. Citations to non-existent cases “undermine the integrity of court filings and evince a lack of diligence under Federal Rule of Civil Procedure 11(b).” “A fake opinion is not ‘existing law’ and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law. An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” The Court does not take suggestions of the improper use of artificial intelligence lightly. However, because, as the Court will discuss in full below, transfer of this action to the District of Arizona is appropriate, the Court will leave this issue to be handled according to the discretion of the receiving judge. As such, this issue does not impact the Court’s decision in this Order, which the Court makes according to the applicable law.", "ai_tool_named": null, "archive_url": null, "case_name": "Carey v. Breakell", "citation": null, "cited_authorities": [ "Larsen v. Davis Cnty. Sch. Dist., 2017 UT App 27", "Dale v. Bennett, 921 P.2d 466 (Utah 1996)", "Fed. R. Civ. P. 11(b)", "28 U.S.C. §§ 1404, 1406" ], "court": "United States District Court for the District of Utah", "court_code": "utd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-30", "decision_id": "utd-2026-carey-v-breakell", "disposition": "The court transferred the action to Arizona and left possible AI-related citation issues for the receiving judge.", "docket_number": "4:25-cv-00108-AMA-PK", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiff’s counsel filed an opposition citing two Utah cases the court could not locate and treated as possible AI-related fake opinions.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2742/Carey_v._Breakell_et_al_USA_30_July_2026.pdf", "state": "UT", "summary": "The District of Utah grants transfer to Arizona and flags possible improper AI use in plaintiff’s opposition. The order says counsel cited two cases the court could not locate on Westlaw, quotes authority condemning fake opinions, and leaves the matter to the receiving judge.", "text_sha256": "4892be05776bdbc3b422408e959104e8ef4edabbfb704e811da551ca8b82e0fa", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "carey-v-breakell", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/utd-2026-carey-v-breakell", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/utd-2026-carey-v-breakell" }, { "ai_passage": "Finally, some discussion of appellant’s brief is warranted. As previously mentioned, appellant’s brief is disjointed and difficult to follow. However, that is not the only shortcoming of appellant’s briefing. It is obvious that appellant’s brief was either (1) the result of using artificial intelligence yielding hallucination citations or (2) a deliberate attempt to mislead this court. I prefer to assume the use of AI rather than intentional deception. ... Unfortunately, the brief is far from accurate. On page 8 of Mr. Lavespere’s brief, he states: “As held in In re Marriage of Harrison, 557 S.W.3d 99, 111 (Tex. App.—Houston [14th Dist.] 2018, pet. denied), a trial court’s failure to consider valid objections to a proposed order can constitute reversible error. The court stated that ‘fundamental notions of due process require that parties be afforded a reasonable opportunity to be heard on issues affecting their rights.’” Although the Marriage of Harrison case exists, the passage that Mr. Lavespere quoted is entirely fabricated. Unfortunately, that is not the only instance of fabricated or hallucinated quotations. ... The problem with fake citations and quotations has become rampant. While courts might ignore hallucination cases and quotations from pro se litigants, we cannot turn a blind eye when lawyers commit the same transgressions. ... Although appellee did not request sanctions, on our own motion we order attorney Lavespere to attend three hours of Continuing Legal Education on the dangers of the use of artificial intelligence in court filings and to certify to this court such attendance and compliance within sixty days of this opinion.", "ai_tool_named": "artificial intelligence", "archive_url": null, "case_name": "In the Interest of S.M.T. and S.J.T.", "citation": null, "cited_authorities": [ "In re Marriage of Harrison, 557 S.W.3d 99 (Tex. App.—Houston [14th Dist.] 2018)", "In re Marriage of Swim, 291 S.W.3d 500 (Tex. App.—Amarillo 2009)", "Lenz v. Lenz, 79 S.W.3d 10 (Tex. 2002)", "In re A.S., 298 S.W.3d 834 (Tex. App.—Amarillo 2009)", "In re Terminix Intern. Co., L.P., 131 S.W.3d 651 (Tex. App.—Corpus Christi–Edinburg 2004)", "In re Bennett, 960 S.W.2d 35 (Tex. 1997)" ], "court": "Texas Court of Appeals, Fourteenth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-30", "decision_id": "txapp-2026-in-re-smt-sjt", "disposition": "The court affirmed and ordered attorney Jerry Lytel Lavespere III to complete three additional hours of AI-focused CLE.", "docket_number": "14-25-00151-CV", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": "artificial intelligence", "conduct": "Appellant’s lawyer signed a brief with fabricated quotations from real cases and asserted propositions not found in cited authorities.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2752/In_the_interest_of_S.M.T._and_S.J.T._USA_July_2026.pdf", "state": "TX", "summary": "The Fourteenth Court of Appeals affirms a child-custody modification judgment and sanctions Father’s lawyer. The court finds fabricated quotations from Harrison and Swim, unsupported assertions from Lenz and A.S., assumes AI hallucination rather than deliberate deception, and orders three additional hours of AI-focused CLE.", "text_sha256": "21e4aa036e86d889606269f0edc82db78f8eff9dbb17a930777749a695ebca00", "topics": [ "fabricated-citations", "competence-fees", "rules-by-opinion" ], "tracker_slug": "in-the-interest-of-s-m-t-and-s-j-t", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txapp-2026-in-re-smt-sjt", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txapp-2026-in-re-smt-sjt" }, { "ai_passage": "Despite the lengthy preparation time, her opening brief’s purported legal analysis—which advanced six appellate issues—spanned just five pages with zero record references and a citation to a nonexistent case. Cf. Tex. R. App. P. 38.1(i). ... Three months later, on the day Father’s brief was due, Mother moved for leave to file an overhauled amended brief. Mother conceded that her original opening brief had not complied with the Rules of Appellate Procedure and she stated that her amended opening brief “correct[ed the] technical deficiencies, incorporate[d] accurate citations to the record and legal authority, and present[ed] the substantive arguments in a clear, organized manner.” ... But as it turned out, Mother’s amended brief was nearly three times the length of her original brief and it raised new and different appellate issues. ... Furthermore, Mother’s amended opening brief cited to portions of case law that did not exist and quoted statements nowhere to be found in the cited case law. ... Mother cannot raise new appellate issues beyond those in her original opening brief, and even if she had obtained leave to do so, the eight issues raised in her amended opening brief lack merit. Mother’s pending motions are denied, and the trial court’s judgment is affirmed.", "ai_tool_named": null, "archive_url": null, "case_name": "In the Interest of Q.C. and P.C.", "citation": null, "cited_authorities": [ "Tex. R. App. P. 38.1(i)", "ERC Midstream LLC v. American Midstream Partners, LP, 497 S.W.3d 99 (Tex. App.—Houston [14th Dist.] 2016)" ], "court": "Texas Court of Appeals, Second District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-30", "decision_id": "txapp-2026-in-re-qc-pc", "disposition": "The court denied Mother's pending motions and affirmed the trial court's modification judgment.", "docket_number": "02-24-00278-CV", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Appellant’s original and amended briefs cited a nonexistent case, nonexistent portions of case law, and quotations not found in cited cases.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2762/In_the_Interest_of_Q.C._and_P.C._USA_30_July_2026.pdf", "state": "TX", "summary": "The Texas Second Court of Appeals affirms a child-custody modification judgment on rehearing. The opinion notes Mother’s original brief cited a nonexistent case and that her counsel-filed amended brief cited nonexistent case portions and false quotations, but the court resolves the appeal on briefing and merits grounds.", "text_sha256": "f714f640579b305e2b3ba34d47aee5f5d58b41d4ad3f509412499decd76f0449", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "in-the-interest-of-q-c-and-p-c", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txapp-2026-in-re-qc-pc", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txapp-2026-in-re-qc-pc" }, { "ai_passage": "[H]e claims that because he has no access to a computer or typing facilities in prison, he first wrote “the entire document by hand” and then had “a person outside the prison type[] [his] handwritten notes and input[] them into an [artificial intelligence (‘AI’)] tool to help format the document properly.” Id. at 2. The Trustee contends that the legal citations in the motion “appear[] to be AI-generated” and that although “most of the cited cases exist, they generally do not support the propositions stated” and that at least one case citation “includes a non-existent quotation.” Opp. at 12. ... Rule VI reminds “all parties” of “their obligation to provide the Court with accurate and complete representations in any pleading, written motion, or other paper submitted to the Court” pursuant to Federal Rule of Civil Procedure 11. Rule VI further requires a party using “generative artificial intelligence” for any submission to confirm for themselves “that the submission and all source material within, is accurate and in compliance with the obligations of Rule 11.” ... For example, on page 21, Modi argues that the Order violates “fundamental notions of fair play” and cites Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541, 546 (1949) for the quotation. Mot. at 21. That quotation does not, however, appear in Cohen. The Court is also concerned by what appear to be AI-generated legal citations that do not support the propositions in the motion. Compare, e.g., Mot. at 18 (citing Traguth v. Zuck, 710 F.2d 90 (2d Cir. 1983) for the proposition that “the Second Circuit held that courts must give special solicitude to pro se prisoners to prevent unfair technical dismissals”), with Traguth, 710 F.2d at 95 (setting aside default judgment in case involving a pro se defendant, who was not incarcerated, where default was not willful).", "ai_tool_named": "artificial intelligence (‘AI’) tool", "archive_url": null, "case_name": "In re Firestar Diamond, Inc.", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Fed. R. Bankr. P. 8011", "Cohen v. Beneficial Industrial Loan Corp., 337 U.S. 541 (1949)", "Traguth v. Zuck, 710 F.2d 90 (2d Cir. 1983)" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-30", "decision_id": "nysd-2026-in-re-firestar-diamond", "disposition": "The court denied Modi leave to pursue an interlocutory bankruptcy appeal and dismissed the action.", "docket_number": "25 Civ. 9434 (AT)", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": "artificial intelligence (‘AI’) tool", "conduct": "Self-represented appellant submitted an AI-assisted bankruptcy appeal motion with a non-existent quotation and citations that did not support asserted propositions.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2761/In_Re_Firestar_Diamond_Inc._USA_30_July_2026.pdf", "state": "NY", "summary": "The Southern District of New York denies Nirav Modi’s motion for leave to appeal a bankruptcy order. The court notes Modi used an outside person and AI tool to format the motion, identifies a false Cohen quotation and unsupported AI-generated citations, and dismisses the action.", "text_sha256": "a52a88c2386646d1eca36c195bf4ad2195904465aeeab8ac2b1eb34c16645593", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "in-re-firestar-diamond-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-in-re-firestar-diamond", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-in-re-firestar-diamond" }, { "ai_passage": "While not touched on by the current opinion due to lack of standing, the Court will note that Mr. Harris cited “Allen v. Equifax Info. Services, LLC, 2020 WL 2155673, at 3 (N.D. Miss. Apr. 1, 2020) and LeBlanc v. TransUnion, LLC, 2021 WL 1243659, at 5 (N.D. Miss. Mar. 19, 2021)” to support his claims against BANA. These two cited Northern District of Mississippi Opinions were unable to be found by this Court, and are likely fictitious citations generated by artificial intelligence. Neither a search of the Westlaw citations or the party names brings up any corresponding case in the Northern District. Citations to and reliance on fraudulent authorities severely undermines the credibility of any of Mr. Harris’ allegations. Due to his pro se nature, the Court will not sanction Mr. Harris, but he is put on notice and will not be given the same grace if he refiles his lawsuit and cites to hallucinated case law again.", "ai_tool_named": null, "archive_url": null, "case_name": "Harris v. Bank of America", "citation": null, "cited_authorities": [ "Allen v. Equifax Info. Services, LLC, 2020 WL 2155673 (N.D. Miss. Apr. 1, 2020)", "LeBlanc v. TransUnion, LLC, 2021 WL 1243659 (N.D. Miss. Mar. 19, 2021)" ], "court": "United States District Court for the Northern District of Mississippi", "court_code": "msnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-30", "decision_id": "msnd-2026-harris-v-bank-of-america", "disposition": "The court dismissed Harris's FCRA claims without prejudice for lack of standing and warned him about hallucinated case law.", "docket_number": "3:25-cv-00328-MPM-JMV", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff cited two likely fictitious Northern District of Mississippi opinions in opposition briefing.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2725/Harris_v._Boma_USA_31_July_2026.pdf", "state": "MS", "summary": "The Northern District of Mississippi dismisses a pro se FCRA suit without prejudice for lack of standing. A footnote identifies two Northern District opinions that the court could not locate, calls them likely AI-generated fictitious citations, declines immediate sanctions, and warns Harris.", "text_sha256": "2d681af5feb4cdd48d2de3f3a6b28a9780d481750a8203be5d63645b7ec84c92", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "harris-v-bank-of-america", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/msnd-2026-harris-v-bank-of-america", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/msnd-2026-harris-v-bank-of-america" }, { "ai_passage": "Before we can consider the merits of Cole’s contentions, we observe that several of his citations to authorities are incorrect, including attributing propositions to authorities that those authorities simply do not support. For example, citing to Avery v. State Farm Mutual Automobile Insurance Co., 216 Ill. 2d 100 (2005), Cole asserts that claims under the Consumer Fraud Act that seek damages are legal claims triable to a jury. However, Avery contains no support for that proposition. Additionally, citing to People ex rel. Daley v. Datacom Systems Corp., 146 Ill. 2d 1 (1991), Cole asserts that where legal and equitable issues are joined, the legal issues must be tried to a jury. Datacom likewise contains no support for that proposition. In addition to attributing propositions to authorities that those authorities do not support, Cole also cites to multiple cases with incorrect citations. ... Under Illinois Supreme Court Rule 341(h)(7) (eff. Oct. 1, 2020), an appellant’s brief must contain argument “with citation of the authorities.” Implicit in this requirement is that citations to authority be accurate. ... Cole’s repeated inaccuracies in this case have prevented meaningful review of his contentions of error and improperly shifted the burden of legal research onto this court. ... Accordingly, we strike Cole’s brief and dismiss his appeal.", "ai_tool_named": null, "archive_url": null, "case_name": "Cole v. Lee", "citation": "2026 IL App (1st) 252223-U", "cited_authorities": [ "Avery v. State Farm Mutual Automobile Insurance Co., 216 Ill. 2d 100 (2005)", "People ex rel. Daley v. Datacom Systems Corp., 146 Ill. 2d 1 (1991)", "Stephens v. Kasten, 383 Ill. 127 (1943)", "In re Estate of Mulvaney, 128 Ill. App. 3d 133 (1984)", "Ill. S. Ct. R. 341(h)(7)", "Strong v. Zubha Pop Foods LLC, 2026 IL App (1st) 242451-U" ], "court": "Appellate Court of Illinois, First District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-30", "decision_id": "illappct-2026-cole-v-lee", "disposition": "The appellate court struck Cole's brief and dismissed the appeal because repeated inaccurate citations prevented meaningful review.", "docket_number": "1-25-2223", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant filed a brief with case citations that did not support asserted propositions and several incorrect reporter citations.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2758/Cole_v._Lee_2026_IL_App_1st_252223-U.pdf", "state": "IL", "summary": "The Illinois First District strikes Tony Cole’s pro se brief and dismisses his appeal. The order identifies authorities that do not support cited propositions and incorrect case citations, says the inaccuracies improperly shifted research burdens to the court, and relies on repeated Rule 341 violations.", "text_sha256": "48e2b981ec4e44956c5de19b8446b7f25b20840147d3f27c4c9d2798451699be", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "cole-v-lee", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/illappct-2026-cole-v-lee", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illappct-2026-cole-v-lee" }, { "ai_passage": "Unfortunately, Mr. Robinson’s brief fails to comply with this rule as it contains numerous false quotations from case law and statutes and, in some instances, outright fake citations. In this way, Mr. Robinson’s brief bears all the hallmarks of an artificial intelligence-generated brief, filled with what has been referred to as “hallucinations.” ... Mr. Robinson’s brief contains all of these forms of hallucinations. For instance, Mr. Robinson cites to “First Tenn. Bank Nat’l Ass’n v. McClure, 199 S.W.3d 429, 432 (Tenn. Ct. App. 2005).” While there is a real case under that name, it is not reported in the South Western Reporter. The citation given actually leads to the dissent of a case from the Court of Appeals of Texas, City of Seabrook v. Port of Houston Auth., 199 S.W.3d 403 (Tex. App. 2006). Further, the real McClure case is not from 2005 but from 1990. ... This issue of AI hallucinations is prevalent in Mr. Robinson’s statutory citations as well. His brief quotes Tenn. Code Ann. § 66-28-304(a) as “A landlord shall: . . . (4) Maintain in good and safe working order and condition all electrical, plumbing, sanitary, heating, ventilating air-conditioning and other facilities and appliances supplied or required to be supplied by the landlord.” ... However, that section of the code, Tenn. Code Ann. § 66-28-304(a)(4), actually states: “In multi-unit complexes of four (4) or more units, provide and maintain appropriate receptacles and conveniences for the removal of ashes, garbage, rubbish and other waste from common points of collection subject to § 66-28-401(3),” language which is certainly less helpful to Mr. Robinson’s position. Further still, some cases appear to be fabricated entirely as Mr. Robinson cites to “Puckett v. Estate of Puckett, 174 S.W.3d 252, 257 (Tenn. 2005).” The given location in the reporter is actually for the Court of Appeals case Emmit v. Emmit, 174 S.W.3d 248 (Tenn. Ct. App. 2005), and we are unable to find any Tennessee Supreme Court case under the cited case name. ... Because of the inaccurate citations to law, Mr. Robinson’s arguments are not “warranted by existing law,” as required by Tenn. Ct. App. R. 17.01. ... Therefore, we believe the best course is to disregard the citations in Mr. Robinson’s brief that do not accurately reflect what the authority states and address the arguments without consideration of fictitious or meritless arguments.", "ai_tool_named": null, "archive_url": null, "case_name": "Harding Place Multifamily Partners v. Robinson", "citation": null, "cited_authorities": [ "Tenn. Ct. App. R. 17.01", "Simmons v. Islam, 2026 WL 1431143 (Tenn. Ct. App. May 21, 2026)", "Andre v. Warden, FCI Danbury, 827 F. Supp. 3d 294 (D. Conn. 2025)", "First Tenn. Bank Nat'l Ass'n v. McClure, 199 S.W.3d 429 (Tenn. Ct. App. 2005)", "Tenn. Code Ann. § 66-28-304(a)", "Puckett v. Estate of Puckett, 174 S.W.3d 252 (Tenn. 2005)", "Akerlund v. Atlas Air, Inc., 2026 WL 1993146 (11th Cir. July 10, 2026)" ], "court": "Court of Appeals of Tennessee", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-29", "decision_id": "tnctapp-2026-harding-place-v-robinson", "disposition": "The court disregarded inaccurate or fabricated portions of Robinson's brief and affirmed the trial court's judgment.", "docket_number": "M2025-01361-COA-R3-CV", "document_type": "opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant filed a brief with false case and statutory quotations, a fabricated Tennessee Supreme Court citation, and misleading reporter citations.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2728/Harding_Place_Multifamily_Partners_LLC_Emers_DJju7pu._Samuel_Robinson_USA_30_July_2026.pdf", "state": "TN", "summary": "The Tennessee Court of Appeals affirms a landlord-tenant judgment and disregards fabricated or inaccurate parts of Samuel Robinson’s pro se brief. The opinion says the brief bears AI hallmarks, identifies false case and statutory quotations, a fabricated Tennessee Supreme Court case, and unsupported legal assertions.", "text_sha256": "fcaa9149cc2359dc9751b1c21094eca764e72266bd13cfd61b2f6e7dee6a2baa", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "harding-place-multifamily-partners-v-robinson", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/tnctapp-2026-harding-place-v-robinson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tnctapp-2026-harding-place-v-robinson" }, { "ai_passage": "As Amazon suggests (but does not expressly state), Gragston seems to rely on AI-hallucinated caselaw in support of this point. (See Doc. 28, #141 n.2). The Court's independent review suggests the same. Gragston cites a case that he refers to as “Latham v. Off. of Att'y Gen. of Ohio, No. 20-4089, 2021 WL 1324065 (6th Cir. Apr. 9, 2021).” (Doc. 27, #133). True, there is a Sixth Circuit case that bears that name, but it is a published decision from 2005 that is not about hostile work environment claims or the use of racial epithets in the workplace. See 395 F.3d 261 (6th Cir. 2005). And, as best the Court can tell, the only Sixth Circuit case with the docket number “20-4089” is United States v. Culver, 20-4089, 2021 WL 4258764 (6th Cir. Sep. 20, 2021), which is a criminal case about sentencing. Finally, there is no case with the Westlaw citation “2021 WL 1324065.” Accordingly, to avoid any such concerns going forward, the Court FORMALLY WARNS Gragston that any future reliance on AI-hallucinated caselaw in this litigation will result in sanctions, including monetary penalties and dismissal of this case with prejudice. ... But, in offering Gragston this opportunity, the Court reiterates its warning that any further reliance on AI-hallucinated authorities in connection with briefing in this matter will result in sanctions, including monetary penalties and potential dismissal of this case with prejudice.", "ai_tool_named": null, "archive_url": null, "case_name": "Gragston v. Amazon LLC", "citation": "2026 WL 2184981", "cited_authorities": [ "Latham v. Office of the Attorney General of Ohio, 395 F.3d 261 (6th Cir. 2005)", "United States v. Culver, 20-4089, 2021 WL 4258764 (6th Cir. Sept. 20, 2021)" ], "court": "United States District Court for the Southern District of Ohio", "court_code": "ohsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-29", "decision_id": "ohsd-2026-gragston-v-amazon", "disposition": "The court granted Amazon's dismissal motion, allowed Gragston to seek leave to amend, and formally warned him about AI-hallucinated cases.", "docket_number": "1:25-cv-206", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff cited a purported Sixth Circuit case with mismatched name, docket number, subject matter, and nonexistent Westlaw citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2786/TERENCE_A_GRAGSTON_Plaintiff_v_AMAZON_LLC_Defendant_USA_July_2026.pdf", "state": "OH", "summary": "The Southern District of Ohio dismisses Gragston’s amended employment complaint but permits a motion for leave to amend. A footnote identifies a purported Sixth Circuit hostile-work-environment citation as AI-hallucinated and formally warns that future reliance may bring monetary sanctions or dismissal with prejudice.", "text_sha256": "016de34ac77b5e6fb1aa7a65f997bb4e7662776f810ce473dd8bde63f2d4e94d", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "gragston-v-amazon-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohsd-2026-gragston-v-amazon", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohsd-2026-gragston-v-amazon" }, { "decision_id": "mathis-fl-2026", "case_name": "Mathis v. Mathis", "court": "Florida Fourth District Court of Appeal", "court_code": "fladistctapp", "court_level": "state-appellate", "state": "FL", "date_filed": "2026-07-29", "citation": null, "docket_number": "4D2025-2986", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "artificial intelligence", "disposition": "The court reversed and remanded a child-support order while disregarding phantom authorities in a pro se brief.", "ai_passage": "In his answer brief, the husband cites two cases which do not exist. As we recently explained: Such phantom authority cannot assist any litigant and must be expressly disregarded by this court. Attorneys and those, like appellee, who proceed pro se are responsible for the content of their submissions to the court. Those who use artificial intelligence to assist in these submissions must ensure their accuracy.", "cited_authorities": [ "Friend v. Serpa, 425 So. 3d 51 (Fla. 4th DCA 2025)" ], "summary": "The Florida appellate court notes that a self-represented appellee cited two nonexistent cases. Without imposing sanctions, it disregards the phantom authority and reiterates that attorneys and pro se litigants remain responsible for verifying AI-assisted filings.", "lead_source": [ "CourtListener anonymous search pro-se-chatgpt.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10936085/x/", "text_sha256": "d591f16ce2cb4348553c336407f15f9ea714be426ecc2fdcbc9727cf1c90df22", "source_url": "https://flcourts-media.flcourts.gov/content/download/2492962/opinion/Opinion_2025-2986.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/mathis-fl-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mathis-fl-2026" }, { "ai_passage": "Finally, it has come to the Court’s attention that Plaintiff’s Response briefs in opposition to the instant Motion for Summary Judgment [#91] and Motion for Sanctions [#87] contain defective citations to case law. These defects include (1) misattributed or inaccurately quoted language from cases, (2) misrepresentations of legal concepts associated with the cited cases, and, most concerningly, (3) citations to cases that do not exist. Plaintiff appears to have used generative artificial intelligence to prepare her briefs. At this juncture, many generative AI tools are incapable of distinguishing between legitimate precedent and fabricated legal fiction. ... Defendant pointed out some of these deficiencies in his Reply in Support of Motion for Sanctions [#118], stating that the hallucinated citations to legal authority “forced [him] to incur yet further attorney fees to verify the falsity of [Plaintiff’s] citations.” ... The submission of legal argument premised on nonexistent law generated by artificial intelligence is a flagrant Rule 11 violation. ... In conducting a thorough inquiry, the Court believes that the following legal authorities that Plaintiff cited in her briefs do not exist: Mastro v. Rigby, 767 F.3d 934 (10th Cir. 2014) ... United States v. Kitchen, 57 F.3d 916 (10th Cir. 1995) ... Somlo v. S.C. Johnson & Son, Inc., 7 F.3d 1334, 1338 (10th Cir. 1993) ... Mikulski v. Center for Psychiatric Rehabilitation, 789 F.3d 1205, 1213 (10th Cir. 2015) ... Chavez v. Young, 880 F.2d 299, 302-03 (10th Cir. 1989) ... Mobley v. McCormick, 40 F.4th 1199, 1205 (10th Cir. 2022) ... Shen v. Express Scripts, Inc., 2019 WL 4741257, at *3. ... Accordingly, the Court orders that, no later than August 26, 2026, Plaintiff shall SHOW CAUSE in writing why the Court should not further sanction her for her submission of defective legal citations.", "ai_tool_named": null, "archive_url": null, "case_name": "Maloit v. Maloit", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025)", "Coomer v. Lindell, 2025 WL 1865282 (D. Colo. July 7, 2025)", "Ferris v. Amazon.com Servs., LLC, 778 F. Supp. 3d 879 (N.D. Miss. 2025)", "Mastro v. Rigby, 767 F.3d 934 (10th Cir. 2014)", "United States v. Kitchen, 57 F.3d 916 (10th Cir. 1995)", "Somlo v. S.C. Johnson & Son, Inc., 7 F.3d 1334 (10th Cir. 1993)", "Mikulski v. Center for Psychiatric Rehabilitation, 789 F.3d 1205 (10th Cir. 2015)", "Chavez v. Young, 880 F.2d 299 (10th Cir. 1989)", "Mobley v. McCormick, 40 F.4th 1199 (10th Cir. 2022)", "Shen v. Express Scripts, Inc., 2019 WL 4741257" ], "court": "United States District Court for the District of Colorado", "court_code": "cod", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-29", "decision_id": "cod-2026-maloit-v-maloit", "disposition": "The magistrate judge recommended summary judgment, granted discovery-fee sanctions in part, and ordered Maloit to show cause over defective citations.", "docket_number": "24-cv-02383-PAB-KAS", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff filed response briefs with misquoted language, misstated legal concepts, and at least seven nonexistent case citations.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2751/Maloit_v._Maloit_USA_29_July_2026.pdf", "state": "CO", "summary": "The District of Colorado magistrate judge recommends summary judgment and grants discovery-fee sanctions in part. The order separately finds Maloit’s briefs contain misquotations, misstatements, and seven nonexistent cases likely from generative AI, then orders her to show cause about additional sanctions.", "text_sha256": "b5c3abc8d805d61895fc36dd038fc3b556ff698fa21556ac4195f3fda1797633", "topics": [ "fabricated-citations", "pro-se-ai-use", "competence-fees" ], "tracker_slug": "maloit-v-maloit", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cod-2026-maloit-v-maloit", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cod-2026-maloit-v-maloit" }, { "ai_passage": "The district court’s order detailed the clear and convincing evidence it relied on to determine that Ms. Robinson’s conduct was sanctionable. The court noted that despite her claims that her emergency motion was “grounded in fact,” Ms. Robinson submitted “no evidence to support the veracity of the purported intercepted statements” about Mr. Raines following her, and admitted she submitted a photo that was “not authentic” as an exhibit to one of her filings. ... The court further noted that at least four of Ms. Robinson’s filings contained non-existent and misrepresented legal authority, and cited caselaw establishing that failure “to confirm the validity of any cited legal authority” may violate Rule 11. ... Ms. Robinson also claims on appeal that “[a]ll case citations are verifiable,” and that she never submitted any fake or AI-hallucinated cases. Aplt. Opening Br. at 2. But this is not true. In fact, Ms. Robinson relied on a hallucinated case in her opening brief on appeal. See id. at 2 (citing a non-existent case called “Reynolds v. Smith, 62 F.3d 1421 (10th Cir. 1995)”). ... For example, in Ms. Robinson’s opposition to WLCC’s and Mr. Raines’s motion to dismiss, she cited “Navajo Nation Oil & Gas Co. v. Window Rock Unified Sch. Dist., 638 F. App’x 698 (10th Cir. 2016).” Aplee. Supp. App. vol. III at 256. But the case found at 638 F. App’x 698 is Sayed v. Broman. On the same page, Ms. Robinson quotes Lewis v. Clarke, 581 U.S. 155 (2017), as stating, “tribal immunity does not extend to individuals acting outside their official capacity,” but that quote does not exist in the case. Id. ... The district court did not abuse its discretion by dismissing Ms. Robinson’s claims with prejudice as a sanction for her litigation misconduct.", "ai_tool_named": null, "archive_url": null, "case_name": "Robinson v. Oglala Sioux Tribe", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Ehrenhaus v. Reynolds, 965 F.2d 916 (10th Cir. 1992)", "Sanders v. United States, 176 Fed. Cl. 163 (2025)", "Reynolds v. Smith, 62 F.3d 1421 (10th Cir. 1995)", "Navajo Nation Oil & Gas Co. v. Window Rock Unified Sch. Dist., 638 F. App'x 698 (10th Cir. 2016)", "Lewis v. Clarke, 581 U.S. 155 (2017)" ], "court": "United States Court of Appeals for the Tenth Circuit", "court_code": "ca10", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-29", "decision_id": "ca10-2026-robinson-v-oglala-sioux-tribe", "disposition": "The Tenth Circuit affirmed dismissal with prejudice as a Rule 11 sanction for Robinson's litigation misconduct.", "docket_number": "25-6143", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff filed nonauthentic evidence and multiple filings with nonexistent, misrepresented, or falsely quoted legal authorities.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2757/Robinson_v._Oglala_USA_29_July_2026.pdf", "state": null, "summary": "The Tenth Circuit affirms dismissal of Shantell Robinson’s claims with prejudice as a Rule 11 sanction. The order describes nonauthentic evidence, at least four filings with nonexistent or misrepresented authority, and a new appellate brief citation to the nonexistent Reynolds v. Smith case.", "text_sha256": "37f8d856ebb83531b1f9295f78561349d539433c3d20285863515b8944b4e05b", "topics": [ "fabricated-citations", "pro-se-ai-use", "evidence-authentication" ], "tracker_slug": "robinson-v-oglala-sioux-tribe", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca10-2026-robinson-v-oglala-sioux-tribe", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca10-2026-robinson-v-oglala-sioux-tribe" }, { "ai_passage": "The filings in this case are riddled with inaccurate citations, seemingly deliberate misrepresentations of guiding caselaw and the factual record, failures to comply with Court rules, and, in at least one instance, advocacy using caselaw that does not exist, likely the result of imprudent reliance on a generative artificial intelligence tool. ... (See Int. Resp. at 14 (citing Aetna Health Inc. v. Health Goals Chiropractic Ctr., Inc., No. 3:12-CV-2587-O, 2012 WL 12873819, at *1 (N.D. Tex. Oct. 25, 2012) (O’Connor, J.))). The Court notes the existence of a case by the same name, Aetna Health Inc. v. Health Goals Chiropractic Center, Inc., No. 10-5216-NLH-JS, 2011 WL 1343047 (D.N.J. Apr. 7, 2011), but that case provides no support for the assertion made in the brief. The Court notes that the attorney who signed the brief, and thus made certain representations under Fed. R. Civ. P. 11(b), is appearing pro hac vice, and it admonishes counsel about the responsible use of generative artificial intelligence in court filings. See Shelton v. Parkland Health, No. 3:24-CV-2190-L-BW, 2025 WL 3141108, at *3 (N.D. Tex. Nov. 10, 2025). ... For the foregoing reasons, Plaintiffs Pillar and TCI’s Motion to Disqualify Johansen and Blank Rome (Dkt. No. 51) and the Liberty Parties’ Motion to Disqualify Johansen and Blank Rome (Dkt. No. 54) are DENIED.", "ai_tool_named": null, "archive_url": null, "case_name": "Transcontinental Realty Investors, Inc. v. Moos", "citation": null, "cited_authorities": [ "Aetna Health Inc. v. Health Goals Chiropractic Ctr., Inc., No. 3:12-CV-2587-O, 2012 WL 12873819 (N.D. Tex. Oct. 25, 2012)", "Aetna Health Inc. v. Health Goals Chiropractic Center, Inc., No. 10-5216-NLH-JS, 2011 WL 1343047 (D.N.J. Apr. 7, 2011)", "Fed. R. Civ. P. 11(b)", "Shelton v. Parkland Health, 2025 WL 3141108 (N.D. Tex. Nov. 10, 2025)" ], "court": "United States District Court for the Northern District of Texas", "court_code": "txnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-28", "decision_id": "txnd-2026-transcontinental-realty-v-moos", "disposition": "The court denied the motions to disqualify Johansen and Blank Rome and admonished pro hac vice counsel about AI-related citation duties.", "docket_number": "3:26-CV-694-O-BW", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Pro hac vice counsel signed briefing citing a nonexistent N.D. Texas Aetna decision; only an unrelated D.N.J. case by that name existed.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2750/Transcontinental_v._Moose_USA_28_July_2026.pdf", "state": "TX", "summary": "The Northern District of Texas denies disqualification motions in a commercial dispute. The opinion notes briefing problems, including one nonexistent Northern District citation likely caused by imprudent generative-AI reliance, and admonishes pro hac vice counsel about responsible AI use and Rule 11 obligations.", "text_sha256": "2024693b7ea8c751fae85129385f25242ccde4c67f78a2ed62d592568c21ec2a", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "transcontinental-realty-investors-inc-v-moos", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txnd-2026-transcontinental-realty-v-moos", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txnd-2026-transcontinental-realty-v-moos" }, { "ai_passage": "In the course of briefing her motion to dismiss and in response to Plaintiff’s filings, Ms. Askew acknowledged that she relied on a false citation, “Young v. Maciorca, 69 F.4th 1099, 1106 (9th Cir. 2023).” ECF No. 92. Ms. Askew subsequently withdrew her references to “Young v. Maciorca,” which is not a Ninth Circuit decision. The Court notes, however, that “Young v. Maciorca” is not the only false citation in Ms. Askew’s briefing. Ms. Askew also cited to “IGI Cybersecurity Services v. [Defendant], Case No. 3:23-cv-01277 (D. Or. July 11, 2024),” in which Ms. Askew claims that “the court found no personal jurisdiction even though the defendant engaged in videoconferences and communications with Oregon parties. The court explained that such incidental or attenuated contacts, absent purposeful targeting, do not satisfy due process.” Askew Mot. at 6. As might be guessed from its incomplete caption, this is not the case cited. The docket number, 3:23-cv-1277, is for Cohen v. Infinite Group, Inc. et al. and, while that case did discuss personal jurisdiction and final judgment was entered on July 11, 2024, the case was subsequently reversed by the Ninth Circuit, which found errors in the district court’s analysis of personal jurisdiction. The Court understands that the parties in this case are self-represented and that there is a significant temptation to rely on artificial intelligence in the drafting of legal papers. The Court therefore advises the parties that it will not accept false or “hallucinated” citations and will view their inclusion in legal filings as an attempt to deceive or mislead the Court. All parties are warned that the inclusion of false or hallucinated citations in future briefs may result in the imposition of sanctions on the filing party.", "ai_tool_named": null, "archive_url": null, "case_name": "Owen v. Askew", "citation": null, "cited_authorities": [ "Young v. Maciorca, 69 F.4th 1099 (9th Cir. 2023)", "IGI Cybersecurity Services v. [Defendant], Case No. 3:23-cv-01277 (D. Or. July 11, 2024)", "Cohen v. Infinite Group, Inc., No. 3:23-cv-1277", "LR 7-1(a)(3)" ], "court": "United States District Court for the District of Oregon", "court_code": "ord", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-28", "decision_id": "ord-2026-owen-v-askew", "disposition": "The court denied defendants' dismissal, transfer, and anti-SLAPP motions and warned all parties against false or hallucinated citations.", "docket_number": "6:25-cv-01272-AA", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented defendant relied on a nonexistent Ninth Circuit citation and an incomplete, misleading District of Oregon citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2745/Owen_v._Askew_et_al_USA_28_July_2026.pdf", "state": "OR", "summary": "The District of Oregon denies self-represented defendants’ dismissal, transfer, and anti-SLAPP motions. Before reaching the merits, the order records withdrawn and additional false citations in Askew’s briefing and warns all parties that future false or hallucinated citations may be sanctioned.", "text_sha256": "71237b5643fb8f42bece1ca8c544d251730252634537cd6344dae6e6a4d1f11b", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "owen-v-askew", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ord-2026-owen-v-askew", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ord-2026-owen-v-askew" }, { "ai_passage": "The Court notes the presence of several citations to nonexistent or fabricated legal authority in Plaintiff's pleadings. “Although courts are solicitous toward pro se litigants, there are reasonable limits”—“a pro se litigant must not provide the Court with erroneous and factitious citations and has an obligation to review documents filed with the Court to make certain they are scrupulously accurate.” Everett J. Prescott, Inc. v. Beall, No. 1:25-cv-00071, 2025 WL 2084353, at *2 (D. Me. July 24, 2025) (quotation modified). Should Plaintiff continue to litigate matters before this Court, he is cautioned that he bears an obligation to personally check each citation to ensure it is “accurate and stands for its asserted proposition.” Id. ... For these reasons, the Commissioner’s motion for summary judgment, ECF No. 22, is GRANTED. Plaintiff’s amended complaint, ECF No. 20, is DISMISSED.", "ai_tool_named": null, "archive_url": null, "case_name": "McNeil v. Bisignano", "citation": null, "cited_authorities": [ "Everett J. Prescott, Inc. v. Beall, No. 1:25-cv-00071, 2025 WL 2084353 (D. Me. July 24, 2025)", "42 U.S.C. § 405(g)" ], "court": "United States District Court for the District of Maine", "court_code": "med", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-28", "decision_id": "med-2026-mcneil-v-bisignano", "disposition": "The court granted summary judgment for the Commissioner and cautioned McNeil to personally check future citations.", "docket_number": "2:25-cv-00292-SDN", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff filed pleadings with several citations to nonexistent or fabricated legal authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2743/MCNEIL_v._BISIGNANO_USA_July_2026.pdf", "state": "ME", "summary": "The District of Maine grants summary judgment to the Social Security Commissioner and dismisses Alexander McNeil’s amended complaint. A footnote flags several nonexistent or fabricated legal authorities in the pro se pleadings and cautions McNeil to personally verify each future citation.", "text_sha256": "0cf8fafc22759de42513c303f38e1b99fd2ede684e72954baf56068941e28cf5", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "mcneil-v-bisignano", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/med-2026-mcneil-v-bisignano", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/med-2026-mcneil-v-bisignano" }, { "ai_passage": "One other consideration worth discussing is the potential misuse of generative artificial intelligence. The parties dedicate a substantial portion of their respective filings to whether Campbell’s motions involve improper use of or reliance on generative artificial intelligence, including whether she misstates legal authority or she uploaded confidential documents into a generative artificial intelligence program. ... Campbell denies submitting documents into any generative artificial intelligence tools but admits to using unspecified “available tools solely to express [her] arguments in proper legal format, the same way any litigant uses available legal resources.” ... Campbell’s filings bear common hallmarks of generative artificial intelligence, including their verbosity (more than 60 pages of briefing) about a relatively narrow issue, repeated statements that sound legally sophisticated while some of the legal citations are imprecise or inconsistent, and difficult to follow titles of her briefs. More concerning than those are any misrepresentations about the law. While the filings do not outright “hallucinate” any case, the citations do not support Campbell’s asserted propositions in the manner she attempts. For example, while Aguilar is a real case from the Southern District of New York (cited above and in the May 14 Order), the discussion at Campbell’s pincites does not say exactly what she represents. Also, her filings miss the mark in describing the import of this Court’s decision in Mancia. These could be viewed as a matter of (im)precision by a self-represented party lacking formal legal training rather than willful misleading or fabrication. In combination with other aspects of Campbell’s filings, they corroborate her admitted use of generative artificial intelligence. ... However, going forward, Campbell must exercise care in any use of generative artificial intelligence tools, to ensure that they do not generate any fictitious cases or, as best as she can determine, incorrect explanations of real cases. She is responsible for ensuring that the legal arguments presented in her filings are accurate and may not misrepresent the law to the Court. Further, the Court cautions that a failure to exercise such care could result in future sanctions, including an award of attorneys’ fees if future filings reflect bad faith or objectively improper arguments or authority.", "ai_tool_named": null, "archive_url": null, "case_name": "Campbell v. TidalHealth, Inc.", "citation": null, "cited_authorities": [ "Aguilar v. Immigration & Customs Enforcement Division, 255 F.R.D. 350 (S.D.N.Y. 2008)", "Mancia v. Mayflower Textile Services Co., 253 F.R.D. 354 (D. Md. 2008)", "Kruglyak v. Home Depot U.S.A., Inc., 774 F. Supp. 3d 755 (W.D. Va. 2025)", "United States v. Malik, 2025 WL 2687413 (D. Md. Sept. 19, 2025)", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the District of Maryland", "court_code": "mdd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-28", "decision_id": "mdd-2026-campbell-v-tidalhealth", "disposition": "The court denied both sides' sanctions requests, partly granted sealing, and cautioned Campbell about future AI-related authority errors.", "docket_number": "1:25-cv-04293-BAH", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff used generative-AI-adjacent tools and filed briefs with imprecise or incorrect descriptions of real cases.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2753/Campbell_v._TidalHealth_USA_28_July_2026.pdf", "state": "MD", "summary": "The District of Maryland denies discovery sanctions in a pro se employment case and addresses possible generative-AI misuse. The court says Campbell’s filings do not outright hallucinate cases but misdescribe Aguilar and Mancia, corroborating admitted tool use, and cautions that future errors may draw fees or sanctions.", "text_sha256": "a22f6323783f0f0ab97ead57e57b6419714156e69a838c90b824da298b0e71ef", "topics": [ "fabricated-citations", "pro-se-ai-use", "discovery-ediscovery" ], "tracker_slug": "campbell-v-tidalhealth-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdd-2026-campbell-v-tidalhealth", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdd-2026-campbell-v-tidalhealth" }, { "ai_passage": "We also sanction petitioner’s attorney Mason Cole for submitting briefs containing false citations and quotations that are the product of artificial intelligence (AI) hallucinations. ... Petitioner’s briefs also contain false case citations. One such case, “Harris v. Illinois Human Rights Comm’n, 2022 IL App (1st) 210454,” does not exist at all. The citation 2022 IL App (1st) 210454-U leads to a criminal case named People v. Riley-Palmer. ... Citations of fictitious legal authority do not automatically justify striking a brief and dismissing an appeal. ... However, we must address petitioner’s attorney’s pattern of presenting multiple fabricated quotes of statutory language and case citations. ... On June 30, 2026, we ordered petitioner’s attorney Mason Cole to file a response explaining the false quotations and citations in his briefs by July 14, 2026. Attorney Cole filed his response on July 2, 2026, 12 days early. His response concedes that all the quotations and citations set out above are false for the reasons we have explained. Attorney Cole states that he “frequently use[s] a premier corporate subscription of ChatGPT” to “synthesize complex matters,” including this case. ... We order attorney Cole to pay a $15,000 fine to the clerk of the Appellate Court, First District, within 30 days of this opinion. ... Attorney Cole’s briefs contain a total of 10 false citations: 4 false statutory quotations, 1 nonexistent case, and 5 cases that exist but do not contain the cited principle or quoted language. This sanction reflects a $1,500 fine for each false citation and quotation. ... The fact that AI hallucinated these citations does not mitigate their falsehood. AI-hallucinated citations are no different than false citations an attorney could create from his own imagination. ... In addition, the clerk of the Appellate Court, First District, shall send a copy of this opinion to the ARDC.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Scott v. Illinois Human Rights Commission", "citation": "2026 IL App (1st) 251462", "cited_authorities": [ "Ill. S. Ct. R. 375", "Ill. S. Ct. R. 341", "Harris v. Illinois Human Rights Comm'n, 2022 IL App (1st) 210454", "People v. Riley-Palmer, 2022 IL App (1st) 210454-U", "In re Baby Boy, 2025 IL App (4th) 241427", "Couvrette, 2025 WL 4109655", "Noland v. Land of the Free, L.P., 336 Cal. Rptr. 5th 426 (Ct. App. 2025)", "Illinois Supreme Court Policy on Artificial Intelligence" ], "court": "Appellate Court of Illinois, First District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-28", "decision_id": "illappct-2026-scott-v-illinois-human-rights-commission", "disposition": "The court affirmed the Commission's dismissal, fined attorney Mason Cole $15,000, and referred the opinion to the ARDC.", "docket_number": "1-25-1462", "document_type": "opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Attorney used ChatGPT in appellate briefing that contained four false statutory quotations, one nonexistent case, and five unsupported case quotations or principles.", "currency": "USD", "monetary_penalty": 15000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0", "reason-volokh" ], "notes": "Official Illinois Courts PDF located through the lead's Reason/Volokh source and fetched/read directly.", "primary_topic": "fabricated-citations", "source_url": "https://ilcourtsaudio.blob.core.windows.net/antilles-resources/resources/23d7df84-ed51-48df-8477-3a6872db40d5/Scott%20v.%20IL%20Human%20Rights%20Commn%202026%20IL%20App%20(1st)%20251462.pdf", "state": "IL", "summary": "The Illinois First District affirms dismissal of Kimberly Scott’s discrimination charge and sanctions attorney Mason Cole. The opinion says ChatGPT produced 10 false citations or quotations, fines Cole $15,000 at $1,500 per misstatement, and directs the clerk to send the opinion to the ARDC.", "text_sha256": "fb4a0924fbb5ef0c42fd86f8cc7d544d05d47bc7f6d74eed68dbb3575acfb20e", "topics": [ "fabricated-citations", "competence-fees", "rules-by-opinion" ], "tracker_slug": "scott-v-illinois-human-rights-commission", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/illappct-2026-scott-v-illinois-human-rights-commission", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illappct-2026-scott-v-illinois-human-rights-commission" }, { "ai_passage": "On July 8, 2026, the Court issued an order to show cause (“OSC”) requiring Plaintiff's counsel, Elizabeth Tate, to show cause why she should not be sanctioned or disciplined for including, in Plaintiff's response to Defendant's motion for attorneys’ fees, two false quotations from Ninth Circuit cases. ... Ms. Tate utilized Claude AI to help her research and prepare the Response ....After Claude prepared a draft brief incorporating the arguments Ms. Tate asked it to make, Ms. Tate entered the following query: ‘Now please make a list of the cited cases for me to review on lexis to make sure I agree with the way you've cited them.’ Claude generated a list of fourteen cases. ... But it appears that instead of reviewing the Claude-generated brief in a thorough line-by-line manner, confirming the accuracy of each citation as it arises during her review of the brief as a whole, Ms. Tate simply asks Claude to list the cases that Claude used when drafting the brief and then uses that list (rather than the brief) for purposes of her verification efforts. ... it does not strike the Court as responsible to allow an AI program to draft an entire brief and then submit that brief, without significant attorney reworking, as the attorney's own work product. Needless to say, Claude is not a licensed attorney permitted to practice law in the District of Arizona. ... Separately, during trial, Ms. Tate filed “Plaintiff's Brief on Impeachment.” (Doc. 124.) That brief contained the following purported quotation from United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001): “Rule 607 permits impeachment by contradiction, or the admission of extrinsic evidence to impeach specific errors or falsehoods in a witness's testimony.” (Id. at 2.) The quoted language, however, does not appear in Antonakeas. ... It appears to the Court that the additional examples identified above may also be attributable to the misuse of generative AI. ... IT IS ORDERED that within 14 days from the date of this order, Ms. Tate shall file a supplemental memorandum, not to exceed 10 pages, addressing the issues raised in this order.", "ai_tool_named": "Claude AI", "archive_url": "https://web.archive.org/web/20260907213502/https://websitedc.s3.amazonaws.com/documents/Michael_L_Ruiz_Plaintiff_v_Magellan_Financial_And_Insurance_Services_Defen_USA_V9gvRhH.pdf", "case_name": "Ruiz v. Magellan Financial & Insurance Services", "citation": "2026 WL 2167989", "cited_authorities": [ "United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001)", "United States v. Osazuwa, 564 F.3d 1169 (9th Cir. 2009)", "Malkeet Lnu v. Blanche, 177 F.4th 1014 (9th Cir. 2026)", "28 U.S.C. § 1924", "State Bar of Arizona, Guidance For The Use of Generative Artificial Intelligence In The Practice Of Law In Arizona (Apr. 22, 2025)" ], "court": "United States District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-28", "decision_id": "azd-2026-ruiz-v-magellan-financial-claude-osc", "disposition": "The court required plaintiff's counsel Elizabeth Tate to file a supplemental memorandum addressing additional possible AI-related quotation errors.", "docket_number": "CV-23-02090-PHX-DWL", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": "Claude AI", "conduct": "Plaintiff’s lawyer used Claude AI to draft filings containing false quotations from Ninth Circuit cases and a fabricated statutory quotation.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2746/Michael_L_Ruiz_Plaintiff_v_Magellan_Financial_And_Insurance_Services_Defen_USA_V9gvRhH.pdf", "state": "AZ", "summary": "The District of Arizona expands an AI show-cause inquiry against Elizabeth Tate. The order recounts Tate’s Claude AI workflow, finds that list-based cite checking missed false quotations in several filings, criticizes delegating whole-brief drafting to Claude, and requires a supplemental memorandum.", "text_sha256": "0f976d8097e013af2f545834265bcadfcddf55286e818a6f149457f6a2fe184c", "topics": [ "fabricated-citations", "competence-fees", "rules-by-opinion" ], "tracker_slug": "ruiz-v-magellan-financial", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azd-2026-ruiz-v-magellan-financial-claude-osc", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-ruiz-v-magellan-financial-claude-osc" }, { "ai_passage": "We conclude by addressing fabricated authority in Ngouambe’s brief to this court. Fabricated authority includes citations to authority that do not exist, quotations that do not appear in the cited authority, and asserted propositions of law not reasonably attributable to the cited authority. Ngouambe’s informal brief contains fabricated authority in the form of three citations to authority that do not exist and numerous asserted propositions of law not reasonably attributable to the cited authority. The submission of incorrect, misleading, or nonexistent content to this, or any other, court is improper, unacceptable, and an abuse of the judicial process. And we do not consider fabricated authority in our evaluation of the merits. Affirmed.", "ai_tool_named": null, "archive_url": null, "case_name": "Ally Bank v. Ngouambe", "citation": null, "cited_authorities": [ "Minn. R. Civ. App. P. 136.01", "State v. Bartylla, 755 N.W.2d 8 (Minn. 2008)", "Schoepke v. Alexander Smith & Sons Carpet Co., 187 N.W.2d 133 (Minn. 1971)" ], "court": "Minnesota Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-27", "decision_id": "mnctapp-2026-ally-bank-v-ngouambe", "disposition": "The court affirmed summary judgment and disregarded fabricated authority in Ngouambe's informal brief.", "docket_number": "A25-1873", "document_type": "opinion", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented appellant filed an informal brief with three nonexistent authority citations and many propositions not reasonably attributable to cited sources.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2744/Ally_Bank_Respondent_vs._Serge_N._Ngouambe_Appellant_USA_July_2026.pdf", "state": "MN", "summary": "The Minnesota Court of Appeals affirms summary judgment for Ally Bank. At the end of the opinion, the court defines fabricated authority, identifies three nonexistent citations and many unsupported legal propositions in Ngouambe’s pro se informal brief, and disregards them when evaluating the merits.", "text_sha256": "6adfa4868a7e536b41d7afce06f06bbfcdd9b37fc8cfe06d420dcf473702493f", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "ally-bank-v-ngouambe", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mnctapp-2026-ally-bank-v-ngouambe", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mnctapp-2026-ally-bank-v-ngouambe" }, { "ai_passage": "Finally, the Court issues a caution about the use of generative artificial intelligence (“AI”). It appears from the briefing that one or both parties may be utilizing AI to draft their briefs. (See, e.g., ECF No. 20, PageID.71 (citing Antoine v. Atlas Turner, Inc., 66 F.3d 105, 110 (6th Cir. 1995) for a quotation and proposition that does not appear at the citation).) The parties should take note: AI cannot give legal advice, and, in many cases, its use in legal research has led to glaring misstatements of law and related sanctions awarded against both attorneys and pro se litigants. “At this point, it ‘is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs.’” Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC, No. 23-11310, 2025 WL 2105286, at *1 (E.D. Mich. July 28, 2025) (Behm, J.) (quoting Sanders v. United States, 176 Fed. Cl. 163, 169 (2025)). AI chatbots “are designed to mimic patterns of words, probabilistically. When they are ‘right,’ it is because correct things are often written down in the dataset they were trained on, not because they can independently fact-check themselves in the same way a human would.” Id. Indeed, French data scientist Damien Charlotin catalogued “at least 490 court filings” between May and October 2025 that contained hallucinations. ... Thus, the use of generative AI when drafting legal filings is a very risky practice, as pro se litigants and attorneys are still subject to the requirements of Fed. R. Civ. P. 11(b)(2) with respect to pleadings, motions and other documents they sign and submit to the Court; even in the absence of bad faith, Rule 11 sanctions for use of AI generated phantom cases may be warranted. ... The parties are HEREBY SO WARNED.", "ai_tool_named": null, "archive_url": null, "case_name": "Ponder v. BCG Equities, LLC", "citation": null, "cited_authorities": [ "Antoine v. Atlas Turner, Inc., 66 F.3d 105 (6th Cir. 1995)", "Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC, 2025 WL 2105286 (E.D. Mich. July 28, 2025)", "Sanders v. United States, 176 Fed. Cl. 163 (2025)", "Ali v. IT People Corp., Inc., 2025 WL 2682622 (E.D. Mich. Sept. 19, 2025)", "Fed. R. Civ. P. 11(b)(2)" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-27", "decision_id": "mied-2026-ponder-v-bcg-equities", "disposition": "The court struck pending motions, set aside default, set a responsive-pleading deadline, and warned both parties about generative AI.", "docket_number": "2:25-13474", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "other", "ai_tool": null, "conduct": "A party cited Antoine for a quotation and proposition that the court says do not appear at the cited source, suggesting possible generative-AI use.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2759/Ponder_v._BCG_Equities_USA_28_July_2026.pdf", "state": "MI", "summary": "The Eastern District of Michigan resets a pro se FCRA case by striking pending motions and setting aside default. The order cautions both sides after a brief cites Antoine for a quotation and proposition not found there, warning that generative-AI phantom cases can trigger Rule 11 sanctions.", "text_sha256": "01dcf1eca82587312e5c8b7049a53d2663b62a801a25e0174e91679e17bcdd32", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "ponder-v-bcg-equities-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-ponder-v-bcg-equities", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-ponder-v-bcg-equities" }, { "decision_id": "in-re-ap-ohio-2026", "case_name": "In re A.P.", "court": "Ohio Court of Appeals, Twelfth Appellate District", "court_code": "ohioctapp", "court_level": "state-appellate", "state": "OH", "date_filed": "2026-07-27", "citation": "2026-Ohio-2862", "docket_number": "CA2025-12-011", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "artificial intelligence", "disposition": "The court affirmed and warned that erroneous AI-assisted citations may be disregarded or sanctioned.", "ai_passage": "Before we consider Father's assignments of error, we first address his acknowledged reliance on artificial intelligence in drafting his brief. We note that several case citations in Father's brief were erroneous in that they led to miscited cases and cases that exist but stand for different legal propositions than what is represented. We remind all parties and attorneys who may appear before our court that false citations not only will be disregarded by this court, but may result in sanctions. Chasteen v. Lynch, 2024-Ohio- 5857, ¶ 50 (12th Dist.). App.R. 16(A)(7) requires that an appellant set forth \"[a]n argument containing the contentions of the appellant with respect to each assignment of error presented for review and the reasons in support of the contentions, with citations to the authorities, statutes, and parts of the record on which the appellant relies.\" Father's status as a pro se litigant does not relieve him of his obligation to comply with the appellate rules because it is well established that pro se litigants are held to the same standard as all other litigants.", "cited_authorities": [ "Chasteen v. Lynch, 2024-Ohio-5857", "Ohio Appellate Rule 16(A)(7)" ], "summary": "The Ohio appellate court pauses before the merits to address a father’s acknowledged AI-assisted brief. The court identifies erroneous citations, reminds parties that false authorities may lead to sanctions, and applies ordinary appellate standards to the self-represented parent.", "lead_source": [ "CourtListener anonymous search pro-se-chatgpt.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10935435/x/", "text_sha256": "df9fdfa386f813494dfd60ac297a3a4428ff1ed72f8dcdd38d5b86e54c7d1124", "source_url": "https://www.supremecourt.ohio.gov/rod/docs/pdf/12/2026/2026-Ohio-2862.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/in-re-ap-ohio-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/in-re-ap-ohio-2026" }, { "decision_id": "wright-ny-2026", "case_name": "People v. Wright", "court": "New York Supreme Court, Appellate Division, Fourth Department", "court_code": "nyappdiv", "court_level": "state-appellate", "state": "NY", "date_filed": "2026-07-24", "citation": "2026 NY Slip Op 04580", "docket_number": "299 KA 23-00567", "document_type": "opinion", "topics": [ "criminal-justice-algorithms" ], "primary_topic": "criminal-justice-algorithms", "court_used_ai": false, "ai_tool_named": "ShotSpotter", "disposition": "The court affirmed the weapon-possession judgment and upheld the suppression ruling.", "ai_passage": "at around 4:30 a.m. on the day in question, the police heard what they perceived—based on their training and experience—to be a gunshot ring out nearby, causing them to immediately respond to that area. While driving to the location, they received a ShotSpotter activation corroborating what they had heard. Arriving at the scene within a minute of hearing the gunshot, the police encountered just two individuals in the area, one of whom was defendant. The police observed that defendant was walking away from the scene, and was attempting to conceal a \"small black object in his right hand,\" which he \"kind of turned, [by] mov[ing] his hand in a manner\" away from the police. One of the responding officers exited his vehicle and told defendant to stop and show his hands, at which point defendant started to run away, causing the police to chase after him in pursuit.", "cited_authorities": [ "People v. Thomas, 34 N.Y.3d 545 (2019)" ], "summary": "The New York appellate court affirms a suppression ruling where officers heard a gunshot and then received a ShotSpotter activation. The opinion treats the activation as corroboration supporting reasonable suspicion for the ensuing pursuit and firearm recovery.", "verification": "mirror-read", "notes": "Official New York reporter page was not reliably downloadable; text was read from CourtListener storage fallback.", "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10937329/x/", "text_sha256": "8b1a2e541e210042acbeb1b616f2019117b67c2a33e1eb329be6f3117254a7b6", "source_url": "http://www.nycourts.gov/reporter/current/3dseries/2026/2026_04580.shtml", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "lead_source": [ "CourtListener anonymous search shotspotter.json" ], "url": "https://safelegalai.com/courts/opinions/wright-ny-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wright-ny-2026" }, { "ai_passage": "In November and December 2025, Plaintiff Joann LeDoux submitted multiple filings containing dozens of inaccurate factual and legal citations which appeared “hallucinated” by a generative artificial intelligence tool. On February 4, 2026, the Court ordered Plaintiff’s counsel, Ms. Jocelyn Stewart, to show cause and explain why she should not be sanctioned for these errors. ... Ms. Stewart filed a sworn declaration on March 4, explaining that she had used two artificial intelligence programs—ChatGPT and Claude—to generate the false citations, that she was unaware of any falsities when she submitted the documents, and that she “accept[s] full responsibility for the errors” and has “changed [her] practices to ensure this does not happen again.” ... On February 4, 2026, the Court found that Ms. Stewart “submitted dozens of inaccurate factual and legal citations across at least five different filings.” These errors included citations to nonexistent sources, as well as fictitious quotations from real sources. Concerningly, two of Plaintiff’s expert reports contained citations to the same nonexistent or misattributed academic articles. ... She avers that she used Claude and ChatGPT to draft her submissions in this case, that these programs generated the false citations identified in the Court’s order, and that she “did not verify the output against the source before filing.” ... Here, Ms. Stewart’s actions warrant significant sanctions. Ms. Stewart submitted dozens of false citations throughout four briefs and two expert reports. ... The Court thus finds that the below sanctions are necessary to address Ms. Stewart’s conduct. The Court ORDERS the following sanctions for violation of Federal Rule of Civil Procedure 11(b): 1. Attorney Jocelyn Stewart is personally sanctioned in the amount of $3,000. ... 2. Ms. Stewart shall include a certification with all subsequent briefing in this case stating that all citations have been verified and accurately reflect the propositions put forth. 3. Ms. Stewart shall provide a copy of this order to Plaintiff Joann LeDoux and file a certification with the Court that she has done so no later than July 28, 2026.", "ai_tool_named": "ChatGPT and Claude", "archive_url": null, "case_name": "LeDoux v. Outliers, Inc.", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11(b)", "Washington State Bar Association Advisory Opinion 202505", "Chaney v. Transdev Services Inc., 2026 WL 1146736 (C.D. Cal. Apr. 28, 2026)", "Gerke v. Travelers Casualty Insurance Co. of America, 289 F.R.D. 316 (D. Or. 2013)", "Parker, 2025 WL 4228413" ], "court": "United States District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-24", "decision_id": "wawd-2026-ledoux-v-outliers-sanctions", "disposition": "The court sanctioned attorney Jocelyn Stewart $3,000 and required citation certifications after unverified ChatGPT and Claude outputs.", "docket_number": "3:24-cv-05808-TMC", "document_type": "order", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT and Claude", "conduct": "Plaintiff’s counsel used ChatGPT and Claude to generate dozens of false citations and citation tables in briefs and expert reports without verification.", "currency": "USD", "monetary_penalty": 3000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2706/Ledoux_v._Outliers_USA_24_July_2026.pdf", "state": "WA", "summary": "The Western District of Washington sanctions Jocelyn Stewart in the LeDoux litigation. The order finds Stewart used ChatGPT and Claude without verifying outputs, causing dozens of false citations across briefs and expert reports, and imposes a $3,000 personal sanction plus future citation certifications.", "text_sha256": "734eb1fc4bdd05d0844f13e2a7e48c98b8d4108c5f4ae332df4294dfc2c2c5ee", "topics": [ "fabricated-citations", "evidence-authentication", "competence-fees" ], "tracker_slug": "ledoux-v-outliers", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wawd-2026-ledoux-v-outliers-sanctions", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-ledoux-v-outliers-sanctions" }, { "ai_passage": "Plaintiff cites to Boling v. Pub. Utils. Comm'n, 105 Cal.App.3d 805 (1980) and Loving v. Cnty. of Stanislaus, 33 Cal.App.5th 444 (2019), which are not real cases. Plaintiff also cites to Pierce v. Cnty. of Orange, 526 F.3d 1190 (9th Cir. 2008), which does not discuss statute of limitations or continuing violation issues. At the hearing on these motions, the undersigned admonished Plaintiff about the danger of using Artificial Intelligence tools for legal research and writing and Plaintiff's obligation to ensure that all legal citations are legitimate. Future citations to non-existent cases may subject Plaintiff to an order to show cause as to why she should not be sanctioned under Rule 11 of the Federal Rules of Civil Procedure. ... IT IS HEREBY ORDERED that: 1. Plaintiff's motions to e-file (ECF Nos. 4 & 21) are DENIED. ... IT IS HEREBY RECOMMENDED that: 1. Defendants’ motion to dismiss (ECF No. 5) be GRANTED; 2. Plaintiff's motion for leave to amend (ECF No. 14) be GRANTED and Plaintiff allowed 21 days to file a First Amended Complaint.", "ai_tool_named": null, "archive_url": null, "case_name": "Graves v. Pacific Gas & Electric Co.", "citation": "2026 WL 2138081", "cited_authorities": [ "Boling v. Public Utilities Commission, 105 Cal.App.3d 805 (1980)", "Loving v. County of Stanislaus, 33 Cal.App.5th 444 (2019)", "Pierce v. County of Orange, 526 F.3d 1190 (9th Cir. 2008)", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Eastern District of California", "court_code": "caed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-07-24", "decision_id": "caed-2026-graves-v-pacific-gas-electric", "disposition": "The magistrate judge recommended dismissal with leave to amend, granted leave to amend, denied e-filing, and warned Graves about nonexistent cases.", "docket_number": "2:25-cv-02558-DC-SCR", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T15:05:00-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "Self-represented plaintiff cited two nonexistent California cases and mischaracterized Pierce on limitations and continuing-violation issues.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2704/Graves_v._PGE_USA_24_July_2026.pdf", "state": "CA", "summary": "The Eastern District of California recommends dismissing Graves’s utility-pole claims with leave to amend and denies e-filing. A footnote identifies two nonexistent California cases, notes that Pierce does not support the cited limitations point, and warns about AI research and Rule 11 sanctions.", "text_sha256": "8325b7cb3646bd5832683b52bf153ee839bab0fa1f751c5b3b5c767e0951f359", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "graves-v-pacific-gas-electric-co", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/caed-2026-graves-v-pacific-gas-electric", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/caed-2026-graves-v-pacific-gas-electric" }, { "ai_passage": "It is not acceptable to submit filings to the Court containing false, misleading, or nonexistent quotations or authorities. Such conduct contravenes an attorney’s duty toward their client to exercise professional judgment and responsibility. See Park v. Kim, 91 F.4th 610, 614 (2d Cir. 2024). In particular, Rule 11(b)(2) of the Federal Rules of Civil Procedure provides that “[b]y presenting to the court a pleading, written motion, or other paper,” an attorney “certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . the claims, defenses, and other legal contentions are warranted by existing law . . . .” Fed. R. Civ. P. 11(b)(2). Furthermore, Rule 3.3(a)(1) of the District of Columbia Rules of Professional Conduct provides that an attorney “shall not knowingly . . . [m]ake a false statement of fact or law to a tribunal.” D.C. R. Pro. Conduct 3.3(a)(1). The Court agrees with the Second Circuit that, at minimum, such rules “require that attorneys read, and thereby confirm the existence and validity of, the legal authorities on which they rely.” Park, 91 F.4th at 615. Courts have taken diverse disciplinary actions against attorneys who have filed pleadings and other court papers citing nonexistent legal authorities and quotations, ranging from striking the pleadings, see, e.g., Grant v. City of Long Beach, 96 F.4th 1255, 1256–57 (9th Cir. 2024); to ordering counsel to show cause why sanctions should not issue, see, e.g., Mata v. Avianca, Inc., No. 22-cv-1461, 2023 WL 3696209, at *1 (S.D.N.Y. May 4, 2023); and referring counsel to a court’s grievance panel, see, e.g., Park, 91 F.4th at 612. At this juncture, however, it would be premature for the Court to find that anything improper was done in the preparation of the opposition brief, and the Court makes no such finding at this time. After all, counsel for Ms. Porfirio has had no opportunity to address the Court’s concerns. And the Court will not open an inquiry into the brief’s preparation at this time because, as explained above, it is transferring this case to another district and will leave to the sound judgment of the transferee court how to handle the matter. But the Court notes that the brief’s citation to nonexistent quotations and cases as well as its misstatements of law bear the hallmarks of reliance on an artificial intelligence tool.", "ai_tool_named": "artificial intelligence tool", "archive_url": null, "case_name": "Almeida Porfirio v. Mullin", "citation": null, "cited_authorities": [ "Park v. Kim, 91 F.4th 610 (2d Cir. 2024)", "Fed. R. Civ. P. 11(b)(2)", "D.C. Rule of Professional Conduct 3.3(a)(1)", "Grant v. City of Long Beach, 96 F.4th 1255 (9th Cir. 2024)", "Mata v. Avianca, Inc., No. 22-cv-1461, 2023 WL 3696209 (S.D.N.Y. May 4, 2023)", "Williams v. Capital One Bank, N.A., No. 24-cv-2032, 2025 WL 843285 (D.D.C. Mar. 18, 2025)" ], "court": "United States District Court for the District of Columbia", "court_code": "dcd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10934363/almeida-porfirio-v-noem/", "date_filed": "2026-07-23", "decision_id": "dcd-2026-almeida-porfirio-v-mullin", "disposition": "The court transferred the visa-denial action to the Northern District of Texas and noted possible AI-related citation defects in plaintiff’s opposition brief.", "docket_number": "25-4055 (RC)", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "lawyer", "ai_tool": "artificial intelligence tool", "conduct": "Plaintiff’s counsel filed an opposition brief with nonexistent quotations, nonexistent cases and legal misstatements that the court said bore the hallmarks of reliance on an AI tool.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official D.D.C. ECF download URL was robots-disallowed; read the public-domain court PDF from CourtListener storage. The caption substituted Markwayne Mullin for Kristi Noem.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/pdf/2026/07/23/almeida_porfirio_v._noem.pdf", "state": "DC", "summary": "The District of Columbia district court transfers Catarina Almeida Porfirio’s visa case to the Northern District of Texas. The court says plaintiff’s opposition brief contains nonexistent quotations, nonexistent cases and misstatements of law bearing the hallmarks of reliance on an AI tool, but leaves any inquiry to the transferee court.", "text_sha256": "5f311916de79002142b6d1a099119862dfd771a503467e461190efa96dcbc2ac", "topics": [ "fabricated-citations" ], "tracker_slug": "almeida-porfirio-v-mullin", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/dcd-2026-almeida-porfirio-v-mullin", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/dcd-2026-almeida-porfirio-v-mullin" }, { "decision_id": "sherwin-iowa-2026", "case_name": "Sherwin v. State of Iowa, Department of Criminal Investigation", "court": "Iowa Court of Appeals", "court_code": "iowactapp", "court_level": "state-appellate", "state": "IA", "date_filed": "2026-07-22", "citation": null, "docket_number": "25-0992", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "Chat GPT", "disposition": "The court affirmed dismissal and rejected the pro se litigants’ request to require AI-use certification by defendants.", "ai_passage": "the district court properly denied the Sherwins’ request to strike the defendants’ motions to dismiss because they did not certify whether they used “generative artificial intelligence” in their drafting. True, “self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.” Luke v. Dep’t of Health & Hum. Servs., 29 N.W.3d 635, 636 (Iowa Ct. App. 2025). But nothing about the State’s citation to Benskin in its trial brief breached that duty. Even if the citation form was incomplete, the case was neither hallucinated nor “suspicious.” What’s more, the State cited the case for the familiar proposition that “[m]otions to dismiss are disfavored.” Benskin, 952 N.W.2d at 296. Thus, the district court did not act with prejudice by refusing to require the defendants to disclose any use of artificial intelligence.", "cited_authorities": [ "Luke v. Iowa Dep’t of Health & Human Services, 29 N.W.3d 635 (Iowa Ct. App. 2025)" ], "summary": "The Iowa Court of Appeals rejects self-represented plaintiffs’ attempt to strike opposing motions because defendants did not certify whether they used ChatGPT or other AI. The court says no disclosure rule was shown and AI-assisted research or drafting is not inherently improper.", "lead_source": [ "CourtListener anonymous search pro-se-chatgpt.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10933934/x/", "text_sha256": "cc72dddb5a42e0fa29d7d8b04ad9ad0d03be882a203dc558c3db77c44517aa17", "source_url": "https://www.iowacourts.gov/courtcases/26743/embed/CourtAppealsOpinion", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/sherwin-iowa-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/sherwin-iowa-2026" }, { "ai_passage": "This case demonstrates a growing problem in Florida’s appellate courts. The recent change in jurisdiction has given intermediate appellate courts jurisdiction to hear appeals from county court cases. The result has been that the amount of pro se appeals has significantly increased. Initially, the appellate courts were able to expeditiously handle the county court appeals.\n\nRecently, however, it appears that many pro se litigants, in both county and circuit courts, are using artificial intelligence platforms to generate appellate briefs and motions. While the prose in these filings is generally readable, many AI-generated submissions contain phantom authority, misstatements of the record, and fabricated quotations. Pro se litigants are not governed by the ethical rules with which licensed attorneys must comply. Because a principled appellate court must examine the issues raised by the parties, digging into AI-generated filings consumes valuable time that could be better spent on other cases.\n\nWe have observed:\n\n“The submission of fictitious or fabricated case law—whether the product of carelessness, misunderstanding, or reliance on generative artificial-intelligence tools—is sanctionable.” Francois v. Vive Fin., LLC, 51 Fla. L. Weekly D500 (Fla. 4th DCA Mar. 18, 2026); see also Goya v. Hayashida, 418 So. 3d 652, 656 (Fla. 4th DCA 2025); Gutierrez v. Gutierrez, 399 So. 3d 1185, 1188 (Fla. 3d DCA 2024). This includes citations to cases that do not stand for what is argued.\n\nGouldy’s arguments in this appeal are either unpreserved, inadequately briefed, or wholly meritless. She raised fifteen issues, some with sub-issues. To the extent any of her issues may contain a shred of arguable merit (e.g., the unpreserved apportionment argument), they are swamped by the sea of frivolous arguments that dominate her initial brief. Her initial brief cites a nonexistent case, misrepresents the record, fabricates multiple quotations from actual legal decisions, and otherwise relies upon cases that do not support the propositions for which they are cited.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260727022055id_/https://flcourts-media.flcourts.gov/content/download/2492735/opinion/Opinion_2025-1289.pdf", "case_name": "Gouldy v. Chiasson", "citation": null, "cited_authorities": [ "Francois v. Vive Fin., LLC, 51 Fla. L. Weekly D500 (Fla. 4th DCA Mar. 18, 2026)", "Goya v. Hayashida, 418 So. 3d 652 (Fla. 4th DCA 2025)", "Gutierrez v. Gutierrez, 399 So. 3d 1185 (Fla. 3d DCA 2024)" ], "court": "District Court of Appeal of Florida, Fourth District", "court_code": "fladistctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10933819/rose-lannquist-gouldy-v-timothy-michael-chiasson/", "date_filed": "2026-07-22", "decision_id": "fladistctapp-2026-gouldy-v-chiasson", "disposition": "The court affirmed the fee order and issued a separate order to show cause why Gouldy should not be barred from further pro se filings.", "docket_number": "4D2025-1289", "document_type": "opinion", "fetched_at": "2026-09-07T21:10:00Z", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "A pro se appellant filed an appellate brief with a phantom case, record misstatements, fabricated quotations, and authorities that did not support the propositions asserted.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official Florida media host did not resolve from this environment; the official PDF was read from the Wayback snapshot listed in archive_url.", "primary_topic": "fabricated-citations", "source_url": "https://flcourts-media.flcourts.gov/content/download/2492735/opinion/Opinion_2025-1289.pdf", "state": "FL", "summary": "The Florida Fourth District Court of Appeal affirms a fee order against Rose Gouldy and separately orders her to show cause why she should not be barred from further pro se filings. The court says her brief uses phantom authority, record misstatements and fabricated quotations likely produced with AI.", "text_sha256": "cb37654f536824000377bc52caec4a3a75384a888c7444957181384b815cdacc", "topics": [ "fabricated-citations" ], "tracker_slug": "gouldy-v-chiasson", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp-2026-gouldy-v-chiasson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp-2026-gouldy-v-chiasson" }, { "decision_id": "figueroa-hernandez-fl-2026", "case_name": "Figueroa Hernandez v. State", "court": "Florida Third District Court of Appeal", "court_code": "fladistctapp", "court_level": "state-appellate", "state": "FL", "date_filed": "2026-07-22", "citation": null, "docket_number": "3D2024-1368", "document_type": "opinion", "topics": [ "criminal-justice-algorithms" ], "primary_topic": "criminal-justice-algorithms", "court_used_ai": false, "ai_tool_named": "STRmix", "disposition": "The court affirmed the conviction and rejected challenges to DNA evidence and other trial rulings.", "ai_passage": "Defense DNA expert Tiffany Roy disputed the reliability of the State’s testing procedures. Roy testified that Miami-Dade’s crime lab should have updated to a new genotyping software (for example, STRmix), which is better suited for mixed profiles and profiles with low-grade DNA, both of which occurred here. Roy testified that the crime lab’s manual method relies too much on the analyst’s view of the DNA, yielding uncertainty in the tested locations. With low-grade DNA, the manual method may be inadequate to determine “stochastic” effects (random distortions) in the DNA sample. ... On April 4, 2023, the trial court conducted a Daubert hearing to address two defense motions in limine: (i) to suppress the State’s forensic DNA report; and (ii) to prevent the State from referring to its serology test as a “saliva presumptive test.” The trial court’s May 26, 2023 Daubert order denied both motions.", "cited_authorities": [ "Daubert", "Kemp v. State, 280 So. 3d 81 (Fla. 4th DCA 2019)" ], "summary": "The Florida appellate court discusses expert testimony comparing manual DNA interpretation with STRmix probabilistic genotyping. The court affirms after reviewing a Daubert hearing and the defense argument that newer software better suited mixed, low-level DNA profiles.", "lead_source": [ "CourtListener anonymous search forensic-software.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10933758/x/", "text_sha256": "403061fd4f37d9b1cb8c3d8c85fc7ad561c52920d96ffc1fecec263c9df2c093", "source_url": "https://flcourts-media.flcourts.gov/content/download/2492720/opinion/Opinion_2024-1368.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/figueroa-hernandez-fl-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/figueroa-hernandez-fl-2026" }, { "decision_id": "lampinen-ohio-2026", "case_name": "Lampinen v. Borer", "court": "Ohio Court of Appeals, Eleventh Appellate District", "court_code": "ohioctapp", "court_level": "state-appellate", "state": "OH", "date_filed": "2026-07-20", "citation": "2026-Ohio-2769", "docket_number": "2025-L-134", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "artificial intelligence tools", "disposition": "The court affirmed dismissal and declined to impose sanctions while cautioning all litigants.", "ai_passage": "Such a practice is suggestive of an improper reliance on artificial intelligence tools and does not represent a good-faith effort to make a coherent argument. {¶21} This court has previously found the imposition of sanctions to be warranted for the misuse of artificial intelligence. See generally State v. Coleman, 2026-Ohio-965 (11th Dist.). However, recognizing that such power should be exercised with “restraint and discretion” we decline to do so in this instance. Chambers v. NASCO, Inc., 501 U.S. 32, 44 (1991). However, all litigants, regardless of their pro se status, are hereby cautioned that a lack of candor in their briefing may lead to sanctions.", "cited_authorities": [ "State v. Coleman, 2026-Ohio-965", "Chambers v. NASCO, Inc., 501 U.S. 32 (1991)" ], "summary": "The Ohio appellate court sees signs that a self-represented brief relied improperly on AI tools, but it declines sanctions. The court cautions that lack of candor may be sanctionable and refuses to construct arguments for the appellant.", "lead_source": [ "CourtListener anonymous search pro-se-chatgpt.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10933088/x/", "text_sha256": "c7cabb72f8c57608cf82f173b63e8864957590be5b2fa9fab6106c8ce96b7b63", "source_url": "https://www.supremecourt.ohio.gov/rod/docs/pdf/11/2026/2026-Ohio-2769.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/lampinen-ohio-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/lampinen-ohio-2026" }, { "court_code": "ca3", "state": null, "citation": null, "docket_number": "26-1313", "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "7ae67199019b219dff6b8853a07557981f394cba4c4f2ddb24baa6ede8016705", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": null, "decision_id": "ca3-2026-bryan-v-city-of-philadelphia", "case_name": "Bryan v. City of Philadelphia", "court": "U.S. Court of Appeals for the Third Circuit", "court_level": "federal-appellate", "date_filed": "2026-07-17", "document_type": "opinion", "topics": [ "evidence-authentication" ], "primary_topic": "evidence-authentication", "court_used_ai": false, "disposition": "The court affirmed dismissal of Bryan’s civil-rights complaint.", "ai_passage": "Bryan filed this civil rights action under 42 U.S.C. § 1983. He alleges that the City of Philadelphia, Philadelphia Police Department, some of its officers, the Philadelphia District Attorney Office, the Philadelphia District Attorney, and various Assistant District Attorneys violated his civil rights in conjunction with a 2022 arrest and 2023 prosecution. According to Bryan, during his arrest the arresting officer pinned him to a truck, threw him to the ground, tased him, and never read him Miranda rights. The arresting officer manipulated body camera footage using artificial intelligence, body camera footage for all other on-scene officers was also altered, dash camera footage went “missing,” and footage that played in court was altered to remove scenes. Philadelphia police officers covered up this misconduct and conspired with attorneys at the District Attorney’s Office to falsely charge Bryan. The District Attorney, Larry Krasner, approved the charges despite knowing that video footage and the police report were fabricated. An Assistant District Attorney forced him to answer questions regarding the fabricated footage and report. His counsel’s requests for original body camera footage and footage from surrounding video cameras were denied in violation of Brady v. Maryland, undermining his ability to put on an adequate defense.", "cited_authorities": [ "42 U.S.C. § 1983", "Brady v. Maryland", "Heck v. Humphrey, 512 U.S. 477 (1994)" ], "summary": "On 2026-07-17, the Third Circuit affirms dismissal of a civil-rights suit alleging police and prosecutors fabricated or altered body-camera footage with artificial intelligence. The court holds the appeal forfeited and, alternatively, agrees that Heck, limitations, and other grounds bar the claims.", "source_url": "https://www2.ca3.uscourts.gov/opinarch/261313np.pdf", "verification": "fetched-and-read", "lead_source": [ "user lead", "court site search" ], "url": "https://safelegalai.com/courts/opinions/ca3-2026-bryan-v-city-of-philadelphia", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca3-2026-bryan-v-city-of-philadelphia" }, { "ai_passage": "NOTE ON THE USE OF ARTIFICIAL INTELLIGENCE The Webbs refer to various court rules in their motion to support their request to supplement the record. While the rules the Webbs cite do exist, they plainly do not stand for any of the propositions that the Webbs advance. This leads the Court to believe that the Webbs used generative AI in producing their Motion to Supplement the Record. The Court recognizes the benefits of generative AI, especially for self-represented parties like the Webbs, and does not wish to dissuade its responsible use. But that does not relieve attorneys and self-represented litigants of their duty to independently verify the authenticity and accuracy of authoritative sources cited to the Court. Courts “must be able to rely on the authenticity of the authorities cited by the parties to make just decisions.” Williams v. Kirch, 268 N.E.3d 284, 288 (Ind. Ct. App. 2025). Generative AI tools are not reliable for legal citation and “frequently generate fictitious case names and citations.” Wilcox v. Gingrinch, 274 N.E.3d 1269, 1277 (Ind. Ct. App. 2026). Even when such tools do cite authentic cases, they frequently mischaracterize their meaning or essential holdings. See, e.g., Sanders v. United States, 176 Fed. Cl. 163, 170 (Fed. Cl. 2025) (“AI programs can generate fake case citations and other legal misstatements.”). While this technology will undoubtedly be refined and improved in the course of time, litigants must continue to exercise care to ensure that the information gleaned from such sources is reliable and accurate. Accordingly, the Court admonishes the Webbs for failing to confirm the accuracy of their legal presentations but will impose no further penalties.", "ai_tool_named": "generative AI", "archive_url": null, "case_name": "Webb v. Sullivan County Assessor", "citation": null, "cited_authorities": [ "Williams v. Kirch, 268 N.E.3d 284 (Ind. Ct. App. 2025)", "Wilcox v. Gingrinch, 274 N.E.3d 1269 (Ind. Ct. App. 2026)", "Sanders v. United States, 176 Fed. Cl. 163 (Fed. Cl. 2025)" ], "court": "Indiana Tax Court", "court_code": "indtc", "court_level": "other", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10933516/chryshawna-a-webb-v-sullivan-county-assessor/", "date_filed": "2026-07-16", "decision_id": "indtc-2026-webb-v-sullivan-county-assessor", "disposition": "The court denied the Webbs’ motion to supplement the certified record and admonished them for unverified AI-assisted legal presentations.", "docket_number": "25T-TA-00029", "document_type": "order", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "litigant-in-person", "ai_tool": "generative AI", "conduct": "Self-represented petitioners cited real court rules for propositions those rules did not support, leading the court to believe generative AI was used without verification.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official Indiana Decisions API download timed out from this environment; read the public-domain court PDF from CourtListener storage.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/pdf/2026/07/16/chryshawna_a_webb_v._sullivan_county_assessor.pdf", "state": "IN", "summary": "The Indiana Tax Court denies Chryshawna and Jeremy Webb’s pro se motion to supplement an administrative tax record. In a note on artificial intelligence, the court says cited rules did not support the Webbs’ propositions, admonishes them for likely generative-AI use, and imposes no further penalties.", "text_sha256": "48196cea001ce92316fe33aa6d10464279ae27c9920dd381e0f93302c4515a29", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "webb-v-sullivan-county-assessor", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/indtc-2026-webb-v-sullivan-county-assessor", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/indtc-2026-webb-v-sullivan-county-assessor" }, { "decision_id": "pangelinan-guam-2026", "case_name": "In re Estate of Pangelinan", "court": "Supreme Court of Guam", "court_code": "guam", "court_level": "state-supreme", "state": "GU", "date_filed": "2026-07-15", "citation": "2026 Guam 5", "docket_number": "CVA25-007", "document_type": "opinion", "topics": [ "pro-se-ai-use" ], "primary_topic": "pro-se-ai-use", "court_used_ai": false, "ai_tool_named": "generative artificial intelligence", "disposition": "The court affirmed in part and reversed in part while declining sanctions for two possible AI-attributed citations.", "ai_passage": "In Schacher’s opening brief, two nonexistent citations may be attributed to generative artificial intelligence use. See Appellant’s Am. Br. at 15 (June 30, 2025). We do not find sanctions warranted, considering Schacher’s pro se status and this being his initial appearance before the court. However, we reiterate that “[i]t is the responsibility of attorneys, judges, and self-represented litigants to ensure the integrity of their final submissions.” Re: Adoption of the Judiciary of Guam Policy on Artificial Intelligence, ADM25-001, Ex. A (Admin. Order No. ADM25-001, Apr. 30, 2025).", "cited_authorities": [ "Re: Adoption of the Judiciary of Guam Policy on Artificial Intelligence, ADM25-001" ], "summary": "The Supreme Court of Guam observes that two nonexistent citations in a self-represented probate appellant’s brief may be attributable to generative AI. Considering pro se status and a first appearance, it finds sanctions unwarranted but reiterates final-submission duties.", "lead_source": [ "CourtListener anonymous search pro-se-ai.json" ], "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10931852/x/", "text_sha256": "1ff1924668c89780e2e4c4a0914aa608f90ca51810aa3b5e354a952a1f1c7195", "source_url": "https://guamcourts.gov/sites/default/files/SupremeCourtOpinions/2026%20Guam%205.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/pangelinan-guam-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pangelinan-guam-2026" }, { "ai_passage": "The FDOC has moved for sanctions under Federal Rule of Appellate Procedure 27 and our inherent authority, seeking attorney’s fees and to strike portions of Parnell’s reply brief. The FDOC argues that Parnell’s reply brief cites two non-existent court opinions and at least five non-existent quotations from our opinions. Parnell responds that he withdraws any erroneous statements in his reply brief, which renders the FDOC’s motion “moot.” He argues that the errors were not made in bad faith and his reply brief’s arguments are still legally correct.\n\nWe ordered supplemental briefing to provide Parnell’s counsel the opportunity to explain where the defective cases and quotes came from, but counsel merely repeats that he has been unable to identify a verified source with the non-existent opinions and that “the challenged material did not come from a verified review of the cited opinions.” Counsel does not provide an explanation for how the opinions appeared in the reply brief.\n\nWe are disappointed with counsel’s lack of forthcoming candor. Courts around the world currently face a well-publicized problem of attorneys citing hallucinated authorities. See Damien Charlotin, AI Hallucination Cases, https://perma.cc/U84C-WGA7 (last visited May, 22, 2026) (listing over 1000 judicial decisions dealing with AI hallucinations). Presumably, counsel wrote the reply brief, and should thus be familiar with how he came to rely on the nonexistent authorities. Whether the appellant’s citations were generated by AI, as we suspect, or simply made up by counsel, we nevertheless expect accurate representations from any attorney appearing before this Court.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907210335/https://media.ca11.uscourts.gov/opinions/pub/files/202511166.pdf", "case_name": "Parnell v. Florida Department of Corrections", "citation": null, "cited_authorities": [ "Federal Rule of Appellate Procedure 27", "Damien Charlotin, AI Hallucination Cases, https://perma.cc/U84C-WGA7", "11th Cir. R. 27-4", "Purchasing Power, LLC v. Bluestem Brands, Inc., 851 F.3d 1218 (11th Cir. 2017)" ], "court": "United States Court of Appeals for the Eleventh Circuit", "court_code": "ca11", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10932237/marion-parnell-jr-v-florida-department-of-corrections/", "date_filed": "2026-07-10", "decision_id": "ca11-2026-parnell-v-florida-doc", "disposition": "The court affirmed summary judgment, struck portions of Parnell's reply brief, awarded FDOC fees for the sanctions motion, and referred counsel for discipline.", "docket_number": "25-11166", "document_type": "opinion", "fetched_at": "2026-09-07T21:10:00Z", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a reply brief citing two non-existent court opinions and at least five non-existent quotations from Eleventh Circuit opinions.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "The court reserved jurisdiction to set the amount of attorney fees.", "primary_topic": "fabricated-citations", "source_url": "http://media.ca11.uscourts.gov/opinions/pub/files/202511166.pdf", "state": null, "summary": "The Eleventh Circuit affirms summary judgment for the Florida Department of Corrections and grants sanctions relief against Parnell’s counsel. The court strikes defective reply-brief material, awards fees for the sanctions motion, and refers counsel after finding two non-existent opinions and at least five non-existent quotations.", "text_sha256": "229d190eb592dcba2aef7660d507bca217b14f94d62ff527e6d178f102e36e8e", "topics": [ "fabricated-citations" ], "tracker_slug": "parnell-v-florida-doc", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/ca11-2026-parnell-v-florida-doc", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca11-2026-parnell-v-florida-doc" }, { "ai_passage": "Though the filings in this case were substandard in a variety of ways, we have saved the worst for last. The plaintiffs’ counsel Anthony F. Sabatini’s filings are riddled with citations to nonexistent, “hallucinated” cases. His opening brief relies on at least eight such cases, including one purportedly decided by this Court. After the defendants identified this problem, Sabatini acknowledged in his (untimely) proposed reply brief that those citations were “erroneous or unverifiable,” and sought to withdraw his reliance on eight listed cases. At this point, things go from bad to worse: the eight cases Sabatini “withdrew” did not match a single one of the eight hallucinated cases in his opening brief. And not only were they not the right cases—all eight were also hallucinated.\n\nWe are far from the first court to see lawyers uncritically rely on artificial intelligence software and submit briefs citing nonexistent cases. See Chief Justice John G. Roberts, Jr., 2023 Year-End Report on the Federal Judiciary, at 5–6 (2023). The typical response when this kind of violation is identified is some version of an apology from the attorney, often with sanctions to follow. It is rare to see the kind of blatant and repeated misconduct that Sabatini has committed in this case.\n\nWhatever the merits of artificial intelligence, it is no substitute for actual intelligence. Any “use of AI requires caution and humility.” Roberts, 2023 Year-End Report on the Federal Judiciary, at 5. When lawyers rely on AI tools, there is no way to get around the obligation to verify that the software got it right, and that what it got wrong will not end up in court filings.", "ai_tool_named": null, "archive_url": "https://web.archive.org/web/20260907210341/https://media.ca11.uscourts.gov/opinions/pub/files/202411033.pdf", "case_name": "Akerlund v. Atlas Air, Inc.", "citation": null, "cited_authorities": [ "Chief Justice John G. Roberts, Jr., 2023 Year-End Report on the Federal Judiciary", "A.B.A. Committee on Ethics & Professional Responsibility, Formal Opinion 512", "Model Rules of Professional Conduct Rule 1.1" ], "court": "United States Court of Appeals for the Eleventh Circuit", "court_code": "ca11", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10925376/estate-of-lane-caviness-v-atlas-air-inc/", "date_filed": "2026-07-10", "decision_id": "ca11-2026-akerlund-v-atlas-air", "disposition": "The court affirmed dismissal of the complaint and referred attorney Anthony F. Sabatini to the Eleventh Circuit Committee on Lawyer Qualifications and Conduct.", "docket_number": "24-11033", "document_type": "opinion", "fetched_at": "2026-09-07T21:10:00Z", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Plaintiffs’ counsel filed an opening brief and proposed reply brief containing repeated nonexistent, hallucinated case citations after opposing counsel identified the problem.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": null, "primary_topic": "fabricated-citations", "source_url": "http://media.ca11.uscourts.gov/opinions/pub/files/202411033.pdf", "state": null, "summary": "The Eleventh Circuit affirms dismissal of claims against Atlas Air and Flight Services International while referring plaintiffs’ counsel Anthony F. Sabatini for discipline. The court says his opening and proposed reply briefs contained repeated hallucinated case citations and that unverified AI-generated briefing violated duties to clients and the court.", "text_sha256": "16d82e33609f29f1614da106f31294b6411c01d95737d773c20341eecdef3d57", "topics": [ "fabricated-citations" ], "tracker_slug": "akerlund-v-atlas-air", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/ca11-2026-akerlund-v-atlas-air", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca11-2026-akerlund-v-atlas-air" }, { "ai_passage": "We affirm the orders on appeal without comment. We write, however, to caution Cynthia Hulse-Gibson about using generative AI in any future pro se filings without verifying the accuracy of the results. Hulse-Gibson's briefs here are replete with mismatches involving the purported legal proposition, the case name, and the reporter citation. See Fletcher v. Experian Info. Sols., Inc., 168 F.4th 231, 233 (5th Cir. 2026) (\"This problem [the misuse of generative AI] now often manifests as false quotes or statements of law attributed to real cases, rather than the more easily recognizable fake cases.\"). Those who use generative AI to assist with legal research and brief writing must exercise special care to validate the results before signing and filing their briefs; their failure to do so exposes them to potential sanctions.", "ai_tool_named": "generative AI", "archive_url": null, "case_name": "Hulse-Gibson v. Hulse", "citation": null, "cited_authorities": [ "Fletcher v. Experian Information Solutions, Inc., 168 F.4th 231 (5th Cir. 2026)", "Fla. R. Gen. Prac. & Jud. Admin. 2.515(d)(2)", "Gleason v. Marcus, 51 Fla. L. Weekly D962 (Fla. 2d DCA May 13, 2026)", "Gutierrez v. Gutierrez, 399 So. 3d 1185 (Fla. 3d DCA 2024)" ], "court": "District Court of Appeal of Florida, Second District", "court_code": "fladistctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10918387/hulse-gibson-v-hulse/", "date_filed": "2026-07-08", "decision_id": "fladistctapp-2026-hulse-gibson-v-hulse", "disposition": "The court affirmed without comment and cautioned Cynthia Hulse-Gibson to verify generative-AI-assisted pro se filings.", "docket_number": "2D2025-1144", "document_type": "opinion", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "litigant-in-person", "ai_tool": "generative AI", "conduct": "A self-represented appellant filed briefs with mismatches among legal propositions, case names and reporter citations after apparent generative-AI use.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official Florida media host did not resolve from this environment; read the public-domain court PDF from CourtListener storage.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/pdf/2026/07/08/hulse-gibson_v._hulse.pdf", "state": "FL", "summary": "The Florida Second District Court of Appeal affirms orders against Cynthia Hulse-Gibson without comment. The panel separately cautions the self-represented appellant that her briefs contained mismatches among propositions, case names and citations, and warns that unverified generative-AI legal research can expose filers to sanctions.", "text_sha256": "e1032a3cb8e9a5b2d8c80b1aaa96f13ae0384ec274bdb94e680bb4839d8e28e8", "topics": [ "fabricated-citations", "pro-se-ai-use" ], "tracker_slug": "hulse-gibson-v-hulse", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp-2026-hulse-gibson-v-hulse", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp-2026-hulse-gibson-v-hulse" }, { "ai_passage": "GenAI offers a powerful tool to streamline legal practice and assist in advocacy. Using GenAI in preparing court filings is “not inherently problematic”—provided the attorney (or litigant) carefully verifies the accuracy of the output. Here, counsel acknowledges that the GenAI output was not verified before the Answering Brief was filed.\n\nThe submission of hallucinated legal propositions raises an inference of a Rule 11(b) violation, requiring counsel to show cause why sanctions should not issue. A fictitious citation is not “existing law.” The duty of candor to the court, and the obligation to conduct a reasonable inquiry under Rule 11, are nondelegable. Counsel cannot discharge those obligations by relying on a paralegal, much less on an artificial intelligence program.\n\nHere, the concerns raised by the initial filing were compounded by counsel’s response after the errors were identified. In correcting the Answering Brief, counsel merely deleted quotation marks while preserving the fabricated legal synthesis. Additionally, counsel’s assertion that parties should meet and confer before alerting the court to GenAI errors misstates the purpose of that requirement. The meet-and-confer requirement is designed to facilitate the resolution of disputes among parties. There is nothing to negotiate or compromise when an attorney submits false citations to a tribunal, and opposing counsel is justified in bringing such misrepresentations directly to the court’s attention.", "ai_tool_named": "generative artificial intelligence (“GenAI”) tool", "archive_url": "http://web.archive.org/web/20260826143126/https://courts.delaware.gov/opinions/download.aspx?id=397720", "case_name": "Leiske v. Kidd", "citation": null, "cited_authorities": [ "Court of Chancery Rule 11(b)", "An v. Archblock, Inc., 2025 WL 1024661 (Del. Ch. Apr. 5, 2025)", "Lexos Media IP LLC v. Overstock.com, Inc., 2026 WL 265581 (D. Kan. Feb. 2, 2026)", "Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025)", "Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)" ], "court": "Court of Chancery of Delaware", "court_code": "delch", "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10885202/kevin-leiske-v-robert-gregory-kidd/", "date_filed": "2026-07-01", "decision_id": "delch-2026-leiske-v-kidd", "disposition": "The court ordered attorney Richard P. Rollo and Richards, Layton & Finger, P.A. to show cause why sanctions should not be imposed.", "docket_number": "C.A. No. 2025-0426-CDW (LWW)", "document_type": "order", "fetched_at": "2026-09-07T21:10:00Z", "incident": { "actor": "lawyer", "ai_tool": "generative artificial intelligence (“GenAI”) tool", "conduct": "Counsel filed an answering brief with fictitious citations, fabricated quotations and hallucinated legal propositions generated by an unverified GenAI revision process.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "The court ordered affidavits and had not yet determined whether a hearing or sanctions would follow.", "primary_topic": "fabricated-citations", "source_url": "https://courts.delaware.gov/opinions/download.aspx?id=397720", "state": "DE", "summary": "The Delaware Court of Chancery orders Richard P. Rollo and Richards, Layton & Finger to show cause over GenAI errors in an answering brief. The court says counsel did not verify citations, left fabricated legal synthesis in a corrected filing, and must address Rule 11 and firm-supervision issues.", "text_sha256": "4974019f29f4b34e3046fc82b66bcf607856c90af2d3b1eac2fa7bf1ee8afc35", "topics": [ "fabricated-citations" ], "tracker_slug": "leiske-v-kidd", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/delch-2026-leiske-v-kidd", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/delch-2026-leiske-v-kidd" }, { "court_code": "cand", "state": "CA", "citation": null, "docket_number": "4:22-cv-00237-HSG-LB", "ai_tool_named": "Relativity aiR", "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "04ed8e6a9179ab9fe5317d8d464660ed1ee11008367d7ca2d1458224f73d463c", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": null, "decision_id": "cand-2026-schulte-v-linkedin", "case_name": "Schulte v. LinkedIn Corp.", "court": "U.S. District Court for the Northern District of California", "court_level": "federal-district", "date_filed": "2026-07-01", "document_type": "order", "topics": [ "discovery-ediscovery" ], "primary_topic": "discovery-ediscovery", "court_used_ai": false, "disposition": "The court denied plaintiffs’ requests to restrict LinkedIn’s Relativity aiR workflow and compel additional metrics.", "ai_passage": "On May 15, 2026, LinkedIn provided the plaintiffs with twenty-five search strings to be applied against LinkedIn’s custodial documents. At the same time, LinkedIn informed the plaintiffs that it would be using Relativity aiR, a GenAI review tool, “to assist in filtering out non-responsive documents.” On May 23, 2026, the plaintiffs requested more information about LinkedIn’s use of Relativity aiR. LinkedIn disclosed that “(1) there was no seed or training set used; (2) Relativity aiR is being used to make final responsiveness calls; and (3) quality control review is being conducted by human review of samples taken from each responsiveness type.” ... Courts have held that using search terms to pre-cull documents before providing them to technology-review platforms satisfies the reasonableness and proportionality standards of Rules 26(b) and 34(b)(2). E.g., Livingston v. City of Chicago, No. 16-cv-10156, 2020 WL 5253848, at *3 (N.D. Ill. Sep. 3, 2020); In re Biomet M2a Magnum Hip Implant Prods. Liab. Litig., No. 3:12-MD-2391, 2013 WL 1729682, at *2 (N.D. Ind. Apr. 18, 2013). The court finds the same here.", "cited_authorities": [ "Fed. R. Civ. P. 26(b)", "Fed. R. Civ. P. 34(b)(2)", "Livingston v. City of Chicago, No. 16-cv-10156, 2020 WL 5253848 (N.D. Ill. Sep. 3, 2020)", "In re Biomet M2a Magnum Hip Implant Products Liability Litigation, No. 3:12-MD-2391, 2013 WL 1729682 (N.D. Ind. Apr. 18, 2013)" ], "summary": "On 2026-07-01, the Northern District of California resolves discovery disputes over LinkedIn’s use of Relativity aiR. The court permits search-string pre-culling before GenAI review and denies additional audit metrics, finding LinkedIn’s disclosures satisfied the interim ESI order absent a specific deficiency.", "source_url": "https://www.govinfo.gov/content/pkg/USCOURTS-cand-4_22-cv-00237/pdf/USCOURTS-cand-4_22-cv-00237-26.pdf", "verification": "fetched-and-read", "lead_source": [ "GovInfo search", "CourtListener anonymous search" ], "url": "https://safelegalai.com/courts/opinions/cand-2026-schulte-v-linkedin", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-schulte-v-linkedin" }, { "decision_id": "texas-rule-2026", "case_name": "Preliminary Approval of Amendments to Texas Rule of Civil Procedure 13 and Texas Rules of Appellate Procedure 9 and 52", "court": "Supreme Court of Texas", "court_code": null, "court_level": "state-supreme", "state": "TX", "date_filed": "2026-06-26", "citation": "Misc. Docket No. 26-9054", "docket_number": "26-9054", "document_type": "administrative-order", "topics": [ "rules-by-opinion" ], "primary_topic": "rules-by-opinion", "court_used_ai": false, "disposition": "The court preliminarily approved rule amendments addressing verification and sanctions for inaccurate filings.", "ai_passage": "Rule 13 has been rewritten to modernize the rule and reinforce the obligation of attorneys and self-represented parties to verify documents filed with the court. Paragraphs (a) and (b) incorporate the requirements in current Rule 57. Paragraph (c)(1) is adopted principally to address concerns about the improper use of artificial intelligence in filings, which increases the risk of fabricated authorities, quotations, and holdings appearing in court filings. Verifying a filing for accuracy is important, regardless of whether artificial intelligence was Misc. Docket No. 26-9054 Page 5 used. The rule is not intended to govern disputes regarding the interpretation, application, or persuasive force of existing authorities. Paragraph (e)(1) requires the court to give the signer a reasonable opportunity to respond before imposing a sanction. Paragraph (e)(2) imports available sanctions from Rule 215, tailoring them for filings instead of discovery.", "cited_authorities": [ "Texas Rule of Civil Procedure 13", "Texas Rule of Civil Procedure 57", "Texas Rules of Appellate Procedure 9 and 52" ], "summary": "The Texas Supreme Court preliminarily approves amendments to civil and appellate filing rules. Comments explain that the changes address improper AI use by reinforcing attorneys’ and self-represented parties’ obligation to verify authorities, quotations, and holdings before filing.", "verification": "mirror-read", "archive_url": "https://web.archive.org/web/20260727115735/https://www.txcourts.gov/media/1462936/269054.pdf", "lead_source": [ "Texas Judicial Branch", "web search" ], "notes": "Official PDF returned 403 to curl; official PDF was read from an existing Wayback capture.", "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "1c1d0af5c8122e379630f6409fcdbeb8eb82b5458f522f79d932f85b42419648", "source_url": "https://www.txcourts.gov/media/1462936/269054.pdf", "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/opinions/texas-rule-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texas-rule-2026" }, { "ai_passage": "Morgan suggests that these phantom cases may be artifacts from the use of generative artificial-intelligence (“AI”) software drawing upon large language models. Appellate courts across Ohio and the country have experienced a surge of filings with such “hallucinations”—i.e., false citations proffered as true by generative AI. Jones neither confirms nor denies the allegation that he relied on AI; he merely states that the bogus cases “were the result of [his] chasing case law threads from other cases and not keeping close track of the situation.” We are inclined to agree with Morgan: Jones’s citations bear the hallmarks of AI hallucinations. No part of either citation refers to a real case remotely related to the proposition for which it is cited. If Jones had real cases in mind, he surely would have provided them in his opposition to Morgan’s motion. And if Jones had fabricated his bogus cases the old-fashioned way, we doubt he would have opted for an odd, three-party caption like “City of Columbus v. Edwards-Bosh v. Tri-County Toyota.” This court now has a rule about the use of AI. See Loc.R. 45. In it, we make clear that attorneys and parties using generative AI “are responsible for ensuring that all legal arguments, factual assertions, evidence, and citations are accurate, relevant, and comply with applicable laws, procedural rules, and ethical obligations,” and that the submission of “inaccurate, misleading, or fabricated AI-generated content” may result in “strik[ing] the filing and/or impos[ing] sanctions on the attorney or party.” Loc.R. 45(B) and (C). But Loc.R. 45 was not in place when Jones filed his brief. The use of fabricated citations is clearly a breach of a party’s responsibilities to the court. But our general sanctions rule, Loc.R. 23(A), focuses on whether “an appeal, original action, or motion is frivolous or is prosecuted for delay, harassment, or any other improper purpose.” The submission of a brief containing AI hallucinations does not inherently fit these descriptions. In the end, we have discretion to determine whether sanctions are warranted in a particular case. Although we could sanction Jones under our inherent authority, we choose not to do so because (1) we had not yet promulgated Loc.R. 45 when Jones filed the offending brief, and (2) a limited number of his citations (only two) were to “phantom” cases.", "ai_tool_named": "generative artificial-intelligence (“AI”) software", "archive_url": null, "case_name": "Morgan v. Jones", "citation": "2026-Ohio-2432", "cited_authorities": [ "Ohio First District Loc.R. 45", "Ohio First District Loc.R. 23(A)", "Gamble v. Gamble, 2025-Ohio-2381", "Coleman, 2026-Ohio-965", "Park v. Kim, 91 F.4th 610 (2d Cir. 2024)", "Garces v. Hernandez, 2025 U.S. App. LEXIS 21220 (5th Cir. Aug. 19, 2025)", "Moore v. Del City, 2025 U.S. App. LEXIS 31411 (10th Cir. Dec. 3, 2025)", "Shahid v. Esaam, 376 Ga. App. 145 (2025)", "In re S.M., 2025 IL App (4th) 250277-U", "Williams v. Kirch, 268 N.E.3d 284 (Ind. Ct. App. 2025)", "Kruse v. Karlen, 692 S.W.3d 43 (Mo. Ct. App. 2024)" ], "court": "Ohio Court of Appeals, First Appellate District", "court_code": "ohioctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10880916/morgan-v-jones/", "date_filed": "2026-06-26", "decision_id": "ohioctapp-2026-morgan-v-jones", "disposition": "The court affirmed in part, vacated in part, and denied sanctions and vexatious-litigant motions while warning about fabricated AI-generated citations.", "docket_number": "C-250217", "document_type": "opinion", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "litigant-in-person", "ai_tool": "generative artificial-intelligence (“AI”) software", "conduct": "A self-represented appellant cited two phantom cases that the court said bore the hallmarks of generative-AI hallucinations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official Ohio Supreme Court PDF timed out from this environment; read the public-domain court PDF from CourtListener storage.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/pdf/2026/06/26/morgan_v._jones.pdf", "state": "OH", "summary": "The Ohio First District Court of Appeals resolves post-divorce property disputes, denies Victoria Morgan’s request to sanction self-represented Mark Jones, and denies a vexatious-litigant motion. The court says Jones’s two phantom citations bear the hallmarks of AI hallucinations but predate its local AI rule.", "text_sha256": "765d565dcc395844b448e7e4ed11d0ba505b650cecbb9a973e25275b32640ed4", "topics": [ "fabricated-citations", "pro-se-ai-use", "rules-by-opinion" ], "tracker_slug": "morgan-v-jones", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/ohioctapp-2026-morgan-v-jones", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohioctapp-2026-morgan-v-jones" }, { "ai_passage": "The mother primarily relied on AI-generated hallucinations and misrepresentations of holdings in real cases. Rule 21(a)(1)(F), Ala. R. App. P., requires petitioners to include “[a] statement of the reasons why the writ should issue, with citations to the authorities and the statutes relied on” in a petition for the writ of mandamus. Four of the five cases cited by A.I.F.-H. (\"the mother\") in her petition appear to be “hallucinations” from an online artificial-intelligence (“AI”) tool and misrepresentations of holdings in real cases. One “case,” cited as “Ex parte Holloway, 992 So. 2d 521, 524 (Ala. 2008),” does not exist -- the reporter citation is to a case styled Display South, Inc. v. Graphics House Sports Promos., Inc., 992 So. 2d 510 (La. Ct. App. 2008), a Louisiana case concerning a class-action lawsuit alleging violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227 et seq. The mother also provides a “quote” from Ex parte Siderius, 144 So. 3d 319 (Ala. 2013), purporting to represent our supreme court's holding in that case; however, the quoted material cannot be found in that case or, to my knowledge, in any other case. Two other cases the mother cited are real cases, but the holdings the mother attributed to them are not accurate representations of the discussion of the issues in those cases. Our supreme court recently dismissed an appeal as a sanction for the widespread, improper use of AI in the plaintiffs' briefs in Ibach v. Stewart, [Ms. SC-2025-0106, Apr. 24, 2026] ___ So. 3d ___, ___ (Ala. 2026).", "ai_tool_named": "online artificial-intelligence (“AI”) tool", "archive_url": null, "case_name": "Ex parte A.I.F.-H. f/k/a A.I.F.", "citation": null, "cited_authorities": [ "Rule 21(a)(1)(F), Alabama Rules of Appellate Procedure", "Ex parte Siderius, 144 So. 3d 319 (Ala. 2013)", "Ibach v. Stewart, Ms. SC-2025-0106 (Ala. Apr. 24, 2026)" ], "court": "Alabama Court of Civil Appeals", "court_code": "alacivapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10880787/in-re-tbe-v-aif/", "date_filed": "2026-06-26", "decision_id": "alacivapp-2026-ex-parte-aif-h", "disposition": "The majority granted mandamus relief in part; Judge Bowden dissented and would dismiss the petition based on AI-generated hallucinations.", "docket_number": "CL-2025-0966", "document_type": "dissent", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "litigant-in-person", "ai_tool": "online artificial-intelligence (“AI”) tool", "conduct": "A mandamus petitioner cited cases that the dissent said did not exist or did not support the propositions asserted, and included a quotation not found in the cited case.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "AI discussion appears in Judge Bowden’s dissent; the majority did not impose sanctions. Official Alabama portal DNS failed; read the public-domain court PDF from CourtListener storage.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/pdf/2026/06/26/in_re_t.b.e._v._a.i.f..pdf", "state": "AL", "summary": "The Alabama Court of Civil Appeals grants part of a mother’s mandamus petition. In dissent, Judge Bowden says the petition should be dismissed because the mother relied on AI-generated hallucinations and misrepresented real holdings, warning that granting relief leaves fake citations without repercussions.", "text_sha256": "ef37107e6692598a56b38ef0d12847b99ac2155dd25164728090968a6e7fb002", "topics": [ "fabricated-citations" ], "tracker_slug": "ex-parte-a-i-f-h-f-k-a-a-i-f", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/alacivapp-2026-ex-parte-aif-h", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alacivapp-2026-ex-parte-aif-h" }, { "ai_passage": "In this case, we impose sanctions upon an attorney and a law firm for submitting a brief, prepared with the assistance of generative artificial intelligence (hereinafter GenAI), containing citations to nonexistent cases, fictitious purported Court of Appeals quotations wholly contrary to actual law, and misrepresentations about what certain real cases actually held or decided. As this Court discussed recently in Matter of Julien v Arthur (___ AD3d ___, 2026 NY Slip Op 03308, *1-2), “[c]ourts across the country have recognized the pitfalls posed by the use of GenAI in drafting briefs and other memoranda without verifying the accuracy of the information generated.” “In particular, courts have noted the risk of GenAI hallucinations, which may take the form of citations to nonexistent cases, fabricated quotations from actual cases, or misstatements of law that are not representative of what a case actually decided” (Matter of Julien v Arthur, ___ AD3d at ___, 2026 NY Slip Op 03308, *2 [internal quotation marks omitted]). “The danger posed by GenAI hallucinations lies not merely in their inaccuracy, but also in their tendency to masquerade as a genuine citation or statement of law, resulting in a waste of time and money to the opposing party in exposing the deception and an unnecessary burden on the court's resources” (Matter of Julien v Arthur, ___ AD3d at ___, 2026 NY Slip Op 03308, *2 [citation and internal quotation marks omitted]). Under all of the circumstances presented, including Sanders's lack of candor and submission of a brief with fabricated quotations that significantly misstated the law and with other misstatements that wholly misrepresented what certain real cases actually decided, we deem it appropriate to impose a monetary sanction on Sanders in the sum of $8,000. As for the law firm, we credit Haskel's statements in her affirmation that Sanders's actions were contrary to the law firm's policy, and that the law firm had no reason to believe that Sanders was using GenAI in a manner that exceeded the scope of technology approved for use by the law firm. Nevertheless, as the law firm's name appeared on a brief that contained significant misrepresentations, and in light of the deterrent purpose of sanctions, we deem it appropriate to impose a monetary sanction on the law firm in the sum of $2,500.", "ai_tool_named": "generative artificial intelligence (hereinafter GenAI)", "archive_url": null, "case_name": "Landberg v. City of New York", "citation": "2026 NY Slip Op 03935", "cited_authorities": [ "22 NYCRR 130-1.1", "Matter of Julien v. Arthur, 2026 NY Slip Op 03308", "Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)", "Deutsche Bank National Trust Co. v. LeTennier, 2026 NY Slip Op 00040", "Grymes Development Co. v. Fodera, 88 Misc. 3d 767", "Fletcher v. Experian Information Solutions, Inc., 168 F.4th 231 (5th Cir. 2026)" ], "court": "Supreme Court of New York, Appellate Division, Second Department", "court_code": "nyappdiv", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10879078/landberg-v-city-of-new-york/", "date_filed": "2026-06-23", "decision_id": "nyappdiv-2026-landberg-v-city-of-new-york", "disposition": "The court imposed $8,000 in sanctions on Michael Sanders and $2,500 on his law firm for a GenAI-assisted appellate brief.", "docket_number": "2025-02380", "document_type": "order", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "lawyer", "ai_tool": "generative artificial intelligence (hereinafter GenAI)", "conduct": "An attorney filed a GenAI-assisted appellate brief with nonexistent cases, fabricated Court of Appeals quotations and misrepresentations of real holdings; the law firm name appeared on the brief.", "currency": "USD", "monetary_penalty": 10500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official New York Law Reporting Bureau URL returned robots 403 from this environment; read the public-domain court HTML from CourtListener storage.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/html/2026/06/23/landberg_v._city_of_new_york.html", "state": "NY", "summary": "The New York Appellate Division, Second Department sanctions attorney Michael Sanders and Law Offices of Michael S. Lamonsoff, PLLC after an appellate brief used GenAI-assisted research. The court finds nonexistent cases, fictitious Court of Appeals quotations and misstatements, ordering $8,000 and $2,500 sanctions.", "text_sha256": "1da07726aac59fcf7364348b768470dc7a8b1dea5d777d6cef252eed2b3f4c37", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "landberg-v-city-of-new-york", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/nyappdiv-2026-landberg-v-city-of-new-york", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyappdiv-2026-landberg-v-city-of-new-york" }, { "ai_passage": "This case appears to not exist. The reporter citation provided—“521 N.E.2d 1240”—leads to People v. Pira, 521 N.E.2d 1236 (Ill. App. Ct. 1988) (beginning on page 1236, ending on page 1243). The pincite provided—“521 N.E.2d [at] 1244”—leads to Hauk v. Day, 521 N.E.2d 1243 (Ill. App. Ct. 1988) (beginning on page 1243, ending on page 1245). This court has decided several cases with the name “Fox v. Fox,” but none of those cases were decided in 1988. A search of Indiana cases for the quotation Hoagland provided returned no relevant results. Because the “Fox v. Fox” citation and associated quotation do not exist, it is likely they were created using generative artificial intelligence. “Citations to fictitious, AI-generated authority is a growing problem nationwide. Courts have sanctioned both attorneys and pro se litigants for including them in briefs.” Cingel v. Ferreri, 269 N.E.3d 857, 861 (Ind. Ct. App. 2025) (quoting Williams v. Kirch, 268 N.E.3d 284, 288 (Ind. Ct. App. 2025), trans. not sought), trans. not sought. “We caution attorneys and pro se litigants alike against using AI to conduct legal research without independently verifying the citations generated. Judges must be able to rely on the authenticity of the authorities cited by the parties to make just decisions.” Id. (quoting Williams, 268 N.E.3d at 288). Although the Town in its Appeal 1361 briefing brought to Hoagland’s attention the nonexistent citation and quotation, Hoagland failed to explain in its Appeal 1361 reply brief why it cited and quoted a nonexistent source. We remind Hoagland’s counsel of his obligations under the Professional Conduct Rules, particularly his duty to not “knowingly . . . fail to correct a false statement of . . . law previously made to the tribunal,” Prof. Cond. R. 3.3(a)(1).", "ai_tool_named": "generative artificial intelligence", "archive_url": null, "case_name": "Hoagland Family Limited Partnership v. Town of Clear Lake", "citation": null, "cited_authorities": [ "Cingel v. Ferreri, 269 N.E.3d 857 (Ind. Ct. App. 2025)", "Williams v. Kirch, 268 N.E.3d 284 (Ind. Ct. App. 2025)", "Indiana Professional Conduct Rule 3.3(a)(1)" ], "court": "Court of Appeals of Indiana", "court_code": "indctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10878086/hoagland-family-limited-v-town-of-clear-lake/", "date_filed": "2026-06-22", "decision_id": "indctapp-2026-hoagland-v-town-of-clear-lake", "disposition": "The court affirmed the appealed orders and reminded Hoagland’s counsel of candor duties after finding a nonexistent citation and quotation.", "docket_number": "25A-PL-1361; 25A-PL-3170", "document_type": "opinion", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "lawyer", "ai_tool": "generative artificial intelligence", "conduct": "Hoagland’s counsel cited and quoted a nonexistent Fox v. Fox source, failed to explain it after the appellee identified the problem, and was reminded of candor duties.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official Indiana Decisions API download timed out from this environment; read the public-domain court PDF from CourtListener storage.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/pdf/2026/06/22/hoagland_family_limited_v._town_of_clear_lake.pdf", "state": "IN", "summary": "The Indiana Court of Appeals affirms multiple orders in Hoagland Family Limited Partnership’s sewer-system dispute with Clear Lake. While rejecting one appellate argument, the court says a Fox v. Fox citation and quotation did not exist, likely came from generative AI, and reminds counsel of candor duties.", "text_sha256": "a6ca000173e87267044da0b169d2259df560e299464cd05f5776e8c84255d996", "topics": [ "fabricated-citations" ], "tracker_slug": "hoagland-family-limited-partnership-v-town-of-clear-lake", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/indctapp-2026-hoagland-v-town-of-clear-lake", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/indctapp-2026-hoagland-v-town-of-clear-lake" }, { "decision_id": "joyner-dcd-2026", "case_name": "United States v. Joyner", "court": "U.S. District Court for the District of Columbia", "court_code": "dcd", "court_level": "federal-district", "state": "DC", "date_filed": "2026-06-19", "citation": null, "docket_number": "Criminal No. 2023-0309", "document_type": "memorandum-opinion", "topics": [ "criminal-justice-algorithms" ], "primary_topic": "criminal-justice-algorithms", "court_used_ai": false, "ai_tool_named": "STRmix", "disposition": "The court granted in part and denied in part several limine motions, including challenges to STRmix DNA evidence.", "ai_passage": "These samples were imported into a probabilistic genotyping software, STRmix, which calculated the statistical probability that Mr. Joyner’s DNA contributed to the DNA profile of the samples (“inclusion”) or did not contribute to it (“exclusion”). See Def.’s Mot. Limit DNA Evid. at 2. For each sample analyzed, STRmix produced a likelihood ratio describing “how much more likely it is to obtain the DNA results if the person of interest is a contributor to the DNA profile, rather than if an unknown, unrelated person is a contributor to the DNA profile.” Id. (citation modified). In all but one of the samples, DNA from multiple persons was detected. STRmix ultimately assigned Items 4, 44, 56(1), and 69 likelihood ratios of 10, 21, 100, and 34, respectively.", "cited_authorities": [ "Federal Rule of Evidence 702", "Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993)" ], "summary": "The D.C. district court evaluates STRmix probabilistic-genotyping evidence among extensive pretrial motions in a robbery and carjacking prosecution. The opinion explains the software’s likelihood ratios and rules on admissibility limits for DNA testimony.", "verification": "mirror-read", "notes": "D.D.C. public-document CGI path is disallowed by robots.txt; court-authored PDF was read from CourtListener storage fallback.", "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10877644/x/", "text_sha256": "f90bb17edc3b163027f091e805d937e4ab3c5361e7cbd9c38679ceb2fe9e0ee7", "source_url": "https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2023cr0309-148", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "lead_source": [ "CourtListener anonymous search forensic-software.json" ], "url": "https://safelegalai.com/courts/opinions/joyner-dcd-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/joyner-dcd-2026" }, { "decision_id": "guerra-ny-2026", "case_name": "People v. Guerra", "court": "New York Court of Appeals", "court_code": "ny", "court_level": "state-supreme", "state": "NY", "date_filed": "2026-06-18", "citation": "2026 NY Slip Op 03905", "docket_number": "62", "document_type": "opinion", "topics": [ "criminal-justice-algorithms" ], "primary_topic": "criminal-justice-algorithms", "court_used_ai": false, "ai_tool_named": "forensic software program", "disposition": "The court affirmed the Appellate Division’s order granting a new trial for ineffective assistance.", "ai_passage": "In January 2017, an NYPD detective ran a forensic software program to investigate the sharing of child sexual abuse material (\"CSAM\")FN1 on an online \"peer-to-peer network.\"FN2 Such networks allow users to directly share electronic files without connecting to a central internet server. The forensic program identified 19 video files which were being shared from an unknown device at an IP address associated with a multi-family residential building in Queens. On July 27, 2017, police executed a search warrant at the building, which had 12 rented bedrooms with shared kitchens and bathrooms; the defendant shared one of the bedrooms with a roommate. Police seized approximately 20 electronic devices from the building, including a laptop computer from the defendant's room. A forensic preview of the laptop, which was not password protected, found no CSAM but did find digital artifacts indicating that the laptop had been used to run the peer-to-peer network. One of those artifacts was a list of files that had been downloaded using the laptop onto an external USB storage drive, and the titles of those files indicated that they were CSAM. No USB drive was recovered from the building.", "cited_authorities": [], "summary": "The New York Court of Appeals describes forensic software used to identify peer-to-peer CSAM sharing and later computer-forensics evidence. The court’s ineffective-assistance analysis turns on stipulations about digital evidence, possession, and mens rea.", "verification": "mirror-read", "notes": "Read from CourtListener storage copy of New York reporter HTML after official site access issues.", "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10877048/x/", "text_sha256": "3b495ffcb704bb9d0558b6c5cb1563f22d2db218a18d0a728e32d43c5f8affe7", "source_url": "http://www.nycourts.gov/reporter/current/3dseries/2026/2026_03905.shtml", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "lead_source": [ "CourtListener anonymous search forensic-software.json" ], "url": "https://safelegalai.com/courts/opinions/guerra-ny-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/guerra-ny-2026" }, { "ai_passage": "Counsel’s explanation does not excuse the violation. Artificial intelligence may be a useful tool for legal research and drafting, but the use of such technology does not alter an attorney’s professional obligations. Lawyers remain responsible for the filings they sign and submit. They must verify that cited authorities exist, read the authorities on which they rely, and ensure that those authorities support the propositions asserted. Counsel’s repeated reliance on artificial intelligence without meaningful verification, despite having been alerted more than once that his filings contained fabricated authority, fell below that standard. Counsel’s conduct burdened both defendant and this Court. Defendant was required to expend resources identifying and responding to fabricated citations, unsupported authorities, and arguments grounded in inapplicable criminal doctrine. This Court, in turn, was required to expend judicial resources disentangling plaintiff’s arguments from authorities that either did not exist or did not say what counsel represented them to say. We therefore consider the appropriate sanction. Under MCR 7.216(C)(1)(b), this Court may “assess actual and punitive damages or take other disciplinary action when it determines that an appeal or any of the proceedings in an appeal was vexatious because” a brief filed on appeal “was grossly lacking in the requirements of propriety, violated court rules, or grossly disregarded the requirements of a fair presentation of the issues to the court.” Counsel’s brief violated MCR 1.109(E)(5) and grossly disregarded the requirements of fair presentation by relying on fabricated authority, unsupported citations, and inapplicable criminal doctrine. Sanctions are therefore authorized under MCR 7.216(C)(1)(b).", "ai_tool_named": "artificial intelligence research tools", "archive_url": null, "case_name": "Barber v. Morawa", "citation": null, "cited_authorities": [ "MCR 1.109(E)(5)", "MCR 1.109(E)(6)", "MCR 7.216(C)(1)(b)", "Nixon v. Ken Ganley Ford West, 798 F. Supp. 3d 770 (N.D. Ohio 2025)", "Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025)", "Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341 (E.D.N.Y. 2025)", "Hardy v. Whitaker, E.D. Mich. 2026" ], "court": "Michigan Court of Appeals", "court_code": "michctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10876653/joyce-barber-v-lawrence-j-morawa-md/", "date_filed": "2026-06-17", "decision_id": "michctapp-2026-barber-v-morawa", "disposition": "The court affirmed denial of a new-trial motion, remanded to determine fees and expenses caused by the appeal, and referred counsel to the Attorney Grievance Commission.", "docket_number": "374773", "document_type": "opinion", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "lawyer", "ai_tool": "artificial intelligence research tools", "conduct": "Plaintiff’s counsel repeatedly filed fabricated and unsupported authorities generated or revised with artificial intelligence, despite defendant identifying the defects.", "currency": null, "monetary_penalty": null, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official Michigan judiciary URL returned robots 403 from this environment; read the public-domain court PDF from CourtListener storage.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/pdf/2026/06/17/joyce_barber_v._lawrence_j_morawa_md.pdf", "state": "MI", "summary": "The Michigan Court of Appeals affirms denial of Joyce Barber’s new-trial motion but sanctions her counsel for AI-related citation failures. The court holds that repeated fabricated and unsupported authorities violated Michigan court rules, remands to determine defendant’s actual damages and expenses, and refers counsel for possible investigation.", "text_sha256": "773b23dea3e99fb62ffdb5e8b30719ef8d6698539ef566b9b4d0c172c5eefdf8", "topics": [ "fabricated-citations", "competence-fees" ], "tracker_slug": "barber-v-morawa", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/michctapp-2026-barber-v-morawa", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/michctapp-2026-barber-v-morawa" }, { "ai_passage": "These circumstances present an opportunity for this court to reemphasize the importance of verifying every citation, holding, and quote a litigant selects for inclusion in his or her filings to a court. We expect this even more so from an attorney when case-related information is provided by his non-lawyer client for use in his brief. “All attorneys are officers of the legal system and have a duty of candor toward tribunals.” Brown v. State, 746 N.E.2d 63, 70 (Ind. 2001) (citing Ind. Professional Conduct Rule 3.3); see Ind. Trial Rule 11(A) (“The signature of an attorney constitutes a certificate by him that he has read the pleadings; [and] that to the best of his knowledge, information, and belief, there is good ground to support it[.]”). “[A] lawyer who uses . . . legal authority obtained from [artificial intelligence] in a pleading without independently confirming its accuracy fails to adhere to the obligation of candor to the court if those representations turn out to be false.” Maura R. Grossman et al., Is Disclosure and Certification of the Use of Generative AI Really Necessary? 107 Judicature 68, 75 (2023). “Courts nationwide have confronted this problem and imposed sanctions on attorneys . . . who file briefs containing fictitious authority.” Wilcox v. Gingrich, 274 N.E.3d 1269, 1276 (Ind. Ct. App. 2026). However, given the unique circumstances at issue here, we do not find sanctions are warranted. First, Father’s counsel brought this to the Court’s attention and sought to rectify the situation almost immediately upon discovering his mistake. In light of counsel’s honesty in bringing this matter to the Court’s attention and a lack of any alleged prejudice, we do not find monetary sanctions are appropriate in this case and therefore deny Mother’s request. Notwithstanding our decision, we echo the warnings issued by this Court and others around the country, especially to attorneys, of the risks posed by using artificial intelligence in litigation and the sanctions that can result from its misuse.", "ai_tool_named": "artificial intelligence", "archive_url": null, "case_name": "Holstein v. Holstein", "citation": null, "cited_authorities": [ "Brown v. State, 746 N.E.2d 63 (Ind. 2001)", "Indiana Professional Conduct Rule 3.3", "Indiana Trial Rule 11(A)", "Wilcox v. Gingrich, 274 N.E.3d 1269 (Ind. Ct. App. 2026)", "Dec v. Mullin, 171 F.4th 940 (7th Cir. 2026)", "Williams v. Kirch, 268 N.E.3d 284 (Ind. Ct. App. 2025)" ], "court": "Court of Appeals of Indiana", "court_code": "indctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": "https://www.courtlistener.com/opinion/10875747/jon-hansford-holstein-v-lacey-lawana-holstein/", "date_filed": "2026-06-16", "decision_id": "indctapp-2026-holstein-v-holstein", "disposition": "The court affirmed the custody order and denied a $5,000 sanctions request after counsel corrected fictitious citations.", "docket_number": "25A-DC-2767", "document_type": "opinion", "fetched_at": "2026-09-07T21:20:00Z", "incident": { "actor": "lawyer", "ai_tool": "artificial intelligence", "conduct": "Father’s counsel included two nonexistent cases and a fictitious quote provided by his client in an initial brief, then promptly disclosed and corrected the problem.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Official Indiana Decisions API download timed out from this environment; read the public-domain court PDF from CourtListener storage.", "primary_topic": "fabricated-citations", "source_url": "https://storage.courtlistener.com/pdf/2026/06/16/jon_hansford_holstein_v._lacey_lawana_holstein.pdf", "state": "IN", "summary": "The Indiana Court of Appeals affirms a custody order in Holstein v. Holstein and denies Mother’s request for $5,000 in sanctions. The court says Father’s counsel included citations from his client without verification, corrected them promptly, and receives a warning rather than a monetary sanction.", "text_sha256": "9e1b3c4704074d531242ddc1c44bc4fc6041c87f478546967cb7b2e7b48954b9", "topics": [ "fabricated-citations" ], "tracker_slug": "holstein-v-holstein", "verification": "fetched-and-read", "url": "https://safelegalai.com/courts/opinions/indctapp-2026-holstein-v-holstein", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/indctapp-2026-holstein-v-holstein" }, { "ai_passage": "As we will discuss, the district court confirmed no such case exists and admonished Ms. Borsody to refrain from using AI when drafting legal documents without confirming the accuracy of citations. We too have confirmed “Alford v. City of Canon City” is not a real case. In October 2025, while Frontier’s motion to dismiss was still pending, Ms. Borsody moved a second time for entry of default under Rule 55(a). In the same motion, she sought Rule 11 sanctions against Frontier for filing “recycled procedural motions” that “clearly serve[d] no purpose but delay.” RI.116. This filing also included argument about the relationship between Frontier and Michaels. Ms. Borsody said her “formal onboarding, payroll, and benefits were handled by Michaels, but [she] physically worked at the Fort Leavenworth property controlled and managed by Frontier[.]” RI.117. Although “daily duties, discipline, and workplace rules were enforced by Frontier Heritage,” Michaels was—at least according to Ms. Borsody— responsible for “benefits and pay[.]” RI.117.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Andria Borsody v. Frontier Heritage Communities", "citation": null, "cited_authorities": [ "Alford v. City of Canon City", "Rule 55(a)", "Rule 11" ], "court": "United States Court of Appeals for the Tenth Circuit", "court_code": "ca10", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-15", "decision_id": "ca10-2026-andria-borsody-v-frontier-heritage-communities", "disposition": "The court affirmed dismissal and upheld the district court's admonition that the self-represented appellant verify case citations before relying on AI-assisted briefing.", "docket_number": "25-3205", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant cited Alford v. City of Canon City even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2573/Borsody_v._Frontier_USA_15_June_2026.pdf", "state": null, "summary": "On 2026-06-15, in Andria Borsody v. Frontier Heritage Communities, the Tenth Circuit affirmed dismissal and upheld the district court's admonition that the self-represented appellant verify case citations before relying on AI-assisted briefing. A self-represented appellant cited Alford v. City of Canon City even though the court found the authority did not exist.", "text_sha256": "fbf3ef57c2d1bca24ea10636c2a42c9c164bd44a8c5f23b98889d21c9524529e", "topics": [ "fabricated-citations" ], "tracker_slug": "andria-borsody-v-frontier-heritage-communities", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca10-2026-andria-borsody-v-frontier-heritage-communities", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca10-2026-andria-borsody-v-frontier-heritage-communities" }, { "ai_passage": "–4– Appellant initially filed a brief raising sixteen appellate issues.1 The brief contained at least four hallucinated citations and at least twenty citations which do not stand for the proposition or holding for which they are presented. After appellees filed their brief, appellant filed a reply brief with at least two hallucinated citations and at least ten citations which do not stand for the proposition or holding for which they are presented. Appellees,meanwhile,filedabriefchallengingappellant’sinitialbrief,noting at least one hallucination and multiple instances of appellant misrepresenting the holdings of cited cases. Appellees’ brief itself was lacking; the brief contained exactly one citation to the record, and that citation was to the entirety of the trial court record (“see generally Clerk’s Record and Reporter’s Record”). Notably, appellees’ brief made no effort to refute appellant’s arguments about the portion of the judgment awarding appellee Lyotard damages for intentional infliction of emotional distress.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Shaddai Harris v. Nadia Lyotard and Mitchell Sadler", "citation": null, "cited_authorities": [], "court": "Court of Appeals of Texas", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-12", "decision_id": "texapp-2026-shaddai-harris-v-nadia-lyotard-and-mitchell-sa", "disposition": "The court struck the appellant's original briefs, required an amended brief, and then decided the appeal on the redrawn briefing.", "docket_number": "05-24-01449-CV", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a reply brief using at least four nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2396/Shaddai_Harris_v._Nadia_Lyotard_USA_12_June_2026.pdf", "state": "TX", "summary": "On 2026-06-12, in Shaddai Harris v. Nadia Lyotard and Mitchell Sadler, Court of Appeals of Texas struck the appellant's original briefs, required an amended brief, and then decided the appeal on the redrawn briefing. A self-represented appellant filed a reply brief using at least four nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "text_sha256": "6a13cb0d6381810098420fbf6cdd09a75fcb25ad3dca91137b87d2fe4cb79a0e", "topics": [ "fabricated-citations" ], "tracker_slug": "shaddai-harris-v-nadia-lyotard-and-mitchell-sadler", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp-2026-shaddai-harris-v-nadia-lyotard-and-mitchell-sa", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp-2026-shaddai-harris-v-nadia-lyotard-and-mitchell-sa" }, { "ai_passage": "The prior decision and order acknowledged the non-existent cases, but the proposition of law in those non-existent citations was, in fact, true. As the filing of identical motion papers in Paez Rodriguez is intended to cure a mistaken belief that “consolidated motion practice” was permissible, this court will not attribute the non-existent citations to appellate counsel for Paez Rodriguez.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Vargas v. MTA Bus Co.", "citation": "2026 WL 1811875", "cited_authorities": [], "court": "Supreme Court of New York", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-12", "decision_id": "nysupct-2026-vargas-v-mta-bus", "disposition": "The court amended its prior order and declined to attribute the non-existent citations in duplicated opposition papers to appellate counsel.", "docket_number": "No. 150611/2019", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed opposition papers using nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2483/Vargas_v_MTA_Bus_Co_USA_9_May_2026.pdf", "state": "NY", "summary": "On 2026-06-12, in Vargas v. MTA Bus Co, Supreme Court of New York amended its prior order and declined to attribute the non-existent citations in duplicated opposition papers to appellate counsel. Counsel filed opposition papers using nonexistent or hallucinated authorities.", "text_sha256": "2565c5f6353367d9a319107a93c596f943e33bffb42263ae28a1529e01281417", "topics": [ "fabricated-citations" ], "tracker_slug": "vargas-v-mta-bus-co", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-vargas-v-mta-bus", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-vargas-v-mta-bus" }, { "ai_passage": "Courts have previously observed that a citation to a nonexistent case suggests that Plaintiff may have used a form of generative artificial intelligence (“genAI”) to draft submissions to the Court and that genAI hallucinated the phantom case citation. See Park v. Kim, 91 F.4th 610, 614 (2d Cir. 2024) (discussing case cited in a reply brief that the Second Circuit was unable to locate and attorney’s admission that the case was provided by ChatGPT). The Court reminds and warns Plaintiff that all litigants are subject to Rule 11(b)(2) of the Federal Rules of Civil Procedure, which provides, in relevant part, that “[b]y presenting to the court a . . . motion . . . an attorney or unrepresented party certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . the claims, defenses, and other legal contentions are warranted by existing law. . .", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Jason Wimberly v. Verizon New York Inc.", "citation": null, "cited_authorities": [ "See Park v. Kim, 91 F", "Rule 11(b)(2)" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-12", "decision_id": "nysd-2026-jason-wimberly-v-verizon-new-york", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "1:26-cv-02341-LTS", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "ChatGPT", "conduct": "A self-represented litigant filed a reply brief using nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2449/Wimberly_v_Verizon_New_York_Inc_USA_12_June_2026.pdf", "state": "NY", "summary": "On 2026-06-12, in Jason Wimberly v. Verizon New York Inc, 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 reply brief using nonexistent or hallucinated authorities.", "text_sha256": "025b2e82259164560c79a284e94e41c5d72f97ce49c586e9972f1e5dc704c5b8", "topics": [ "fabricated-citations" ], "tracker_slug": "jason-wimberly-v-verizon-new-york-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-jason-wimberly-v-verizon-new-york", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-jason-wimberly-v-verizon-new-york" }, { "ai_passage": "The Reply also flagged fake quotes and unsupported propositions. Ginsburg did not file a sur-reply or move to remedy this problem. The Order to Show Cause. After reviewing the veracity of Defendant's claim that Ginsburg submitted a brief with fraudulent citations, the Court issued an order to show cause on May 15, 2026 (Dkt. #23). The order identified the suspect citations and ordered Ginsburg to appear in person on May 28, 2026, at 10:00 a.m., to explain why she should not be sanctioned. The Court also ordered Ginsburg to bring highlighted copies of the cases she cited. TheResponsetotheOrdertoShowCause.OnMay28,2026, less than one hour before the show cause hearing, Ginsburg filed a response to the order to show cause (Dkt. #24) (the “OrdertoShowCauseResponse”).AtthestartofherOrderto Show Cause Response, Ginsburg represented that she wanted “to explain how the filing occurred, correct the erroneous [fictitious] Noviello citation, and accept responsibility for the failure to verify the final version had been filed” (Dkt. #24 at p. 1).", "ai_tool_named": "GAI", "archive_url": null, "case_name": "McCormick v. Texakoma Financial", "citation": "2026 WL 1746259", "cited_authorities": [], "court": "United States District Court for the Eastern District of Texas", "court_code": "txed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-11", "decision_id": "txed-2026-mccormick-v-texakoma-financial", "disposition": "The court publicly reprimanded plaintiff's counsel, imposed $6,000 in sanctions, ordered firmwide citation review, and required AI-focused CLE.", "docket_number": "4:25-cv-773", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 6000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2457/MATT_MCCORMICK_v._TEXAKOMA_FINANCIAL_INC_USA_11_June_2026.pdf", "state": "TX", "summary": "On 2026-06-11, in McCormick v. Texakoma Financial, the Eastern District of Texas publicly reprimanded plaintiff's counsel, imposed $6,000 in sanctions, ordered firmwide citation review, and required AI-focused CLE. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "text_sha256": "047831bc9e15301c502fb2b1cfc14df9246ed853e4272f518febd8e2b7bd291f", "topics": [ "fabricated-citations" ], "tracker_slug": "mccormick-v-texakoma-financial", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txed-2026-mccormick-v-texakoma-financial", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txed-2026-mccormick-v-texakoma-financial" }, { "ai_passage": "adequate record on an issue requires that the issue be resolved against [appellant]”].) on Plaintiff’s multiple misrepresentations and erroneous citations of authority” that “permeate[] Plaintiff’s opposition.” On July 8, the court issued a tentative ruling granting Harbor’s motion to stay under the court’s inherent authority and the doctrine of exclusive concurrent jurisdiction and noticing in a footnote, “The court is separately issuing an Order to Show Cause re Sanctions based on [LLG’s] miscitation of cases, fabrication of quotations, and blatant misrepresentation of authority.” LLG “stipulated to” the tentative ruling.5 On July 9, the court “adopted” the tentative ruling in a court order that found LLG’s “arguments [against a stay were] unavailing in light of the controlling legal standard and the substantial factual overlap between the actions.” The court found it “undeniable that the two actions are substantially similar, involving nearly all of the same parties and claims.” “Here, eight of the nine causes of action” overlapped, “both actions [were] filed by the same plaintiff’s firm,” purportedly seeking to represent classes working “during closely overlapping time periods.” The order included the footnote noticing the separately issued order to show cause (OSC) re sanctions. The separately issued OSC re sanctions explained its basis as LLG’s opposition brief, which “contains non-existent citations, fabricated quotations, and seriously misrepresents controlling authority.” More specifically, LLG repeatedly cited and relied on two cases as authority, but, as the court noted in bold font, “Neither citation is accurate ...", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Quinteros v. Harbor Distributing, LLC", "citation": null, "cited_authorities": [], "court": "Court of Appeal of California, First Appellate District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-11", "decision_id": "calctapp1-2026-quinteros-v-harbor-distributing", "disposition": "The court imposed $6,000 in sanctions payable to the court and referred counsel to the California State Bar.", "docket_number": "Super. Ct. No. CGC24620226)", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Counsel filed opposition papers using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 6000, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2382/Quinteros_v._Harbor_Distributing_USA_June_2026.pdf", "state": "CA", "summary": "On 2026-06-11, in Quinteros v. Harbor Distributing, LLC, the California First District Court of Appeal imposed $6,000 in sanctions payable to the court and referred counsel to the California State Bar. Counsel filed opposition papers using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "text_sha256": "d634c17b1e38c1447257b9a815d21c49a1ddc36706de9aa06a16c7e8e629f71e", "topics": [ "fabricated-citations" ], "tracker_slug": "quinteros-v-harbor-distributing-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp1-2026-quinteros-v-harbor-distributing", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp1-2026-quinteros-v-harbor-distributing" }, { "ai_passage": "Mother's opening brief contained citations to a non-existent case, citations to cases with incorrect and impossible pin cites, citations to a memorandum decision issued before 2015, and other errors. Father noted these issues in his answering brief and argued Mother's arguments should be considered waived. Mother responded to this argument by denying the errors and insisting her citations were correct. This Court ordered Mother to file a supplementalbriefto address her citationproblems,and she then confessed she used generative artificial intelligence to produce her briefs and failed to check the accuracy of her briefs' citations. ¶8 We may consider an argument waived if it is \"not supported by adequate explanation, citations to the record, or authority.\" Ramos v. Nichols,252Ariz. 519,522,¶8 (App. 2022)(quotingIn reAubuchon,233Ariz. 62, 64–65, ¶ 6 (2013)). Mother's briefs are inadequately supported by legal authority. But waiver is a discretionary doctrine. Logan B. v. Dep't of Child Safety, 244 Ariz. 532, 536, ¶ 9 (App. 2018). We generally decline to find waiver when a child's best interests are at issue. Solorzano v. ... Mother indicated that she had paid her attorney $20,000 in fees and noted the source of those funds as \"self.\" She VILLANUEVA v. BOWERS Decision of the Court left blank the portion of the AFI requesting her total gross income for the last three tax years. ¶10 At the evidentiary hearing, Mother testified that she owns a business and her income from the business varies monthly. She stated: There's some times I will have a really good month, where I'll do a lot of jobs, and I'll make—I'll bank personally, maybe 35—40—5 grand tops, monthly. There's other months, for example, winter months where you don't really work in the winter.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Villanueva v. Bowers", "citation": null, "cited_authorities": [ "Ramos v. Nichols,252Ariz", "But waiver is a discretionary doctrine. Logan B. v. Dep't of Child Safety, 244 Ariz", "She VILLANUEVA v. BOWERS Decision of the Court left blank the portion of the AFI req" ], "court": "Arizona Court of Appeals, Division One", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-11", "decision_id": "arizctapp1-2026-villanueva-v-bowers", "disposition": "The court awarded $1 in costs or fees caused by the defective legal authorities.", "docket_number": "1 CA-CV 25-0345 FC", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed an opening brief using nonexistent or hallucinated authorities.", "currency": "USD", "monetary_penalty": 1, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2400/Villanueva_v._Bowers_USA_11_June_2026.pdf", "state": "AZ", "summary": "On 2026-06-11, in Villanueva v. Bowers, Arizona Court of Appeals, Division One awarded $1 in costs or fees caused by the defective legal authorities. A self-represented appellant filed an opening brief using nonexistent or hallucinated authorities. The monetary component was $1.", "text_sha256": "7468552c0836a8987f29d0b8808d5dc91f00e3070bef05297da2523111f39101", "topics": [ "fabricated-citations" ], "tracker_slug": "villanueva-v-bowers", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/arizctapp1-2026-villanueva-v-bowers", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arizctapp1-2026-villanueva-v-bowers" }, { "ai_passage": "Her briefs also cited two Iowa cases that do not exist; the reporter citations provided are for other states and cases unrelated to the cited propositions. We have addressed this phenomenon—problematic filings apparently “written” by artificial intelligence (AI)—in other cases. See Nisland Asset Inv., LLC v. Gericke, No. 25-0659, 2026 WL 1162553, at *1 (Iowa Ct. App. Apr. 29, 2026); In re W.G., No. 25-1916, 2026 WL 892837, at *2–3 (Iowa Ct. App.Apr.1,2026);InreR.A.,No.24-1629,2025WL2793560,at*2–4(Iowa Ct.App.Oct.1,2025);Lukev.Dep’tofHealth&Hum.Servs.,29N.W.3d635, 636(IowaCt.App. 2025);Turnerv.Garrels,No.24-0895,2025WL2537738, at *1 n.1 (Iowa Ct. App. Sep. 4, 2025). Most pertinent here, using AI in legal matters carries the risk of AI“hallucinating” or fabricating legal authorities thatdonotactuallyexist.SeeThomasA.Mayes,ArtificialIntelligence,Special Education,and theLaw: Risks,Rewards,and OpportunitiesforLeadership, 20 J. Bus. & Tech. L. ... We have, in the recent past, stricken offending portions of briefs and petitions containing a few AI-generated citations. See, e.g., W.G., 2026 WL 892837, at *3; In re R.A., 2025 WL 2793560, at *4. We decline to follow that path here for two reasons. First, the offending parties in W.G. and R.A. both complied with our order and expressed remorse for submitting fabricated citations;Andersonhasdoneneither.Second,inbothofthosecaseswecould at least arguably sift out the hallucinated authorities and decide what remainedof properlegalargument;wecannotdosoheregiventhedepthand breadthof thefabricated casecitations.SeeNisland,2026WL 1162553,at*1. GivenAnderson’sfailuretocomplywithourorderorsupplyalegalargument upon which we could decide this appeal, we conclude the only available remedy is dismissal. Last, Anderson suggested in her filing that we have ...", "ai_tool_named": null, "archive_url": null, "case_name": "State of Iowa ex rel J.G. v. Mynesia A. Anderson", "citation": null, "cited_authorities": [ "LLC v. Gericke, No. 25-0659, 2026 WL 1162553, at *1 (Iowa Ct. App. Apr. 29, 2026)" ], "court": "Iowa Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-10", "decision_id": "iowactapp-2026-state-of-iowa-ex-rel-j-g-v-mynesia-a-anderson", "disposition": "The court dismissed the appeal after the appellant failed to comply with its order addressing fabricated authorities in her briefs.", "docket_number": "25-1022", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "A self-represented appellant filed a petition using quotations that did not appear in the cited source and at least eight nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2388/Iowa_v._Anderson_USA_10_June_2026.pdf", "state": "IA", "summary": "On 2026-06-10, in State of Iowa ex rel J.G. v. Mynesia A. Anderson, Iowa Court of Appeals dismissed the appeal after the appellant failed to comply with its order addressing fabricated authorities in her briefs. A self-represented appellant filed a petition using quotations that did not appear in the cited source and at least eight nonexistent or hallucinated authorities.", "text_sha256": "7503871f189c79cfce5f7d505957dbd5d4bbf65990c305db3d80298c2d9cb64e", "topics": [ "fabricated-citations" ], "tracker_slug": "state-of-iowa-ex-rel-j-g-v-mynesia-a-anderson", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/iowactapp-2026-state-of-iowa-ex-rel-j-g-v-mynesia-a-anderson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/iowactapp-2026-state-of-iowa-ex-rel-j-g-v-mynesia-a-anderson" }, { "ai_passage": "Figure 3 below cites the 13 deficient arguments previously mentioned above; captures additional questionable arguments, misleading quotes, a non-existent Bankruptcy Rule; internally inconsistent and contradictory arguments; and describes other problems with the Trustee's Brief. The Court would not have a problem if the issues below were isolated, or if only a few of them appeared. But collectively, they may suggest that the Trustee has violated one or more of the Ind. R. Prof. Cond or Fed. R. Bank. P 9011. Figure 316 : Deficiencies in the Trustee's Brief VI. Conclusion *12 The Court rejects the Trustee's arguments. First, the majority approach to the §§ 1326(a)(2) – 349(b)(3) divide is thebetterapproach.ButeveniftheCourtappliedtheminority approach,theresultwouldbethesame.GeraciLawisentitled to the administrative expense it seeks, and the Trustee must disburse the funds to Debtor's attorneys. To the Trustee's second argument, the Trustee is wrong about “binding” case law. ... The second order will direct the Trustee to show cause in writing and at a hearing, why she should not be sanctioned for the 13 issues highlighted in Figure 3. SO ORDERED. In re Garcia-Martz, --- B.R. ---- (2026) All Citations --- B.R. ----, 2026 WL 1815400 Footnotes 1 Aside from Section I of this Decision, when the Court discusses jurisdiction and venue, all future references to statutes will be to Title 11, the Bankruptcy Code. The Code does not capitalize “Title” or “Chapter.” See, e.g., § 503. Many courts capitalize Title and Chapter. See, e.g., Marshall v. Johnson, 100 F.4th 914, 918 (7th Cir. 2024).", "ai_tool_named": "GAI", "archive_url": null, "case_name": "In re Garcia-Martz", "citation": "2026 WL 1815400", "cited_authorities": [ "Marshall v. Johnson, 100 F" ], "court": "United States Bankruptcy Court for the Northern District of Indiana", "court_code": "innb", "court_level": "federal-bankruptcy", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-10", "decision_id": "innb-2026-in-re-garcia-martz", "disposition": "The court ordered the filer to show cause why sanctions should not issue for the defective authorities.", "docket_number": "25-31324", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions they did not support, and a nonexistent rule or legal standard.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2507/In_re_Garcia-Martz_USA_June_2026.pdf", "state": "IN", "summary": "On 2026-06-10, in In re Garcia-Martz, the Northern District of Indiana Bankruptcy Court ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.", "text_sha256": "40439796b076e96944aca3acf298e7837095c31f59b619eca404eb416fc2ccdc", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-garcia-martz", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/innb-2026-in-re-garcia-martz", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/innb-2026-in-re-garcia-martz" }, { "ai_passage": "Obi continues to submit AI hallucinated arguments and cases. On page 7, she asserts that “The district court acknowledged on page 7 that ‘a federal court may hear a claim alleging a state court judgment is void forlackofjurisdiction.’ItcitedAndradev.ArbyConcessions, 88F.4th1014(7thCir.2023).”(Dkt.100at7).Theentiretyof that assertion—the quote, case, and “acknowledgement”—is made up. (Compare id. with Dkt. 88). Obi is a repeat offender on this front. She has continually filed briefs generated by AI that are riddled with fabricated cases and arguments. (Dkt. 97 at 3) (ruling that “[t]he severity of Plaintiff's Rule 11 ongoing and repeated violations warrants sanctions”). She also continues to ignore basic orders and court rules (such as page limit and spacing requirements). (Id. at 1-2).3 Obi claimsthattheCourtdismissedoneofherpositionsrelyingon “a single authority” and “without engagement with binding precedent.” (Dkt. 100 at 8). That is false. The Court cites to, relieson,andengageswith,multiplebindingcases.(Compare id. with Dkt. 88 at 6-8). Obi re-raises her frivolous position that “Docket 14 [i]s the Operative Complaint.” (Dkt. 100 at 10-11, 4).", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Ifeoma Delliane Chinedu Obi v. Cook County, Illinois, et al.", "citation": "2026 WL 1678232", "cited_authorities": [ "Rule 11" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-10", "decision_id": "ilnd-2026-ifeoma-delliane-chinedu-obi-v-cook-county-illi", "disposition": "The court struck the latest defective filing and imposed monetary sanctions for repeated AI-hallucinated arguments and cases.", "docket_number": "25 C 3096", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant cited Andrade v. Arby Concessions, 88 F.4th 1014 (7th Cir. 2023) even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2387/Obi_v._Cook_COunty_USA_10_June_2026.pdf", "state": "IL", "summary": "On 2026-06-10, in Ifeoma Delliane Chinedu Obi v. Cook County, Illinois, et al, the Northern District of Illinois struck the latest defective filing and imposed monetary sanctions for repeated AI-hallucinated arguments and cases. A self-represented litigant cited Andrade v. Arby Concessions, 88 F.4th 1014 (7th Cir. 2023) even though the court found the authority did not exist.", "text_sha256": "bb1ef91d0482aaf7dd64ed3fc5cf6d3e5a6db239e493411165fade622e80a265", "topics": [ "fabricated-citations" ], "tracker_slug": "ifeoma-delliane-chinedu-obi-v-cook-county-illinois-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-ifeoma-delliane-chinedu-obi-v-cook-county-illi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-ifeoma-delliane-chinedu-obi-v-cook-county-illi" }, { "ai_passage": "In addition to citing federal law applicable to motions to dismiss and confusing constitutional claims with employment discrimination, it also ignores binding Georgia precedent, mis-quotes cases cited, and relies on at least one hallucinatedcase.Wefindittroublingthatcounselsubmittedsuchanordertothetrial court, and regrettable that the trial court failed to identify any of these errors. See Paynev.State,CaseNo.S26A0459,slipop.at1-5(1)-(4),2026WL1215905(Ga.May 5, 2026) (sanctioning counsel who prepared order citing hallucinated cases, remanding to the trial court to issue a new order omitting such citations, and encouragingtrialcourtstoengageinacarefulreviewofmaterialssubmittedtoit);Slay v. Ross, __ Ga. App. __ (927 SE2d 569, 571) (2026) (“[h]allucinated cases are typicallyahallmarkoftheirresponsibleuseofregenerativeartificialintelligence(A.I.) in legal drafting.” (punctuation omitted)). Accordingly, we must, yet again, remind counsel,andlowercourts,oftheirprofessionalresponsibilitiesandobligationsinthe use of artificial intelligence. Moreover, the trial court’s order contains no analysis of the Eleventh Amendmentimmunityissuenorfactualfindingsastoanyofthefactorsapplicableto the question of whether the school district was an “arm of the State.” The trial court’s summary conclusion, coupled with the errors identified above, hampers our abilitytoreachthemeritsoftheEleventhAmendmentarguments.Asaresult,wefind itnecessarytovacatetheorderdenyingthemotiontodismisstheTitleVIIclaims,and weremandthecaseforreconsiderationundertheproperstandardsandbonafidecase law. See Payne, Case No. S26A0459, slip op. at 1-5(1)-(4) (remanding case for reconsideration without hallucinated cases). (b)Isthereawaiverofthedistrict’ssovereignimmunityforstatelawclaimsbrought in state court? We next consider whether the plaintiffs established a waiver of sovereign immunityforthestatelawtortandbreachofcontractclaims,concludingthattheydid not. TheHenryCountySchool Districtisapoliticalsubdivision of theStateand is entitledtosovereignimmunityunlessithasbeenwaived.Ga.Const.of1983,Art.IX, Sec. II, Par.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Henry County Schools et al. v. Grant et al.", "citation": null, "cited_authorities": [ "Slay v. Ross, __ Ga" ], "court": "Court of Appeals of Georgia", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-10", "decision_id": "gactapp-2026-henry-county-schools-v-grant", "disposition": "The court vacated the order denying dismissal of the Title VII claims and remanded for reconsideration using proper standards and real case law.", "docket_number": "A26A0698; A26A0699; A26A0700", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "judge", "ai_tool": "GAI", "conduct": "The trial court's order relied on at least one nonexistent or hallucinated authority and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2379/Henry_County_Schools_USA_10_June_2026.pdf", "state": "GA", "summary": "On 2026-06-10, in Henry County Schools et al. v. Grant et al, Court of Appeals of Georgia vacated the order denying dismissal of the Title VII claims and remanded for reconsideration using proper standards and real case law. The trial court's order relied on at least one nonexistent or hallucinated authority and authorities used for propositions they did not support.", "text_sha256": "95d107a5da45b24209e9521afcdd0eb7af7ba8d17254feb98206767834cd2c7e", "topics": [ "fabricated-citations" ], "tracker_slug": "henry-county-schools-et-al-v-grant-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gactapp-2026-henry-county-schools-v-grant", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gactapp-2026-henry-county-schools-v-grant" }, { "ai_passage": "He speculates about Gillespie’s motives and saturates his briefing with immaterial and misrepresented facts, apparently hallucinated by artificial intelligence. The record shows Gillespie fired Gaddy because he concluded after investigating that Gaddy fudged the customers’ tips. The Court grants defendants’ motion. I Customers and staff at Woody’s and Voyeur are mostly gay, bisexual or queer males. (Defs.’ SOMF ¶ 11, Dkt. No. 49-2.) Some bartenders start work at Woody’s and move to Voyeur around 2:00 a.m. when Woody’s closes. Voyeur is open until 4:00 a.m. on weekends. (Id. ¶¶ 7, 56.) Approximately two-thirds of the bartenders at Woody’s and Voyeur are male. (Id. ¶ 12.) Gaddy started as a bartender at both Woody’s and Voyeur around February of 2018. (Id. ¶ 14.) Martin Gillespie and Roy Baldwin supervised Gaddy at Woody’s, (id. ¶ 16), and Gaddy also reported to Gillespie at Voyeur, (id. ¶ 17). Gillespie assigned bartenders’ shifts at both establishments. (Id. ¶ 54); (Gaddy’s Resp. to Defs.’ SOMF ¶ 54, Dkt. No. 50-1.) In 2022, Gaddy worked almost exclusively at Woody’s, which has several bars inside. ... She would be a comparator if Gillespie concluded both had fudged tips, and only disciplined Gaddy, but that’s not what happened. Gaddy conflates his comparator arguments with his criticism of Woody’s investigation into the disputed tips. See infra subsection III.C.1. He claims “Woody’s investigated and terminated Gaddy (male) while taking no adverse action against Esser (female) whose checks were implicated.” (Gaddy’s Resp. in Opp’n at 9, Dkt. No. 50.) All agree the receipts which triggered the investigation bore Esser’s name. (Tr. of Oral Arg. at 20:7–11.) But Gillespie concluded Gaddy was responsible for improperly entering tip information into the point-of-sale system. Esser therefore is not a comparator. Neither is Chelsea Michaels.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Casey A. Gaddy v. Wood Brothers Bar, Inc., et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Eastern District of Pennsylvania", "court_code": "paed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-09", "decision_id": "paed-2026-casey-a-gaddy-v-wood-brothers-bar", "disposition": "The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.", "docket_number": "24-6529", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a motion using record or transcript quotations not found in the record, quotations that did not appear in the cited source, several nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2399/Gaddy_v._Wood_Brothers_Bar_USA_6_June_2026.pdf", "state": "PA", "summary": "On 2026-06-09, in Casey A. Gaddy v. Wood Brothers Bar, Inc., et al, the Eastern District of Pennsylvania admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant filed a motion using record or transcript quotations not found in the record, quotations that did not appear in.", "text_sha256": "e9754ae0d08450cebd4714f5ac0d9ab4a7d798ed970d3136c07373692219e46d", "topics": [ "fabricated-citations" ], "tracker_slug": "casey-a-gaddy-v-wood-brothers-bar-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/paed-2026-casey-a-gaddy-v-wood-brothers-bar", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/paed-2026-casey-a-gaddy-v-wood-brothers-bar" }, { "ai_passage": "Constants also admitted that “he did not prepare, review, or file at least one of plaintiffs motions,” and nearly all of the motions in this matter contain the hallmarks of artificial intelligence (“Al”) fabrication, including non-existent hallucinated cases, formatting unchanged from that produced by Al platforms, and remnants of prompts that the drafter declined LEGAL STANDARDS’ Under § 1927, the Court may require “any attorney ... who so multiplies the proceedings in any case unreasonably and vexatiously” to pay the other party’s “excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.” 28 U.S.C. § 1927. Similarly, the Court may “exercise its inherent power to sanction a party or an attorney who has acted in bad faith, vexatiously, wantonly, or for oppressive reasons.” Ransmeier v. Mariani, 718 F.3d 64, 68 (2d Cir. 2013). In practice, “the only meaningful difference between an award made under § 1927 and one made pursuant to the court’s inherent power is . . . that awards under § 1927 are made only against attorneys . . . while an award made under the court’s inherent power may be made against an attorney, a party, or both.” Enmon v. Prospect Cap.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "LiveVideo.AI Corp. v. Redstone", "citation": null, "cited_authorities": [ "Ransmeier v. Mariani, 718 F", "Enmon v. Prospect Cap" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-09", "decision_id": "nysd-2026-livevideo-ai-v-redstone", "disposition": "The court awarded more than $85,000 in fees and costs and referred counsel to the district grievance committee.", "docket_number": "24 Civ. 6290", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a motion using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.", "currency": "USD", "monetary_penalty": 85056, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2385/LiveVideo_v._RedStone_USA_9_June_2026.pdf", "state": "NY", "summary": "On 2026-06-09, in LiveVideo.AI Corp. v. Redstone, the Southern District of New York awarded more than $85,000 in fees and costs and referred counsel to the district grievance committee. Counsel filed a motion using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.", "text_sha256": "de0dcf0b678e2faaacb9ce63598fed7646c6aab71d170c6e544bbd5b5c0d6fdb", "topics": [ "fabricated-citations" ], "tracker_slug": "livevideo-ai-corp-v-redstone", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-livevideo-ai-v-redstone", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-livevideo-ai-v-redstone" }, { "ai_passage": "Across these motions, the Court finds Castro: (1) overstated the breadth of four cases; (2) discussed a non-existent count; (3) completely misrepresented five cited authorities; and, most troubling of all, (4) failed to take responsibility for clearly failing to review his motions. Leafwell requests the Court dismiss with prejudice My Florida Green’s related claims against Leafwell and/or grant a default judgment against My Florida Green in this case. (Doc. #40, p. 26.) The Court, however, finds these proposed sanctions excessive. Castro already has ongoing obligations from the previous sanctions order issued by District Court Judge Sherri Polster Chappell, under which Castro is obligated to pay attorney’s fees, must attach a copy of Judge Chappell’s order to any case he files or removes to the Middle District of Florida, and was referred to the Florida Bar for appropriate discipline. See The Doc App, Inc. v. Leafwell, Inc., No. 2:25-cv-838-SPC-NPM, 2025 WL 3288251 (M.D. Fla. Nov. 26, 2025).", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Leafwell, Inc. v. The Doc App, Inc.", "citation": null, "cited_authorities": [ "Inc. v. Leafwell" ], "court": "United States District Court for the Middle District of Florida", "court_code": "flmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-09", "decision_id": "flmd-2026-leafwell-v-doc-app", "disposition": "The court declined to add new sanctions but warned counsel that the order could support future professional-discipline proceedings.", "docket_number": "2:25-cv-01132-JES-KRH", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel 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.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2405/Leafwell_Inc._v._The_Doc_App_USA_9_June_2026.pdf", "state": "FL", "summary": "On 2026-06-09, in Leafwell, Inc. v. The Doc App, Inc, the Middle District of Florida declined to add new sanctions but warned counsel that the order could support future professional-discipline proceedings. Counsel 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.", "text_sha256": "919a9867d63c400bdab3f31e232338676e918ecb7ebf209df4c8e7c41cbad1f8", "topics": [ "fabricated-citations" ], "tracker_slug": "leafwell-inc-v-the-doc-app-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/flmd-2026-leafwell-v-doc-app", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flmd-2026-leafwell-v-doc-app" }, { "ai_passage": "However, the Amended Complaint alleges that the Employee Handbook contains certain language that does not appear in the document filed by Defendants. Compare [Doc. 24 at ¶¶ 42–47], with [Doc. 34-1]. Because the Court cannot verify the accuracy of the document filed by Defendants, the Court declines to consider it in ruling on the Motion to Dismiss. Case No. 1:25-cv-03285-NYW-MDB Document 49 filed 06/09/26 USDC Colorado pg 3 of 21 at ¶ 90]. Plaintiff alleges that this “legally shareable” “proprietary knowledge” was “confidential and trade secret information and documents that Ms. Combs had obtained and retained from THTBC . . ., and which she used, disclosed, or planned to use or disclose, for or to Combs Consulting’s clients.” [Id. at ¶ 93]. In August 2025, Ms. Combs began working for CBRE Government & Defense Services, a direct competitor of THTBC. [Id. at ¶¶ 105–06]. THTBC initiated this action on October 17, 2025, [Doc. 1], and filed the Amended Complaint on February 6, 2026, [Doc. 24]. It asserts eight claims: (1) a breach of contract claim against Ms.", "ai_tool_named": "Eve Legal", "archive_url": null, "case_name": "Tlingit Haida Tribal Business Corporation v. OnePromom", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Colorado", "court_code": "cod", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-09", "decision_id": "cod-2026-tlingit-haida-tribal-business-v-onepromom", "disposition": "The court ordered plaintiff to show cause why the filing was not sanctionable and whether counsel complied with professional obligations.", "docket_number": "25-cv-03285-NYW-MDB", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "Eve Legal", "conduct": "Counsel filed a motion using quotations that did not appear in the cited source.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2397/Tlingit_v_Onepromom_USA_9_June_2026.pdf", "state": "CO", "summary": "On 2026-06-09, in Tlingit Haida Tribal Business Corporation v. OnePromom, the District of Colorado ordered plaintiff to show cause why the filing was not sanctionable and whether counsel complied with professional obligations. Counsel filed a motion using quotations that did not appear in the cited source.", "text_sha256": "4bfa8da0116b39fcf9db290a11f7ac7f3c5b8324c5f6bfc9c3f0774d2e603d4a", "topics": [ "fabricated-citations" ], "tracker_slug": "tlingit-haida-tribal-business-corporation-v-onepromom", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cod-2026-tlingit-haida-tribal-business-v-onepromom", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cod-2026-tlingit-haida-tribal-business-v-onepromom" }, { "ai_passage": "2026) (granting defendant’s motion to compel arbitration, in response to Plaintiff’s “90-page complaint [that] assert[ed] 18 causes of action under federal and state law,” and noting that Plaintiff’s filings included at least one “hallucinated citation” as well as “fake quotations” misattributed to real cases). … … … Court Action. Restatement (Second) of Judgments § 13, cmt. f (1982) (“The better view is that a judgment otherwise final remains so despite the taking of an appeal . . . .”). - 13 - Accordingly, IT IS ORDERED that Defendant’s motion to dismiss (Doc. 17) is granted.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Perry v. Merrick Bank Corporation", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-09", "decision_id": "azd-2026-perry-v-merrick-bank", "disposition": "The court dismissed the complaint without leave to amend and noted the plaintiff's prior hallucinated citations in related litigation.", "docket_number": "CV-25-02297-PHX-DWL", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a response using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2398/Perry_v_Merrick_Bank_Corporation__USA_9_June_2026.pdf", "state": "AZ", "summary": "On 2026-06-09, in Perry v. Merrick Bank Corporation, the District of Arizona dismissed the complaint without leave to amend and noted the plaintiff's prior hallucinated citations in related litigation. A self-represented litigant filed a response using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.", "text_sha256": "e11c8817782ab860434a6c00afcbba50d667e8cf6aa43a46efde5eca5e609eb3", "topics": [ "fabricated-citations" ], "tracker_slug": "perry-v-merrick-bank-corporation", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azd-2026-perry-v-merrick-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-perry-v-merrick-bank" }, { "ai_passage": "✳ ✳ ✳ As counsel for the City of Austin has noted, Plaintiffs’ response to the City’s plea to the jurisdiction contains a non-existent quotation of a legal authority. The response falsely quotes the Texas Tort Claims Act as containing an exception to governmental immunity for “engaging in a proprietary function, including . . . allowing use of a public facility for compensation.” Counsel for Plaintiffs Bradford Klager admitted to the Court that this fake quote was completely fabricated by a generative artificial intelligence chatbot, and it was blindly copied and pasted into the Plaintiffs’ response without checking its veracity. Plaintiffs’ response also states that “CPRC § 75.002(d) waives the immunity of governmental entities for gross negligence causing personal injury on public land used for 06/08/2026 10:19:51 AM D-1-GN-25-011111 Velva L. Price District Clerk Travis County recreational purposes.” As the City’s attorney correctly notes, this provision does not address governmental immunity.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Erica Whitesock v. Bird Global, Inc., and The City of Austin", "citation": null, "cited_authorities": [], "court": "District Court of Travis County, Texas, 250th Judicial District", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-08", "decision_id": "txdistct-2026-erica-whitesock-v-bird-global-and-city-of-aust", "disposition": "The court granted the City of Austin's jurisdictional plea, dismissed those claims with prejudice, and awarded $10,000 in attorney fees.", "docket_number": "D-1-GN-25-011111", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions they did not support, and a nonexistent rule or legal standard.", "currency": "USD", "monetary_penalty": 10000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2807/Whitesock_v._City_of_Austin_USA_August_2026.pdf", "state": "TX", "summary": "On 2026-06-08, in Erica Whitesock v. Bird Global, Inc., and The City of Austin, the Travis County district court granted the City of Austin's jurisdictional plea, dismissed those claims with prejudice, and awarded $10,000 in attorney fees. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.", "text_sha256": "232fc1971866041a67465e92e6789a6e012cfc83e4e9687d4efa1cdc946052c1", "topics": [ "fabricated-citations" ], "tracker_slug": "erica-whitesock-v-bird-global-inc-and-the-city-of-austin", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txdistct-2026-erica-whitesock-v-bird-global-and-city-of-aust", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txdistct-2026-erica-whitesock-v-bird-global-and-city-of-aust" }, { "ai_passage": "Apparently that AI program hallucinated over some citations. As a result, the Court required Plaintiff’s counsel to correct the citations and submit a Corrected Motion. They did so. (ECF No. 94.) The Sixth Circuit has recently addressed the role of AI in the realm of litigation. That court imposed significant sanctions and pointed out that lawyers cannot outsource their ethical obligations to an AI program. In fact, the Sixth Circuit has sanctioned lawyers for doing just that. In United States v. Farris, the court noted the “baseline ethical obligations as they relate to the use of artificial intelligence.” 171 F.4th 920, 922 (6th Cir. 2026). Even though this new technology holds great potential, the court explained that “all in the legal profession must be clear eyed PageID 1120 Agreement so that they can send notice to the Settlement Class.2 (ECF No.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Bailey v. Sedgwick Claims Management Services, Inc.", "citation": null, "cited_authorities": [ "In United States v. Farris" ], "court": "United States District Court for the Western District of Tennessee", "court_code": "tnwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-08", "decision_id": "tnwd-2026-bailey-v-sedgwick-claims-management-services", "disposition": "The court required a corrected motion after counsel disclosed AI-hallucinated citations, but declined to impose sanctions at that point.", "docket_number": "2:24-cv-02749-TLP-tmp", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2370/Bailey_v._Sedgwick_USA_June_2026.pdf", "state": "TN", "summary": "On 2026-06-08, in Bailey v. Sedgwick Claims Management Services, Inc, the Western District of Tennessee required a corrected motion after counsel disclosed AI-hallucinated citations, but declined to impose sanctions at that point. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.", "text_sha256": "5fa42bc102118f6350a684041c9b8eded8d544bdc1f8dc77b4dc949e5c1c8805", "topics": [ "fabricated-citations" ], "tracker_slug": "bailey-v-sedgwick-claims-management-services-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/tnwd-2026-bailey-v-sedgwick-claims-management-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tnwd-2026-bailey-v-sedgwick-claims-management-services" }, { "ai_passage": "On December 10, 2025, the Court entered an Order to Show Cause [110] directing all counsel of record in this case to show cause as to why the Court should not impose sanctions against them pursuant to Rule 11 of the Federal Rules of Civil Procedure, the Court’s Local Rules, and/or its inherent authority for filing legal memoranda containing hallucinated case citations. The four attorneys, namely Kathleen M. Wilson, Shauncey Hunter Ridgeway, Kathryn Y. Williams, and Mark C. McClinton, appeared before the Court on January 20, 2026 for a hearing on this matter. Following entry of the Order to Show Cause [110], both parties submitted Motions for Leave [112, 113] to file corrected versions of the legal memoranda in issue. Having considered the record, the applicable law, and counsels’ explanation presented at the hearing, the Court is prepared to rule on the sanctions issue, as well as on the related pending Motions [112, 113]. Relevant Factual and Procedural Background A brief recitation of the facts underlying this case provides helpful context. This action involves a contractual dispute between Withers and the City of Aberdeen (“the City”) over legal fees. Withers is a licensed attorney in the State of Louisiana whose Complaint [1] brings a single breach of contract claim against the City. He is represented in this case by Kathleen M.", "ai_tool_named": "First Drafts", "archive_url": null, "case_name": "Withers v. City of Aberdeen", "citation": null, "cited_authorities": [ "Rule 11" ], "court": "United States District Court for the Northern District of Mississippi", "court_code": "msnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-08", "decision_id": "msnd-2026-withers-v-city-of-aberdeen", "disposition": "The court revoked pro hac vice admission, disqualified resident counsel, fined counsel $8,000, and referred the matter to bar authorities.", "docket_number": "1:24-CV-218-SA-RP", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "First Drafts", "conduct": "Counsel filed opposition papers using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 8000, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2371/Withers_v._City_of_Aberdeen_USA_June_2026.pdf", "state": "MS", "summary": "On 2026-06-08, in Withers v. City of Aberdeen, the Northern District of Mississippi revoked pro hac vice admission, disqualified resident counsel, fined counsel $8,000, and referred the matter to bar authorities. Counsel filed opposition papers using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "text_sha256": "f092ba4943a9a4635e84af2fdcd1a4b577b7574ad524db31a329fb7f16d78048", "topics": [ "fabricated-citations" ], "tracker_slug": "withers-v-city-of-aberdeen", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/msnd-2026-withers-v-city-of-aberdeen", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/msnd-2026-withers-v-city-of-aberdeen" }, { "ai_passage": "Our review of father’s brief shows that it contains many citations to caselaw that either do not exist—sometimes referred to as “hallucinations”—or do not support his legal argument. And father’s brief inaccurately quotes statutes and the record. Our review also leads us to believe that father may have used generative artificial intelligence (AI) to write his brief. While AI can be a helpful tool and we do not suggest that court rules prohibit its use,weemphasizethat hallucinatedcaselawisnotvalidauthorityandthatallpartiesshould be mindful of the importance of accuracy in their submissions. Finally, as discussed below, father fails to cite authority that supports his position and to articulate an argument in support of some issues. This results in forfeiture, and the issue “will not be considered on appeal unless prejudicial error is obvious on mere inspection.” Schoepkev.AlexanderSmith& SonsCarpetCo.,187 N.W.2d133,135 (Minn. 1971). We reorganize the arguments in father’s brief into six issues and discuss each in turn. I.", "ai_tool_named": "generative artificial intelligence", "archive_url": null, "case_name": "Young v. Young", "citation": null, "cited_authorities": [], "court": "Minnesota Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-08", "decision_id": "minnctapp-2026-young-v-young", "disposition": "The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.", "docket_number": "A25-0906", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "generative artificial intelligence", "conduct": "A self-represented appellant filed a brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2402/Re_mariage_of_Young_USA_8_June_2026.pdf", "state": "MN", "summary": "On 2026-06-08, in Young v. Young, Minnesota Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a brief using record or transcript quotations not found in the record, quotations that did not appear in.", "text_sha256": "0e962c19bb1b779e62d58f756927818794e700238b11ef48fdfdc6f960d9d31d", "topics": [ "fabricated-citations" ], "tracker_slug": "young-v-young", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/minnctapp-2026-young-v-young", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/minnctapp-2026-young-v-young" }, { "ai_passage": "In any event, Norberg is a district court case—it is not precedential, and certainly not “controlling.”2 Allison’s mischaracterization of the cases he cites, as well as his filing of prior documents that include citations to fictitious cases, are “hallmarks of a so-called AI hallucination, a circumstance where anAI large language model generates an output that is fictional, inaccurate, or nonsensical.” See Jones v. Kankakee Cnty. Sheriff’s Dep’t, 164 F.4th 967, 969–70 (7th Cir. 2026); see also see also Turnage v. Associated Bank, N.A., No. 25-3004, 2025 WL 3052638, at *3 (D. Minn. Sept. 12, 2025) (“Every filing in a federal court that contains citations to phony case law amounts to a violation of Rule 11(b) of the Federal Rules of Civil Procedure. There is no pro se exception to Rule 11(b).”). Allison suggests that he personally suffered “emotional distress arising from the loss of control over sixteen images of his minor son and the risk that an unknown third party may have access to them.” (Reply [84] at 6.) Assuming he has standing to bring such a claim, these allegations also do not state a plausible claim for relief. ... Allison attacks this as a “transparent and cynical litigation tactic designed to give the Court a basis to declare the breach of contract claim moot and dismiss the entire case,” and urges that the package of reprints“ignores the true harm . . . caused by the reckless mishandling of a minor’s sensitive images.” (Id.) Perhaps Allison believes that once he filed a lawsuit, Shutterfly’s compliance with its own terms of service by presenting reprints and a refund constitutes a “cynical litigation tactic.” The court does not share that belief.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Allison v. Shutterfly LifeTouch LLC", "citation": null, "cited_authorities": [ "See Jones v. Kankakee Cnty. Sheriff’s Dep’t, 164 F", "Turnage v. Associated Bank", "Rule 11(b)" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-08", "decision_id": "ilnd-2026-allison-v-shutterfly-lifetouch", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "25 C 03546", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant cited || Misrepresented: Case Law | Plaintiff characterized Norberg v. Shutterfly as even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2403/Allison_v._Shutterfly_USA_8_June_2026.pdf", "state": "IL", "summary": "On 2026-06-08, in Allison v. Shutterfly LifeTouch LLC, the Northern District of Illinois warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant cited || Misrepresented: Case Law | Plaintiff characterized Norberg v. Shutterfly as even though the court found the authority did not exist.", "text_sha256": "9e1daf256432ca3800b013deaed56a70a10058efe8f2bc6e20e06ab20654e494", "topics": [ "fabricated-citations" ], "tracker_slug": "allison-v-shutterfly-lifetouch-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-allison-v-shutterfly-lifetouch", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-allison-v-shutterfly-lifetouch" }, { "ai_passage": "I would, however, address the appellant's use of several fake case citations in his brief. An appellate brief containing nonexistent case citations or fake legal authority needlessly undermines the validity of a party's arguments. Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 448-49 (S.D.N.Y. 2023). Here, the appellant's brief—as noted by the appellee—contains several fake case citations in support of his arguments. It is unclear whether the fake cases were the result of fabrications on the part of artificial intelligence. See United States v. Hayes, 763 F. Supp. 3d 1054, 1064-65 (E.D. Cal. 2025) (describing characteristics of \"hallucinated case\" citations generated by artificial intelligence). Regardless, we should disregard any of the appellant's arguments supported by nonexistent cases because \"[a] fake opinion is not 'existing law' and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law.\" Mata, 678 F. Supp. 3d at 461.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Kendall E. Scheer v. Scheer Farms, LLC", "citation": null, "cited_authorities": [ "Mata v. Avianca", "See United States v. Hayes, 763 F" ], "court": "Kansas Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-05", "decision_id": "kanctapp-2026-kendall-e-scheer-v-scheer-farms", "disposition": "The court affirmed summary judgment, while a concurrence admonished the appellant over fake case citations and quotations in his brief.", "docket_number": "129,066", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2367/Scheer_v._Scheer_Farms_USA_5_June_2026.pdf", "state": "KS", "summary": "On 2026-06-05, in Kendall E. Scheer v. Scheer Farms, LLC, Kansas Court of Appeals affirmed summary judgment, while a concurrence admonished the appellant over fake case citations and quotations in his brief. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.", "text_sha256": "a7fb13e6448afcc05b6918a8f8a6f6567eba358d55dc81b1414fcc2be0c2e571", "topics": [ "fabricated-citations" ], "tracker_slug": "kendall-e-scheer-v-scheer-farms-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/kanctapp-2026-kendall-e-scheer-v-scheer-farms", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/kanctapp-2026-kendall-e-scheer-v-scheer-farms" }, { "ai_passage": "Petitioner on review filed a reply to the response that argued, among other things, that respondent on review’s \"response relies on authorities that cannot be located in the Oregon Reports.\" On March 26, 2026, respondent on review filed a response to the reply that addressed petitioner's other arguments but did not address the assertion about fabricated authorities. On April 10, 2026, this court issued a show cause order directing respondent on review to confirm, under penalty of perjury, each of the citations in his response, to explain how any erroneous citations came to be included in the pleading, and to show cause why the court should not strike his response or impose other sanctions. On April 24, 2026, respondent on review complied with this court's order. The response addressed each of the fabricated authorities filed, explained that respondent had used generative artificial intelligence (\"AI\") to create the pleading, and asserted that respondent on review was unaware that generative AI could generate fictitious authorities and inaccurate legal arguments. ORDER STRIKING RESPONDENT’S RESPONSE TO PETITION FOR REVIEW, IMPOSING SANCTION, AND GRANTING PETITIONER'S MOTION TO TAKE JUDICIAL NOTICE Appellate Court Administrator, Appellate Court Records Section, Oregon Supreme Court 1163 State Street, Salem, Oregon 97301-2563 (503) 986-5555 Page 2 of 3 Respondent on review stipulates that a financial sanction of $500 is appropriate.", "ai_tool_named": null, "archive_url": null, "case_name": "Mary McGreevy v. Adam Witkin", "citation": null, "cited_authorities": [], "court": "Supreme Court of Oregon", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-04", "decision_id": "orsupct-2026-mary-mcgreevy-v-adam-witkin", "disposition": "The court struck the response to the petition for review, imposed a $500 sanction, and granted judicial notice.", "docket_number": "S072692", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "A self-represented appellant filed a response using nonexistent or hallucinated authorities.", "currency": "USD", "monetary_penalty": 500, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2312/Witking_v._McGreevy_USA_4_June_2026.pdf", "state": "OR", "summary": "On 2026-06-04, in Mary McGreevy v. Adam Witkin, Supreme Court of Oregon struck the response to the petition for review, imposed a $500 sanction, and granted judicial notice. A self-represented appellant filed a response using nonexistent or hallucinated authorities. The monetary component was $500.", "text_sha256": "b231ade2266ae0dac9558e31dcc97b560c115ad1336148b82d25f0162879988d", "topics": [ "fabricated-citations" ], "tracker_slug": "mary-mcgreevy-v-adam-witkin", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/orsupct-2026-mary-mcgreevy-v-adam-witkin", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/orsupct-2026-mary-mcgreevy-v-adam-witkin" }, { "ai_passage": "The use of fake or misleading citations violates this rule and wastes the opposing party’s and the Court’s time by requiring them to parse through the citations to determine which points of law, if any, are accurate. See Perez v. Evans, 24-CV-356, 2025 WL 2726792, at *4 (S.D.N.Y. Sept. 25, 2025) (determining that a plaintiff’s use of “hallucinated” citations violated Rule 11). The plaintiff is warned that he must exercise caution in relying on AI software to draft court filings or to conduct legal research. The Court will impose sanctions for any further violations, including summary dismissal of his claims. SO ORDERED. ___________________________ ANN M. DONNELLY United States District Judge Dated: Brooklyn, New York June 4, 2026 s/Ann M.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Owens v. Select Portfolio Servicing, Inc.", "citation": "2026 WL 1413883", "cited_authorities": [ "See Perez v. Evans, 24-CV-356, 2025 WL 2726792, at *4 (S.D.N.Y. Sept. 25, 2025)", "Rule 11)" ], "court": "United States District Court for the Eastern District of New York", "court_code": "nyed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-04", "decision_id": "nyed-2026-owens-v-select-portfolio-servicing", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "14", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant submitted a filing using quotations that did not appear in the cited source and at least four nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2401/Owens_v._Portfolio_USA_4_June_2026.pdf", "state": "NY", "summary": "On 2026-06-04, in Owens v. Select Portfolio Servicing, Inc, 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 submitted a filing using quotations that did not appear in the cited source and at least four nonexistent or hallucinated authorities.", "text_sha256": "9ecd283c6774b82c251b0965e3b82969bcb2a9283c121b552d14091eec4ca50e", "topics": [ "fabricated-citations" ], "tracker_slug": "owens-v-select-portfolio-servicing-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nyed-2026-owens-v-select-portfolio-servicing", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyed-2026-owens-v-select-portfolio-servicing" }, { "ai_passage": "at 728. As a result, the Substitute Trustees have standing to foreclose. Thus, Brown’s motion to stay or dismiss did not raise a valid defense to the Substitute Trustees’ right to foreclose, and the circuit court therefore did not abuse its discretion in denying it without a hearing. JUDGMENT OF THE CIRCUIT COURT FOR BALTIMORE COUNTY AFFIRMED. COSTS TO BE PAID BY APPELLANT. In her reply brief, Brown cites to Brock, 430 Md. at 729 with a parenthetical quote: “production of a copy of the note does not prove possession of the original[.]” This quote does not appear in Brock, any other Maryland case, or, indeed, any case anywhere.", "ai_tool_named": null, "archive_url": null, "case_name": "Lafaye B. Brown v. James E. Clarke, et al.", "citation": null, "cited_authorities": [], "court": "Appellate Court of Maryland", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-04", "decision_id": "mdctapp-2026-lafaye-b-brown-v-james-e-clarke", "disposition": "The court affirmed the foreclosure rulings and noted that the appellant's reply brief used a quotation found nowhere in Maryland or other case law.", "docket_number": "C-03-CV-24-004807", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "A self-represented appellant filed a reply brief using quotations that did not appear in the cited source.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2368/Briwn_v._Clarke_USA_4_June_2026.pdf", "state": "MD", "summary": "On 2026-06-04, in Lafaye B. Brown v. James E. Clarke, et al, Appellate Court of Maryland affirmed the foreclosure rulings and noted that the appellant's reply brief used a quotation found nowhere in Maryland or other case law. A self-represented appellant filed a reply brief using quotations that did not appear in the cited source.", "text_sha256": "ce3b7c514728f37bbe1052ed99b7b7b524fff1cc06e486a46866dbe5ec88b580", "topics": [ "fabricated-citations" ], "tracker_slug": "lafaye-b-brown-v-james-e-clarke-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdctapp-2026-lafaye-b-brown-v-james-e-clarke", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdctapp-2026-lafaye-b-brown-v-james-e-clarke" }, { "ai_passage": "As an initial matter, we are troubled by Mother’s citation to fictitious cases and fictitious quotations throughout her appellate brief. “Such ‘hallucinated’ cases are typically a hallmark of the irresponsible use of regenerative artificial intelligence (A.I.)inlegaldrafting.”Slayv.Ross,379Ga.App.1,1(927SE2d 569)(2026).While Motherisprose,sheisnonethelessrequiredtofollowtherulesofthisCourt,andwe caution her that any future filings in this Court containing fictitious cases and/or fictitious quotations may result in the imposition of sanctions against her. See Court of Appeals Rule 7(e)(2) (“The panel of the Court ruling on a case, with or without motion, may by majority vote to impose a penalty not to exceed $10,000 against any party and/or a party’s counsel in any civil case in which there is a direct appeal, application for discretionary appeal, application for interlocutory appeal, or motion thatisdeterminedtobefrivolous.”);Modiv.India-Am.CulturalAss’n,367Ga.App. 572,574(2)(886SE2d378)(2023)(“Although[Appellant]isproceedingprose,[she] isnotrelievedof[her]obligationtoconformtothisCourt’srules.”)(quotationmarks omitted). AswehavejurisdictionofthisappealpursuanttoOCGA§5-6-34(a)(11),we hereby deny the Father’s motion to dismiss. Mother filed a motion to modify custody, and the trial order entered an order on February 13, 2024, which denied her motion to modify custody but modified the parenting plan, which included changing the exchange location for non-school days to both parents’ houses.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Washington v. Washington", "citation": null, "cited_authorities": [ "Rule 7(e)(2)" ], "court": "Court of Appeals of Georgia", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-04", "decision_id": "gactapp-2026-washington-v-washington", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "A26A0506", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2366/Washington_v._Washington_USA_4_June_2026.pdf", "state": "GA", "summary": "On 2026-06-04, in Washington v. Washington, Court of Appeals of Georgia 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 and multiple nonexistent or hallucinated authorities.", "text_sha256": "df325dc8458951b02c81d6087a302a9842ec581f6714e9d8bdbf033cacf727d6", "topics": [ "fabricated-citations" ], "tracker_slug": "washington-v-washington", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gactapp-2026-washington-v-washington", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gactapp-2026-washington-v-washington" }, { "ai_passage": "Judge Starnella concluded that pseudonymity is not warranted in this case because the record shows that the individuals that threatened Plaintiff already know his name and address, and that he has not faced 1 In his argument that Judge Starnella mischaracterized his request as a fishing expedition, Plaintiff cites to hallucinated cases and misattrib- utes conclusions that cannot be found in real cases. He cites a nonex- istent case, Diamond Fortress Techs., Inc. v. EverID, Inc., No. 19-337- LPS, 2022 WL 2239826, at *3–4 (D. Del. June 22, 2022), and gives the opposite holding of another case, Hard Drive Prods., Inc. v. Does 1-90, No. C11-03825 HRL, 2012 WL 1094653, *2–*3 (N.D. Cal. Mar. 30, 2012). This is a sufficient alternative ground for overruling his objec- tions. See Doc. 90 at 21:18–20 (“I am warning you that if you continue to miscite cases and misstate cases, I will likely recommend that the district judge impose filing restrictions on you.”). Case No. 1:25-cv-03129-DDD-KAS Document 115 filed 06/04/26 USDC Colorado pg 4 of 5 - 5 - any further threats. Plaintiff correctly notes that repeated threats are not strictly necessary, but he has not shown that Judge Starnella based her conclusions on an incorrect standard or incorrect information.", "ai_tool_named": null, "archive_url": null, "case_name": "Y.S. v. John Doe, et al.", "citation": null, "cited_authorities": [ "Inc. v. EverID", "Inc. v. Does 1-90, No. C11-03825 HRL, 2012 WL 1094653, *2–*3 (N.D. Cal. Mar. 30, 2012)" ], "court": "United States District Court for the District of Colorado", "court_code": "cod", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-04", "decision_id": "cod-2026-y-s-v-john-doe", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "1:25-cv-03129-DDD-KAS", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "A self-represented litigant submitted a filing using nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2521/YS_v._Doe_USA_4_June_2026.pdf", "state": "CO", "summary": "On 2026-06-04, in Y.S. v. John Doe, et al, the District of Colorado warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant submitted a filing using nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "text_sha256": "0e9467459b6f88ab757a1bec9a664a7f9b38facccdc91d343317188a994be7ce", "topics": [ "fabricated-citations" ], "tracker_slug": "y-s-v-john-doe-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cod-2026-y-s-v-john-doe", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cod-2026-y-s-v-john-doe" }, { "ai_passage": "motions and other papers that “strain[ed] the [district] [c]ourt’s ability to manage its docket efficiently.” After a four-month span in which she filed fifty-five motions, the court ordered that Peters “must request leave of court before filing any Motion, Notice, Request, or any other document.” Peters repeatedly violated this and other explicit court orders by filing discovery requests without seeking leave of court and filing motions exceeding a court- orderedpagelimit.Shealsoignoredcourtinstructionstoceasefilingmotions containing legal citations and quotations hallucinated by generative artificial intelligence. The court repeatedly struck her motions and discovery filings for failing to comply with its orders. Peters’ conduct was so disruptive that the magistrate judge observed in a December 2025 discovery hearing that Peterswas“excessivelyusingCourtresources”andhadmadeit“impossible to litigate this case.” Peters’conductculminatedinDecember2025whensherefusedtosit for a court-ordered follow-up deposition. She had sat for an initial deposition on December 3, 2025, but continually objected and refused to answer questions in what the court described as a “calculated campaign of obstruction.” At a hearing on December 8, the magistrate judge ordered Peters to sit for a follow-up deposition on December 12 and extended the discovery deadline to that date. Peters refused to appear for the follow-up deposition and invited Banner to seek dismissal.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Kisha Peters v. Banner Health", "citation": null, "cited_authorities": [], "court": "United States Court of Appeals for the Fifth Circuit", "court_code": "ca5", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-04", "decision_id": "ca5-2026-kisha-peters-v-banner-health", "disposition": "The court struck the defective appellate filings, admonished the appellant, and warned that additional violations could draw sanctions.", "docket_number": "26-20035", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2404/Peters_v._Banner_Health_USA_4_June_2026.pdf", "state": null, "summary": "On 2026-06-04, in Kisha Peters v. Banner Health, the Fifth Circuit struck the defective appellate filings, admonished the appellant, and warned that additional violations could draw sanctions. A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.", "text_sha256": "f9bb06bd99e0fa95a790a56254536ea021f0c488139178387d76c1ccb5987656", "topics": [ "fabricated-citations" ], "tracker_slug": "kisha-peters-v-banner-health", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca5-2026-kisha-peters-v-banner-health", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca5-2026-kisha-peters-v-banner-health" }, { "ai_passage": "Artificial Intelligence The Defendants contend that the Plaintiff’s memorandum in support of the instant motion contains two fabricated quotations, along with multiple quoted statements lacking citation to any authority, and that such deficiencies suggest that the memorandum was drafted using artificial The Plaintiff complains that the Defendants tookthe “position” throughout discovery “that neither the vehicular pursuit nor policies are at issue in this case.” [Doc. 63 at 4]. The Court notes, however, that neither the vehicular pursuit nor the county’s policies are, in fact, at issue in this case. The Plaintiff’s counsel has also failed to show proper conferral or attempt to confer regarding one motion to compel and two motions for sanctions that are currently pending in this matter. LCvR 7.1(b); see generally [Docs. 46, 61, 68]. intelligence and without adequate human verification. [Doc. 60 at 2, 4 n.1, 9 n.3, 14 n.4]. The Defendants further note that the Plaintiff did not file the required certification regarding use of artificial intelligence with the memorandum, in violation of the Court’s Standing Order Regarding the Use of Artificial Intelligence, No. 3:24-mc-00104-MR (W.D.N.C.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Wayne K. Smith, Sr. v. Polk County, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Western District of North Carolina", "court_code": "ncwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-03", "decision_id": "ncwd-2026-wayne-k-smith-sr-v-polk-county", "disposition": "The court ordered plaintiff's counsel to show cause about two fabricated quotations and compliance with the court's AI-use standing order.", "docket_number": "1:24-cv-00037-MR-WCM", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed an opening brief using quotations that did not appear in the cited source.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2271/Smith_v_Polk_County_et_al__ncwdc_USA_3_June_2026.pdf", "state": "NC", "summary": "On 2026-06-03, in Wayne K. Smith, Sr. v. Polk County, et al, the Western District of North Carolina ordered plaintiff's counsel to show cause about two fabricated quotations and compliance with the court's AI-use standing order. Counsel filed an opening brief using quotations that did not appear in the cited source.", "text_sha256": "12f3b36f2ff228cf06ecc54379afc6e72ce493df9f318674b515786a6cdc55aa", "topics": [ "fabricated-citations" ], "tracker_slug": "wayne-k-smith-sr-v-polk-county-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ncwd-2026-wayne-k-smith-sr-v-polk-county", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ncwd-2026-wayne-k-smith-sr-v-polk-county" }, { "ai_passage": "“The covenant of good faith and fair dealing cannot be relied upon to overcome the parol evidence rule and add terms to a contract that do not exist,” and is not “an ever[]flowing cornucopia of wished-for legal duties,” in that it “cannot giverise to new obligations not otherwise contained in a contract’s express terms.” DePeralta v. Dlorah, Inc., No. 11-1102- CV-SJ-ODS, 2012 WL 4092191, at *4 (W.D. Mo. Sept. 17, 2012) (internal quotation marks omitted). though there is no writing,” Doss v. Epic Healthcare Mgmt. Co., 901 S.W.2d 216, 221 (Mo. Ct.App. 1995), neither the Second Amended Complaint nor the proposed third amended complaint allege facts to support such modification, particularly as to the initial lease agreement. The only “ongoing negotiations” alleged were discussions that occurred after the initial lease agreement, and which ultimately were followed by the Amended and Restated Triple Net Lease that The Sourze signed. As indicated above, the Amended and Restated Triple Net Lease expressly excluded The Sourze’s use of the premises other than as an art gallery/event space. ... Westport Development’s motion to dismiss Count 1 of the SecondAmended Complaint is GRANTED, and Plaintiffs’third motion to amend is DENIED in relevant part because Count 1 of the proposed third amended complaint asserting a breach of contract claim against Westport Development is futile. 2. Murfin, Inc. and Hurt and Vos Nor does The Sourze assert a plausible claim for breach of contract (under any theory) against Murfin, Inc. or Hurt and Vos, whether in the Second Amended Complaint (as to Murfin, Inc.) or proposed third amended complaint (as to all three defendants). Murfin, Inc. is an entirely separate legal entity from Westport Development.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Euphoric, LLC et al. v. Westport Community Improvement District, et al.", "citation": null, "cited_authorities": [ "DePeralta v. Dlorah", "Doss v. Epic Healthcare Mgmt. Co., 901 S" ], "court": "United States District Court for the Western District of Missouri", "court_code": "mowd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-03", "decision_id": "mowd-2026-euphoric-v-westport-community-improvement-dist", "disposition": "The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.", "docket_number": "4:25-cv-00023-RK", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel 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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2275/Euphoric_v._Westport_USA_3_June_2026.pdf", "state": "MO", "summary": "On 2026-06-03, in Euphoric, LLC et al. v. Westport Community Improvement District, et al, the Western District of Missouri admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. Counsel 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.", "text_sha256": "149d2db430657cb7637d36c6a9933c015e828e69ac4de5575aaa52afdaefe196", "topics": [ "fabricated-citations" ], "tracker_slug": "euphoric-llc-et-al-v-westport-community-improvement-district-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mowd-2026-euphoric-v-westport-community-improvement-dist", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mowd-2026-euphoric-v-westport-community-improvement-dist" }, { "ai_passage": "10) contained citation errors which appeared to be “the result of using generative artificial intelligence without checking the citations generated by the program.” Dkt. 12 at 3. The Court ordered Petitioner’s counsel to show cause as to why they should not be sanctioned pursuant to Rule 11. Id. at 3–4. Within 24 hours, Julian Mansoor Daman—counsel responsible for drafting Petitioner’s briefs—filed a declaration explaining the origin of the errant citations. Dkt. 13. I. ORDER Federal Rule of Civil Procedure 11 “imposes a duty on attorneys to certify that they have conducted a reasonable inquiry and have determined that any papers filed with the court are well grounded in fact, legally tenable, and ‘not interposed for any improper purpose.’” Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 393 (1990).", "ai_tool_named": "Gemini", "archive_url": null, "case_name": "Fadi El Bitar v. Julio Hernandez", "citation": null, "cited_authorities": [ "Cooter & Gell v. Hartmarx Corp., 496 U", "Rule 11", "Federal Rule of Civil Procedure 11" ], "court": "United States District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-02", "decision_id": "wawd-2026-fadi-el-bitar-v-julio-hernandez", "disposition": "The court imposed a $1,000 monetary sanction for the defective legal authorities.", "docket_number": "2:26-cv-00919-TMC", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "Gemini", "conduct": "Counsel filed a petition using quotations that did not appear in the cited source.", "currency": "USD", "monetary_penalty": 1000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2255/El_bitar_v._Wamsley_USA_2_June_2026.pdf", "state": "WA", "summary": "On 2026-06-02, in Fadi El Bitar v. Julio Hernandez, the Western District of Washington imposed a $1,000 monetary sanction for the defective legal authorities. Counsel filed a petition using quotations that did not appear in the cited source. The monetary component was $1,000.", "text_sha256": "17c31e5f4e439a2567b47eaf6b1729ce7aee26a6e0859de464ecad39ea3700de", "topics": [ "fabricated-citations" ], "tracker_slug": "fadi-el-bitar-v-julio-hernandez", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wawd-2026-fadi-el-bitar-v-julio-hernandez", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-fadi-el-bitar-v-julio-hernandez" }, { "ai_passage": "Specifically, Defendants’ response to RLF’s Partial Motion to Dismiss asserts that Plaintiff relies on cases that do not stand for the propositions for which they are cited, and, even worse, RLF includes quotations from those cases that do not exist. (See ECF No. 19.) Two days after Defendants initially raised the GAI issues, RLF filed a response to the Motion for Judgment on the Pleadings. (ECF No. 20.) Then, three days after that, RLF filed a supplemental response. (ECF No. 23.) But, according to Defendants, those two filings contain more of the same issues that surfaced in RLF’s Partial Motion to Dismiss, and Plaintiff “remain(ed) steadfast in it misuse and abuse of GAI” even after being put on notice of the GAI issues. (ECF No. 24 at PageID 316.) For instance, the Response to the Motion for Judgment on the Pleadings cites to numbered paragraphs from RLF’s complaint that do not exist and to facts that the complaint does not allege. (See ECF No.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Western District of Tennessee", "court_code": "tnwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-02", "decision_id": "tnwd-2026-reaves-law-firm-pllc-v-baker-donelson-bearman", "disposition": "The court ordered Reaves Law Firm to pay costs for improper citations and directed counsel to send the order to professional regulators.", "docket_number": "2:25-cv-2623-SHL-atc", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel cited Press v. Vanderbilt University even though the court found the authority did not exist.", "currency": "USD", "monetary_penalty": 1, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2257/Reaves_Law_Firm_v._Baker_USA_2_June_2026.pdf", "state": "TN", "summary": "On 2026-06-02, in Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al, the Western District of Tennessee ordered Reaves Law Firm to pay costs for improper citations and directed counsel to send the order to professional regulators. Counsel cited Press v. Vanderbilt University even though the court found the authority did not exist.", "text_sha256": "97ccc50771a8fc253a607468133df3e7ff2d209405aa7285b7ca12873f38db7c", "topics": [ "fabricated-citations" ], "tracker_slug": "reaves-law-firm-pllc-v-baker-donelson-bearman-caldwell-berkowitz-pc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/tnwd-2026-reaves-law-firm-pllc-v-baker-donelson-bearman", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tnwd-2026-reaves-law-firm-pllc-v-baker-donelson-bearman" }, { "ai_passage": "149.) In addition, it appears Plaintiff has also been using some form of generative artificial intelligence resulting in citations which are hallucinations or other improper citations. (See Doc. 223 at 6-7 and 12-16). Defendants identify that in one of Plaintiff’s numerous responses, he made a total of “one hundred fifteen false citations.” (Doc. 186 at 4 n.2 (emphasis omitted).) This included “twenty-nine of the cases cited by - 7 - Plaintiff [that] do not exist as cited,” an “additional four cases [that] have been overturned, five cases [that] were cited for quotations that do not appear therein, and seventy-seven [that] do not contain the proposition for which they were cited.” (Id. (emphasis omitted); see also Doc. 186-1 (compiling the false citations).) “[W]hether created by generative artificial intelligence or not,” Plaintiff “submitting a filing containing false submissions . . . is unacceptable.” Simpson v. Portfolio Recovery Assocs., LLC, No. 24-CV-00094, 2025 WL 3684541, at *6 n.6 (W.D. Va. Dec. 19, 2025). ... This court finds that under the fourth factor in Cromer an alternative sanction will not “suffice[] to deter [Plaintiff] from making future filings” because, as Defendants explain, “after [Defendants] identified eight false citations in Plaintiff’s Final Amended Complaint, Plaintiff not only failed to correct these discrepancies, but still cited an additional - 8 - sixteen cases that either do not exist or fail to include the quoted language or cited propositions.” (Doc. 223 at 13 (emphasis omitted).) At the hearing, Plaintiff had no non- frivolous excuse for his continued use of irrelevant or non- existent citations.", "ai_tool_named": "generative artificial intelligence", "archive_url": null, "case_name": "Anthony Josue Grajales v. Santander Consumer USA Inc., et al.", "citation": null, "cited_authorities": [ "Simpson v. Portfolio Recovery Assocs" ], "court": "United States District Court for the Middle District of North Carolina", "court_code": "ncmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-02", "decision_id": "ncmd-2026-anthony-josue-grajales-v-santander-consumer", "disposition": "The court sanctioned the plaintiff $120, stayed the case until payment, and required copies of cited authorities with future filings.", "docket_number": "1:25-cv-00877-WO-JEP", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "generative artificial intelligence", "conduct": "A self-represented litigant filed a response using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 120, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2256/Grajales_v._Santander_USA_2_June_2026.pdf", "state": "NC", "summary": "On 2026-06-02, in Anthony Josue Grajales v. Santander Consumer USA Inc., et al, the Middle District of North Carolina sanctioned the plaintiff $120, stayed the case until payment, and required copies of cited authorities with future filings. A self-represented litigant filed a response using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities, and.", "text_sha256": "aec44af29a7a9eda9cefef2ad158291bc82028e3860e5d032f12bb0a820abf01", "topics": [ "fabricated-citations" ], "tracker_slug": "anthony-josue-grajales-v-santander-consumer-usa-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ncmd-2026-anthony-josue-grajales-v-santander-consumer", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ncmd-2026-anthony-josue-grajales-v-santander-consumer" }, { "ai_passage": "Boatner’s appeal violates several Missouri Supreme Court Rules, including the briefing requirements of Rule 84.04, and her amended brief includes fictitious cases generated by artificial intelligence (“A.I”), which prevent this Court from engaging in meaningful review. Accordingly, the appeal is dismissed. Additionally, given the frivolousness of the appeal, this Court awards $10,000 in damages to Hickerson, pursuant to Rule 84.19. Factual and Procedural Background On March 10, 2025, Boatner, acting pro se, filed a “Petition to Quiet Title” against Hickerson. Therein, Boatner sought to quiet title for a property on Capitol Drive in St. Louis County (“Property”). Because personal service of process was not successful on Hickerson, Boatner filed an application for service by publication. The trial court entered an order for service by publication. Then, on July 14, 2025, the trial court entered a default judgment in favor of Boatner.2 Rule 54.20(e) sets forth the requirements for proving service by publication, stating: Service by publication shall be proved by an affidavit showing the dates upon which and the newspaper in which the notice was published.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Boatner v. Hickerson", "citation": null, "cited_authorities": [ "Rule 84.04", "Rule 84.19", "Rule 54.20(e)" ], "court": "Missouri Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-02", "decision_id": "moctapp-2026-boatner-v-hickerson", "disposition": "The court imposed a $10,000 monetary sanction for the defective legal authorities.", "docket_number": "ED113978", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant cited Davis v. Bess even though the court found the authority did not exist.", "currency": "USD", "monetary_penalty": 10000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2253/Boatner_v._Hickerson_USA_2_June_2026.pdf", "state": "MO", "summary": "On 2026-06-02, in Boatner v. Hickerson, Missouri Court of Appeals imposed a $10,000 monetary sanction for the defective legal authorities. A self-represented appellant cited Davis v. Bess even though the court found the authority did not exist. The monetary component was $10,000.", "text_sha256": "3273947495daaa1ec20bb6d7e64cffa5c83f5ee28a7183dc511a42239c48f94c", "topics": [ "fabricated-citations" ], "tracker_slug": "boatner-v-hickerson", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/moctapp-2026-boatner-v-hickerson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/moctapp-2026-boatner-v-hickerson" }, { "ai_passage": "3 Judge Morris also noted Plaintiff's “troubling” pattern of misquotes, false quotations, and false citations throughout his briefs. This court likewise notes that in his briefing, Plaintiff stated the following proposition: “The Sixth Circuit likewise holds that a conviction on appeal is not final. Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016).” ECF No. 50, PageID.774 (emphasis in original). But that citation does not exist. The reporter leads to a Third Circuit case with a different title and having nothing to do with the issues presented, while a search for “Parris v. Pappas” turned up only a series of opinions from a District of Connecticut case, but again the subject matter appears to have nothing to do with this case. The court notes and refers this misrepresentation to the Magistrate Judge to consider in conjunction with all of Plaintiff's briefings, and her previous warning, as this case progresses. See ECF No. 43, PageID.715. Government Works.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Patrick C. Shaltry v. Donna Collins, et al.", "citation": "2026 WL 1556473", "cited_authorities": [ "Parris v. Pappas, 844 F", "Parris v. Pappas" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-02", "decision_id": "mied-2026-patrick-c-shaltry-v-donna-collins", "disposition": "The magistrate judge recommended dismissal and noted a false Sixth Circuit citation while denying further relief.", "docket_number": "25-13704", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant cited Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016) even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2279/Shaltry_v._Collins_USA_2_June_2026.pdf", "state": "MI", "summary": "On 2026-06-02, in Patrick C. Shaltry v. Donna Collins, et al, the Eastern District of Michigan magistrate judge recommended dismissal and noted a false Sixth Circuit citation while denying further relief. A self-represented litigant cited Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016) even though the court found the authority did not exist.", "text_sha256": "45f91c1fc016df7854f9ba49f8c905c2a4d648f43e3534020eeda28b51e1f306", "topics": [ "fabricated-citations" ], "tracker_slug": "patrick-c-shaltry-v-donna-collins-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-patrick-c-shaltry-v-donna-collins", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-patrick-c-shaltry-v-donna-collins" }, { "ai_passage": "The court identified sixteen instances of what appeared to be generative artificial intelligence (AI) hallucinations in the plaintiff’s filings, such as fabricated quotes and cases and misattributed quotes. Id. at 5–9. As the court explained, “[i]t is unacceptable for any party, represented or not, to submit filings that contain non-existent legal citations[,]” and “[p]arties who do so expose themselves to Rule 11 sanctions[.]” Id. at 5. The court ordered the plaintiff to show cause why the court should not sanction him for citing to cases that do not exist, fabricating quotes and asserting that cases stand for 1 The court filed an identical order in each case. certain propositions when they do not.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Branden Driver v. CNA Financial Corporation et al.", "citation": null, "cited_authorities": [ "Rule 11" ], "court": "United States District Court for the Eastern District of Wisconsin", "court_code": "wied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-01", "decision_id": "wied-2026-branden-driver-v-cna-financial", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "Case No. 25-cv-1204-pp", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant submitted a filing using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2274/Driver_v_CNA_Financial_Corporation_et_al_uSA_1_June_2026.pdf", "state": "WI", "summary": "On 2026-06-01, in Branden Driver v. CNA Financial Corporation et al, the Eastern District of Wisconsin warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and.", "text_sha256": "87641d02fb18bab1b90d71c227079d494a61a51fc6428f44e0753ddf220d6211", "topics": [ "fabricated-citations" ], "tracker_slug": "branden-driver-v-cna-financial-corporation-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wied-2026-branden-driver-v-cna-financial", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wied-2026-branden-driver-v-cna-financial" }, { "ai_passage": "Directing that all service in this matter be made upon [Defendant] Mendel Hendel via email to mmhendel@gmail.com; and 10. Granting such other and further relief as the Court deems just and proper.” (NYSCEF Doc. No. 133) a. Plaintiff's first and second branches of its motion: The first two (2) branches of relief sought by Plaintiff relate to this Court's April 2, 2026 order (NYSCEF Doc. No. 126) (“April 2026 Order”). Under CPLR § 2221 [d]: “A motion for leave to reargue: 1. shall be identified specifically as such; 2. shall be based upon matters of fact or law allegedly overlooked or misapprehended by the court in determining the prior motion, but shall not include any matters of fact not offered on the prior motion; and 3. ... There is an indication on the NYSCEF record on December 1, 2025 at 9:28 am by a clerk as follows: “CASE CLOSED--REMOVEDTOEASTERNDISTRICTASPER DOC #92,” referring to Mr. Hendel's purported “Notice of Removal.” There is another, later, comment by a different clerk on December 1, 2025 at 9:54 am as follows: “Closed on error.” *5 AsPlaintiffappearstobeunaware,theCourtcannotenter a decision on the merits of a motion that has been marked “closed.” The Court also cannot direct a “closed” motion to bereopenedforadecision.Theactionbytheclerktomarkthe within action and Plaintiff's Mot. Seq. 007 “closed” rendered this Court unable to enter any decision on Mot. Seq. 007. As such, this Court denied as moot Plaintiff's subsequent motion (Mot. Seq.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Sharei Torah v. Hendel", "citation": "2026 WL 1872259; 2026 N.Y. Slip Op. 50994(U)", "cited_authorities": [], "court": "Supreme Court of New York", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-01", "decision_id": "nysupct-2026-sharei-torah-v-hendel", "disposition": "The court struck defendants' amended answer and counterclaims and awarded plaintiff costs and fees for responding to unsupported citations.", "docket_number": "701131/2023", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant cited Ennis v. Lessing even though the court found the authority did not exist.", "currency": "USD", "monetary_penalty": 1, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2588/Sharei_Torah_v_Hendel_USA_1_June_2026.pdf", "state": "NY", "summary": "On 2026-06-01, in Sharei Torah v. Hendel, Supreme Court of New York struck defendants' amended answer and counterclaims and awarded plaintiff costs and fees for responding to unsupported citations. A self-represented litigant cited Ennis v. Lessing even though the court found the authority did not exist.", "text_sha256": "9f79d2478aadae4b77c63b94b26c2dab6efc7ee61b319c1c9b0e52274c1c5188", "topics": [ "fabricated-citations" ], "tracker_slug": "sharei-torah-v-hendel", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-sharei-torah-v-hendel", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-sharei-torah-v-hendel" }, { "ai_passage": "June 30 , 2023) (\"Because Johnson claims that Wells Fargo failed to deposit funds into his account- as opposed to transfer funds outside of his account-the provisions of section 1693h do not appear to apply to Plaintiff ' s allegations . \" ) . The complaint makes clear that Jonathan , not Cole , instructed the Bank to make the t cansfers . Col e cannot , therefore , sue under that provisi on of the EFTA and defendants ' motion to dismiss will therefore be allowed with respect to Count 1 . 1 To the extent that Cole alleges that Jonathan has assigned to him all claims arisi ng from these facts , the Court is unpersuaded . Even assuming, arguendo , that such claims can be legally assigned, Cole has made no showing that Jonathan actually did so and the Court cannot accept the contention on faith . To the extent that Cole also brings a claim under the Massachusetts state- l aw analogue , M.G. L. c .", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Richard A. Cole v. Midland States Bank, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Massachusetts", "court_code": "mad", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-01", "decision_id": "mad-2026-richard-a-cole-v-midland-states-bank", "disposition": "The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.", "docket_number": "1:25-cv-10216-NMG", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a motion using authorities used for propositions they did not support and a nonexistent rule or legal standard.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2273/Cole_v._Midland_State_Bank_USA_1_June_2026.pdf", "state": "MA", "summary": "On 2026-06-01, in Richard A. Cole v. Midland States Bank, et al, the District of Massachusetts admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant filed a motion using authorities used for propositions they did not support and a nonexistent rule or legal standard.", "text_sha256": "1ad302ade2b0108fb5a9f34f23d41a23dfd5cd043cc36f2d465c97f6980ea59b", "topics": [ "fabricated-citations" ], "tracker_slug": "richard-a-cole-v-midland-states-bank-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mad-2026-richard-a-cole-v-midland-states-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mad-2026-richard-a-cole-v-midland-states-bank" }, { "ai_passage": "Perez-Castillo’s opening brief was riddled with AI hallucinations. These included two 2 No. 25-1988 dozen fabricated quotations, seven cases wrongly identified as precedent from this circuit, erroneous legal propositions, and assertions of fact flatly contradicted by the record. Counsel for Perez-Castillo, Abdullah Salah, blamed these errors on another attorney with whom he had contracted to write the brief. That attorney, Farah Chalisa, did not enter an appearance in this case. In Salah’s telling, Chalisa used ChatGPT for “stylistic and grammatical review” that resulted in the hallucinations. To better understand what happened, we issued an order to show cause why both attorneys should not be sanctioned for their conduct. Both Salah and Chalisa responded, offering their respective sides of the story. Onthemerits,wedenyPerez-Castillo’spetitionforreview because it cannot succeed as a matter of law. As for attorney Salah, we impose a fine of $5,000 for violating this court’s rules of professional conduct and multiple Federal Rules of Appellate Procedure.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Heriberto Perez-Castillo v. Todd W. Blanche", "citation": null, "cited_authorities": [], "court": "United States Court of Appeals for the Seventh Circuit", "court_code": "ca7", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-06-01", "decision_id": "ca7-2026-heriberto-perez-castillo-v-todd-w-blanche", "disposition": "The court sanctioned counsel for appellate expenses, admonished him, and referred the matter for possible discipline.", "docket_number": "25-1988", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Counsel filed an opening brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 4997, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2246/Perez-Castillo_v._Blanche_USA_1_June_2026.pdf", "state": null, "summary": "On 2026-06-01, in Heriberto Perez-Castillo v. Todd W. Blanche, the Seventh Circuit sanctioned counsel for appellate expenses, admonished him, and referred the matter for possible discipline. Counsel filed an opening brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and authorities used for propositions they did not support.", "text_sha256": "fd506528f787b6f426c87ad628dce279414b9e86c2d3cba3fabfd6037dd78651", "topics": [ "fabricated-citations" ], "tracker_slug": "heriberto-perez-castillo-v-todd-w-blanche", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca7-2026-heriberto-perez-castillo-v-todd-w-blanche", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca7-2026-heriberto-perez-castillo-v-todd-w-blanche" }, { "ai_passage": "To the extent Father contends that this court has mandated dispositiveweightbeattributedtofactorsconcerningparental alienationasamatteroflaw,heisincorrect.Indeed,itappears that the authority to which Father cites in support of this contention either does not exist or does not stand for the proposition for which he asserts it does. Notably, Father's brief includes the following quotation: “Where the record demonstrates that one parent has engaged in a sustained campaign to alienate the children from the other parent, ... [t]he court must act to protect the best interests of Children and cannot permit a parent to benefit from such misconduct. [sic] E.D., 33 A.3d at 83 [sic]. Appellant's Brief at 39-40 (emphasis present in original, ending quotation marks missing in original). This Court can find no such case using the citation provided by Father, nor any other source for the quoted language. Rather, the citation provided directs this Court to Discover Bank v. Stucka, 33 A.3d 82 (Pa. Super. 2011), an opinion entirely unrelated to child custody and containing no discussion of parental alienation. Additionally, Father cites to this Court's opinion in S.M. v. J.M., 811 A.2d 621, 625 (Pa. Super. ... Shortly thereafter, on June 6, 2025, Father filed an additional petition for contempt, and a hearing was scheduled for June 12, 2025. At the outset of that hearing, the lower court, with the assistance of counsel, assembled a list of petitions which had at that time not yet been ruled upon. During that hearing, the lower court proposed consolidation of the outstanding petitions as each addressed “the same nucleus of activity,” and no party objected. Notes of Testimony 6/12/2025 at 6-10. Following testimony regarding mother's alleged contempt, the lower court noted that it would continue to hold the pending petitions in abeyance. Id.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Jaclyn Cocco v. Rosario Palmieri, Jr.", "citation": "2026 WL 1506862", "cited_authorities": [ "Court to Discover Bank v. Stucka, 33 A", "Father cites to this Court's opinion in S.M. v. J.M., 811 A" ], "court": "Supreme Court of Pennsylvania", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-29", "decision_id": "pasupct-2026-jaclyn-cocco-v-rosario-palmieri-jr", "disposition": "The court affirmed and observed that an asserted parental-alienation authority could not be located.", "docket_number": "2429 EDA 2025", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2242/Cocco_v._palmieri_USA_29_May_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "d68e9a6984faf56bd84a0ad0de40ef7fa1072c6e6631ffe20a39e5a8c3063e0a", "topics": [ "fabricated-citations" ], "tracker_slug": "jaclyn-cocco-v-rosario-palmieri-jr", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pasupct-2026-jaclyn-cocco-v-rosario-palmieri-jr", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pasupct-2026-jaclyn-cocco-v-rosario-palmieri-jr" }, { "ai_passage": "Page 9 of 12 Most glaringly, in opposition to the Police Department’s motion to dismiss, Trauger represents non-existent assertions and cases from the Police Department’s brief. See Pl.’s Br. in Opp’n to Def. Police Department’s Mot. to Dismiss, doc. 34 at 3-5. This appears to indicate one of the hallmarks of generative AI use: hallucination.3 For example, Trauger states that the Police Department cited “Will v. Michigan Dep’t of State Police, 491 U.S. 58 (1989), and Estate of Lagano v. Bergen Cty. Prosecutor’s Office, 769 F.3d 850 (3d Cir. 2014), to assert it is a state entity immune from suit (Doc. 30 at 8-10).” Id. at 3. Nowhere in its briefs does the Police Department cite to Will or Lagano. See doc. 30; see also Def. Police Department’s Reply Br., doc. 36. Nor does it assert that “it is a state entity immune from suit,” (doc. 34 at 3) as Trauger asserts, but rather that it is a municipal police department. See doc.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Trauger v. Columbia County District Attorney's Office et al.", "citation": null, "cited_authorities": [ "Will v. Michigan Dep’t of State Police, 491 U", "Estate of Lagano v. Bergen Cty. Prosecutor’s Office, 769 F" ], "court": "United States District Court for the Middle District of Pennsylvania", "court_code": "pamd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-29", "decision_id": "pamd-2026-trauger-v-columbia-county-district-attorneys-o", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "4:25-CV-01469", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed opposition papers using nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2278/Trauger_v._Columbia_County_District_Attorneys_Office_USA_29_May_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "5d3c9ef59d78d02c61de6c19a1621d2c716f3d8adcc2bad30cbc5a521e5653ef", "topics": [ "fabricated-citations" ], "tracker_slug": "trauger-v-columbia-county-district-attorneys-office-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pamd-2026-trauger-v-columbia-county-district-attorneys-o", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pamd-2026-trauger-v-columbia-county-district-attorneys-o" }, { "ai_passage": "at ¶ 73.) Garcia alleges that the arrest affidavit relied upon the fabricated autopsy and forensic report by Eikelenbloom and Eikelenbloom-Schieveld but purposefully omitted other exonerating information. (Id. at ¶¶ 74, 76.) Specifically, he asserts the arrest affidavit made no mention of: • The fact that Jones’ autopsy definitively concluded that she died by suicide, or that the doctors who conducted the autopsy were adamant that it was medically impossible that Garcia had murdered Jones; • That the coroner originally determined Jones’ death was a suicide and that the death certificate was only changed to “undetermined” by a high school graduate after years of pressure from MVPD officers and Jones’ family; • Jones’ long history of depression and suicidality; • A traffic stop that took place the day prior to Jones’ death that caused her to miss her probation meeting and led her to spiral into a deepening depressing that she would be sent back to prison; • That Jones lost her new apartment due to her heavily re-engaged drug use immediately prior to her death, that ... ... Rule 12(b)(6) Under Rule 12(b)(6), a party may move to dismiss a claim in a complaint for “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). “The court’s function on a Rule 12(b)(6) motion is not to weigh potential evidence that the parties might present at trial, but to assess whether the plaintiff’s complaint alone is legally sufficient to state a claim for which relief may be granted.” Dubbs v. Head Start, Inc., 336 F.3d 1194, 1201 (10th Cir.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Garcia v. City of Monte Vista, Colorado et al", "citation": null, "cited_authorities": [ "Dubbs v. Head Start", "Rule 12(b)(6)", "Fed. R. Civ. P. 12(b)(6)" ], "court": "United States District Court for the District of Colorado", "court_code": "cod", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-29", "decision_id": "cod-2026-garcia-v-city-of-monte-vista-colorado", "disposition": "The court ordered counsel to show cause why sanctions should not issue for relying on an allegedly fabricated autopsy and forensic report.", "docket_number": "Civil Action No. 25-cv-0769-WJM-KAS", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2270/Garcia_v._City_of_Monte_Vista_Colorado_et_al_USA_29_May_2026.pdf", "state": "CO", "summary": "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.", "text_sha256": "e87bba6f1978862059c71759ecd55c7de36c859ef27e235d0c8d61edd1c3ebcb", "topics": [ "fabricated-citations" ], "tracker_slug": "garcia-v-city-of-monte-vista-colorado-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cod-2026-garcia-v-city-of-monte-vista-colorado", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cod-2026-garcia-v-city-of-monte-vista-colorado" }, { "ai_passage": "Whether the trial court entered judgment despite Appellee initiating the state court action without proper notice to Appellant, and whether this lack of notice constitutes a fundamental procedural defect warranting reversal[;] The alleged contents of the USB drive do not appear anywhere in the record. 3. Whether the trial court violated Appellant’s procedural due process rights by failing to review the full record or provide Appellant with a meaningful opportunity to be heard before rendering the final judgment[;] 4. Whether the trial court abused its discretion by entering judgment while critical dispositive motions—including a Motion to Vacate the Order Granting Retention and a Motion for Sanctions—remained pending, unopposed, and unadjudicated[; and] 5. Whether the trial court failed to address or acknowledge Appellant’s formal and noticed concerns about the misconduct of its own court coordinator Tracy J Laffoon, thereby depriving Appellant of an impartial forum and compounding the denial of procedural due process. Jennings has forfeited her complaints due to inadequate briefing. Notwithstanding Jennings’s forfeited complaints, we conclude that the trial court did not err when it confirmed the arbitration award. A. Standard of Review Texas law favors arbitration. Hoskins v. Hoskins, 497 S.W.3d 490, 494 (Tex. 2016); Brady v. Brady, Nos.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Christian Lavell Jennings v. Vandergriff Honda", "citation": null, "cited_authorities": [ "Standard of Review Texas law favors arbitration. Hoskins v. Hoskins, 497 S", "Brady v. Brady" ], "court": "Court of Appeals of Texas", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-28", "decision_id": "texapp-2026-christian-lavell-jennings-v-vandergriff-honda", "disposition": "The court affirmed the judgment and noted that the appellant's briefing relied on a nonexistent case and fabricated quotations.", "docket_number": "25-00429", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2277/Christian_Lavell_Jennings_v._Vandergriff_Honda_USA_28_May_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "31c7a845d3c48fbd96b06efe844e5fb002cd4f95ed8309824a28f6f61f73b887", "topics": [ "fabricated-citations" ], "tracker_slug": "christian-lavell-jennings-v-vandergriff-honda", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp-2026-christian-lavell-jennings-v-vandergriff-honda", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp-2026-christian-lavell-jennings-v-vandergriff-honda" }, { "ai_passage": "*1 Editor's Note: This document contains discussion of unverified citations, likely generated by AI tools used by a party or counsel. These citations are not attributable to the Court. The unverified citations have been preserved as part of the official record, but links are unavailable. Part 11M Motion Date 02/12/2026 Motion Seq. No. 002 Decision + Order on Motion Present: Hon. Lyle E. Frank, Justice. The following e-filed documents, listed by NYSCEF document number (Motion 002) 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62 were read on this motion to/for VACATE - DECISION/ ORDER/JUDGMENT/AWARD. Upon the foregoing documents, defendants' motion to vacate is denied and plaintiff's cross-motion is denied as moot. Defendants move to vacate a default judgment entered on or about August 21, 2025, notice of entry was filed August 26, 2025, based on an Order dated October 31, 2019 signed by the Honorable Alan Marin. ... It appears undisputed that the complaint does not require dismissal pursuant to CPLR § 3215(c) and that contrary to its moving papers, it is also conceded on reply that 22 NYCRR 202.48 is inapplicable. Defendants have simply failed to establish entitlement to the relief it seeks. The argument that it is somehow prejudiced now, 6 years after default judgment was awarded by an Order and Decision of this Court, by plaintiff's enforcement actions is without merit.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Strategic Funding Source, Inc. v. STI-NY, LLC", "citation": "2026 WL 1587346", "cited_authorities": [ "22 NYCRR 202.48" ], "court": "Supreme Court of New York", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-28", "decision_id": "nysupct-2026-strategic-funding-source-v-sti-ny", "disposition": "The court awarded $2,000 in costs or fees caused by the defective legal authorities.", "docket_number": "No. 651711/2019", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a motion using authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 2000, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2365/Strategic_Funding_Source_Inc_v_STI-NY_LLC_USA_28_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "c72342baf1e992acb08dfb10ed8fd1b5b9b4f6a83f5cda90e47763cdc42495a7", "topics": [ "fabricated-citations" ], "tracker_slug": "strategic-funding-source-inc-v-sti-ny-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-strategic-funding-source-v-sti-ny", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-strategic-funding-source-v-sti-ny" }, { "ai_passage": "2026) (stating that citing “even a single fake case” is sanctionable conduct). And when litigants misrepresent the law, they waste judicial resources. Pro se litigants who have engaged in similar behavior have been subjected to sanctions such as the striking of filings with factitious citations, dismissal of the case, and monetary penalties. See Sanders, 176 Fed. Cl. at 170 (collecting cases); Evans v. Robertson, No. 24-13435, 2025 WL 3126852, at *4 (E.D. Mich. Nov. 7, 2025) (striking filings with factitious citations); Ali v. IT People Corp., Inc., No. 2:25-CV-10815, 2025 WL 2682622, at *3 (E.D. Mich. Sept. 19, 2025) (ordering the plaintiff to pay $200.00 to the defendant’s attorney for each factitious citation). The Court warns Plaintiffs that factitious citations will not be tolerated and that they may be sanctioned if future filings contain factitious citations, including but not limited to striking of filings or dismissal. III. Conclusion For the reasons set forth above, Plaintiffs’ objections are OVERRULED. (ECF No. 25.) IT IS SO ORDERED. Dated: May 28, 2026 s/Judith E.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Boyle, et al. v. Steven Kramer", "citation": null, "cited_authorities": [ "Evans v. Robertson, No. 24-13435, 2025 WL 3126852, at *4 (E.D. Mich. Nov. 7, 2025)", "Ali v. IT People Corp" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-28", "decision_id": "mied-2026-boyle-v-steven-kramer", "disposition": "The court warned that future filings containing fabricated legal authorities may lead to sanctions.", "docket_number": "25-13857", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2231/Boyle_v._Kramer_USA_28_May_2026.pdf", "state": "MI", "summary": "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.", "text_sha256": "c03b6250ca849dd63cec2cac8a697d2b5480a009cfb7a805ba81ef1827a27742", "topics": [ "fabricated-citations" ], "tracker_slug": "boyle-et-al-v-steven-kramer", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-boyle-v-steven-kramer", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-boyle-v-steven-kramer" }, { "ai_passage": "RESPONDENTS MEMORANDUM OPINION AND ORDER In reviewing Petitioners’ Response to Respondents’ Motion to Dismiss (DN 61), the Court identified a series of citations and quotations that appear to be generative artificial intelligence (“AI”) hallucinations. Petitioners’ counsel—Daniel N. Thomas and Mary E. Jocelyn—were ordered to show cause why they should not be sanctioned pursuant to Fed. R. Civ. P. 11(b)(2) and (c), and the inherent power of the Court. (Show Cause Order, DN 65). Fed. R. Civ. P. 11 requires lawyers to certify that their “claims, defenses, and other legal contentions are warranted by existing laworby a nonfrivolous argument for extending,modifying, or reversing existing law or for establishing new law.” Fed. R. Civ. P. 11(b)(2). “If, after notice and a reasonable opportunity to respond, the court determines that Rule 11(b) has been violated, the court may impose an appropriate sanction upon any attorney, law firm, or party that violated the rule or is responsible for the violation.” Fed. R. Civ. P. 11(c)(1). Whether to impose sanctions under Fed. R. Civ. P. 11 “is a matter of judicial discretion.” LinearGrp.Servs., LLC v. Attica Automation,Inc.,No.13-10108,2014WL 3400714,at *14(E.D. Mich. July 11, 2014) (collecting federal authorities).", "ai_tool_named": "generative artificial intelligence", "archive_url": null, "case_name": "Roger Patel et al. v. Chandresh Patel et al.", "citation": null, "cited_authorities": [ "LLC v. Attica Automation", "Fed. R. Civ. P. 11(b)(2)", "Fed. R. Civ. P. 11", "Rule 11(b)", "Fed. R. Civ. P. 11(c)(1)" ], "court": "United States District Court for the Western District of Kentucky", "court_code": "kywd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-28", "decision_id": "kywd-2026-roger-patel-v-chandresh-patel", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "4:24-CV-00053-GNS", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "generative artificial intelligence", "conduct": "Counsel filed a response using quotations that did not appear in the cited source and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2584/Patel_v._Patel_USA_7_July_2026.pdf", "state": "KY", "summary": "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.", "text_sha256": "e3a0a579ff850aa19d997de329ddef34094c84853759a291695bf9a660f8e07d", "topics": [ "fabricated-citations" ], "tracker_slug": "roger-patel-et-al-v-chandresh-patel-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/kywd-2026-roger-patel-v-chandresh-patel", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/kywd-2026-roger-patel-v-chandresh-patel" }, { "ai_passage": "The Public Guardian points out that, throughout her brief, the Mother misstates the facts or holdings of cases she citedinsupportofherarguments,incorrectlycitesothers,and referencescasesthatdonotexist.ThePublicGuardianargues that the Mother's reliance on fictitious case holdings violates Illinois Supreme Court Rule 341(h)(7) (eff. Oct. 1, 2020) and asks us to find the Mother's arguments forfeited. “ ‘[B]ecause the merits of the case can be ascertained from the record and we have the benefit of *** cogent brief[s]’ from the State and the Public Guardian, we will consider the merits” of the Mother's arguments. In re Es. C., 2021 IL App (1st) 210197, ¶ 13 (quoting Antonson v. Department of Human Services, 2021ILApp(1st)192272-U,¶18).However,simultaneously with this decision, we issued a rule to show cause order to the Mother's counsel, requiring her to file a response addressing these issues. In the event we find sanctions are warranted, we will issue a separate written order imposing the sanction. In re M.H., M.L., and M.H., Minors (The People of the State of Illinois, Petitioner-Appellee,..., Not Reported in N.E. Rptr.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "In re M.H., M.L., and M.H., Minors", "citation": "2026 IL App (1st) 250013-U", "cited_authorities": [ "Antonson v. Department of Human Services, 2021ILApp(1st)", "Rule 341(h)(7)" ], "court": "Appellate Court of Illinois, First District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-28", "decision_id": "illappct1-2026-in-re-m-h-m-l-and-m-h-minors", "disposition": "The court ordered mother to show cause within fourteen days why sanctions should not be imposed for fictitious authorities.", "docket_number": "25-0013", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a response using nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2240/In_re_MH_ML_and_MH_Minors_USA_28_May_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "e2f7bf08d4691d9981350f41d32cfd4544d002739784ad80f776811d77818694", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-m-h-m-l-and-m-h-minors", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/illappct1-2026-in-re-m-h-m-l-and-m-h-minors", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illappct1-2026-in-re-m-h-m-l-and-m-h-minors" }, { "ai_passage": "Instead, they merely declared that they could \"cure[]\" any deficiencies and that the 4 In addition to misrepresenting the holdings of several cases in their opening appellate brief, Solano and Maxilin also referenced quotations that do not appear in those cases or in any case that we have been able to find. Then, even after Barton pointed out these errors, Solano and Maxilin filed a reply brief that again cited cases for propositions that the cases do not support and quoted language that the cases do not contain. - 21 - district court had \"misapplied the Duxbury standard\" in dismissing their complaint. These conclusory assertions do \"no more than reiterate the[ir] [earlier] arguments.\" Palmer, 465 F.3d at 30. And a motion for reconsideration is \"not a promising vehicle for revisiting a party's case and rearguing theories previously advanced and rejected.\" Id. Solano and Maxilin again misrepresent our case law in claiming that we have \"repeatedly emphasized\" that a \"district court abuses its discretion when it fails to articulate any rationale for denying\" a Rule 59(e) motion. None of the cases they cite stand for such a proposition.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "USA ex rels. v. Barton Associates, Inc.", "citation": null, "cited_authorities": [ "Rule 59(e)" ], "court": "United States Court of Appeals for the First Circuit", "court_code": "ca1", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-28", "decision_id": "ca1-2026-ex-rels-v-barton-associates", "disposition": "The court affirmed dismissal and noted that appellants misrepresented authorities and quoted language absent from cited cases.", "docket_number": "25-1309", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a reply brief using quotations that did not appear in the cited source and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2230/USA_v._Barton_USA_28_May_2026.pdf", "state": null, "summary": "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.", "text_sha256": "3c555c78e3bf3ef7cd153a61b1fecd14593cb1cc4698371c19c2f2f65620c5be", "topics": [ "fabricated-citations" ], "tracker_slug": "usa-ex-rels-v-barton-associates-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca1-2026-ex-rels-v-barton-associates", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca1-2026-ex-rels-v-barton-associates" }, { "ai_passage": "1-A, Complainant, Oklahoma Bar Association, caused documentation to be transmitted to the Chief Justice of this Court following public reprimand and public censure in the states of Texas, Tennessee, and Alabama based on a sanctions order in the United States District Court for the Northern District of Alabama for using generative artificial intelligence to fabricate citations in two motions. STATE OF OKLAHOMA ex rel. OBA v. REEVES 2026 OK 37 Decided: 05/27/2026 SUPREME COURT OF THE STATE OF OKLAHOMA NOTICE: THIS OPINION HAS NOT BEEN RELEASED FOR PUBLICATION. UNTIL RELEASED, IT IS SUBJECT TO REVISION OR WITHDRAWAL. State of Oklahoma, ex rel., Oklahoma Bar Association, Complainant, v. Matthew Brett Reeves, Respondent. ORIGINAL PROCEEDING FOR ATTORNEY DISCIPLINE RESPONDENT PUBLICLY REPRIMANDED. Gina L. Hendryx, General Counsel, Oklahoma Bar Association, Oklahoma City, Oklahoma, for Complainant. Matthew B. Reeves, Respondent, Pro Se. Darby, J.: I. BACKGROUND ¶1 Pursuant to Rule 7.7 of the Rules Governing Disciplinary Proceedings (RGDP), 5 O.S.2021, ch. 1, app. 1-A, Complainant, Oklahoma Bar Association (OBA) caused documentation in this attorney disciplinary proceeding to be transmitted to the Chief Justice of this Court on December 2, 2025, following the public reprimand of Respondent, Matthew Brett Reeves, in Texas, on November 4, 2025, based upon similar discipline imposed in the United States District Court for the Northern District of Alabama.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves", "citation": "2026 OK 37", "cited_authorities": [ "STATE OF OKLAHOMA ex rel. OBA v. REEVES 2026 OK 37 Decided", "Rule 7.7" ], "court": "Supreme Court of Oklahoma", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "oksupct-2026-state-of-oklahoma-ex-rel-oklahoma-bar-associat", "disposition": "The court publicly reprimanded the attorney as reciprocal discipline for ChatGPT-generated citations used in federal filings.", "docket_number": null, "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Counsel filed a motion using authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2227/STATE_OF_OKLAHOMA_ex_rel._OBA_v._REEVES.pdf", "state": "OK", "summary": "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.", "text_sha256": "e977ac0053d5bc59cb5c51fd662341bf591304f79eac7812683198ff169c4a00", "topics": [ "fabricated-citations" ], "tracker_slug": "oba-v-reeves", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/oksupct-2026-state-of-oklahoma-ex-rel-oklahoma-bar-associat", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/oksupct-2026-state-of-oklahoma-ex-rel-oklahoma-bar-associat" }, { "ai_passage": "Warning About Fake Citations Plaintiff cites a fictitious case, “Moore v. Alliance Credit Union,” which he falsely claims was decided by the United States Supreme Court on January 14, 2025, and “addressed the legality of mortgage loans based on fiat currency and its implications on constitutional rights.” ECF No. 1 at 4. He claims, falsely, that the Supreme Court held that “foreclosure proceedings based on a mortgage loan derived from fiat currency were deemed to violate Zachary Moore’s constitutional rights under the Fifth, Thirteenth, and Fourteenth Amendments.” Id. The Second Circuit has explained that a party’s attempt to persuade a court or oppose an adversary by relying on non-existent precedent “is an abuse of the adversary system.” Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024); see also Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 461 (S.D.N.Y.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Polanco v. Himalayan Real Estate LLC, et al.", "citation": null, "cited_authorities": [ "Moore v. Alliance Credit Union", "Park v. Kim, 91 F", "Mata v. Avianca" ], "court": "United States District Court for the Eastern District of New York", "court_code": "nyed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "nyed-2026-polanco-v-himalayan-real-estate", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "1:25-cv-06939-HG-JAM", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant cited Moore v. Alliance Credit Union even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2217/Polanco_v._Driscoll_USA_27_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "f5662fe17fede7dadd46e48706b32e77b535f9a7c65da1e1d498eca6440c4d18", "topics": [ "fabricated-citations" ], "tracker_slug": "polanco-v-himalayan-real-estate-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nyed-2026-polanco-v-himalayan-real-estate", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyed-2026-polanco-v-himalayan-real-estate" }, { "ai_passage": "By order to show cause datedJanuary14,2026,thisCourtdirectedthepartiestoshow cause before this Court why an order should not be made and entered imposing sanctions and/or costs, if any, as this Court may deem appropriate, against the appellant pursuant to 22 NYCRR 130–1.1 for filing a brief containing fabricated legal authority. The motion was held in abeyance and referred to the panel of Justices hearing the appeal for determination upon the argument or submission thereof. Kevin A. Julien, Brooklyn, NY, appellant pro se. Geanine Towers, Brooklyn, NY, for respondent. WOOTEN, J. This appeal presents this Court with the opportunity to address an emerging issue with broad and significant implications—the usage of generative artificial intelligence(hereinafterGenAI)indraftingappellatebriefs— which has the potential to produce misleading or inaccurate information,includingcitationstononexistentcases.Wehold that the unverified usage of GenAI to draft an appellate brief containing false information constitutes frivolous conduct warranting the imposition of a sanction, even when the offending party is a pro se litigant. COLLEEN D. DUFFY, J.P. PAUL WOOTEN CARL J. LANDICINO SUSAN QUIRK, JJ. Argued—January 8, 2026 OPINION & ORDER *1 I. Relevant Factual Background The parties, who were never married, are the parents of a child, born in June 2020.", "ai_tool_named": "GenAI", "archive_url": null, "case_name": "In the Matter of Kevin A. Julien v. Danielle M. Arthur", "citation": "2026 WL 1476261; 2026 N.Y. Slip Op. 03308", "cited_authorities": [ "22 NYCRR 130–1.1" ], "court": "Supreme Court of New York, Appellate Division, Second Department", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "nyappdiv2-2026-in-matter-of-kevin-a-julien-v-danielle-m-arthu", "disposition": "The court imposed a $250 sanction on the self-represented appellant for a brief prepared with unverified generative AI.", "docket_number": "(Docket Nos. V-4283-21,V-4283-21/23B", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GenAI", "conduct": "A self-represented appellant filed an appellate brief using unsupported or inaccurate legal authorities.", "currency": "USD", "monetary_penalty": 250, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2249/In_the_Matter_of_Kevin_A_Julien_appellant_v_Danielle_M_Arthur_USA_27_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "2a51681b984ecf741803b1913977bfc1ca87373de85b90dc216ed3f8bfb097a2", "topics": [ "fabricated-citations" ], "tracker_slug": "in-the-matter-of-kevin-a-julien-v-danielle-m-arthur", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nyappdiv2-2026-in-matter-of-kevin-a-julien-v-danielle-m-arthu", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyappdiv2-2026-in-matter-of-kevin-a-julien-v-danielle-m-arthu" }, { "ai_passage": "Sinegal’s appellate and reply briefs contain citations to cases that do not exist or donotstandforthepropositionforwhichtheyarecited. Thissuggeststhepossibilitythat he used generative artificial intelligence to prepare his briefs. If that is the case, we again “stress that self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.” Luke v. Dep’t. of Health and Human Servs., 29 N.W.3d 635, 636 (Iowa Ct. App. 2025). When considering whether Sinegal established excusable neglect, relevant considerations include timeliness of Sinegal’s filings,“whether [he] intendedtodefend,whether[he]assertedameritoriousdefenseingoodfaith, andwhether[he]ignoredorwillfullydefiedtherulesof procedure.” Id. The district court’s ruling took these considerations into account, and we agree with its analysis and conclusions. Accordingly, we affirm without further opinion. Iowa Ct. R. 21.26(1)(d)(e) (authorizing memorandum opinions when“[a] full opinion would not augment or clarify existing case law”). AFFIRMED.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Christ Apostolic Temple, Inc., Dwight Reed and Jordan Reed v. Demetrius Sinegal, et al.", "citation": null, "cited_authorities": [ "Luke v. Dep’t. of Health and Human Servs., 29 N" ], "court": "Iowa Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "iowactapp-2026-christ-apostolic-temple-dwight-reed-and-jordan", "disposition": "The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.", "docket_number": "24-1896", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a reply brief using nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2216/Christ_Apostolic_v._Sinegal_USA_May_2026.pdf", "state": "IA", "summary": "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.", "text_sha256": "faccb67027006a8d809676cd36bf113e818596e3040c35c7486423a702efae09", "topics": [ "fabricated-citations" ], "tracker_slug": "christ-apostolic-temple-inc-dwight-reed-and-jordan-reed-v-demetrius-sinegal-et-a", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/iowactapp-2026-christ-apostolic-temple-dwight-reed-and-jordan", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/iowactapp-2026-christ-apostolic-temple-dwight-reed-and-jordan" }, { "ai_passage": "These types of AI-hallucinated arguments are just as egregious as a citation to non-existent law. See Clerk of Court & Comptroller for 13th Judicial Circuit, Hillsborough Cnty. v. Rangel, 427 So. 3d 1069, 1071 (Fla. 2d DCA 2025) (sanctioning counsel for filing a brief that, among other things, “misstated court holdings”). Pro se litigants and attorneys are responsible for their AI-generated filings and may be subject to sanctions for filings that contain fictitious authority or “cite actual cases for inaccurate legal propositions.” Hessert v. Hessert, 51 1 This Court has seen this AI-hallucinated argument often. Seeing it at all is too often. Fla. L. Weekly D520 (Fla. 6th DCA March 20, 2026). Pro se litigants are not held to a lesser standard. Goya v. Hayashida, 418 So. 3d 652, 655 (Fla. 4th DCA 2025). The delay in filing a UCCJEA affidavit does not deprive the trial court of jurisdiction or void the orders entered before the affidavit was filed. Holub v. Holub, 54 So. 3d 585, 588 (Fla.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Robert Hinton Avery v. Danielle Beauzil", "citation": null, "cited_authorities": [ "Hillsborough Cnty. v. Rangel, 427 So", "Hessert v. Hessert, 51 1 This Court has seen this AI-hallucinated argument often", "Pro se litigants are not held to a lesser standard. Goya v. Hayashida, 418 So", "Holub v. Holub, 54 So" ], "court": "District Court of Appeal of Florida, Fourth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "fladistctapp4-2026-robert-hinton-avery-v-danielle-beauzil", "disposition": "The court barred the appellant from future pro se filings in the case unless signed by a Florida Bar member.", "docket_number": "4D2026-0406", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a brief using nonexistent or hallucinated authorities, authorities used for propositions they did not support, and a nonexistent rule or legal standard.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2212/Avery_v._Beauzil.pdf", "state": "FL", "summary": "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.", "text_sha256": "ab40c0f25517f8619fd5b7097022cdb6eb218238c98f979c00ad2d0b8e18692d", "topics": [ "fabricated-citations" ], "tracker_slug": "robert-hinton-avery-v-danielle-beauzil", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-robert-hinton-avery-v-danielle-beauzil", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-robert-hinton-avery-v-danielle-beauzil" }, { "ai_passage": "We write briefly, however, to address concerns regarding multiple quotations from the trial transcript contained in Appellant’s initial brief that do not appear to be found anywhere in the actual trial transcript or otherwise in the Record. In consideration of the arguments made on this point in the parties’ briefs, as well as during oral argument, we refer this matter to the Florida Bar for appropriate action. See Eclectic Synergy, LLC v. Seredin, et al., No. 4D26- 0781 (Fla. 4th DCA May 27, 2026) (citing Russell v. Mells, 426 So. 3d 913, 920 (Fla. 2d DCA 2025) (“When a lawyer cites imaginary legal authorities to our court as if they were law, we are compelled to refer that lawyer to the Bar because of the professional rules of conduct.”); Fla. Code of Jud. Conduct, Canon 3D(2) (“A judge who receives information or has actual knowledge that substantial likelihood exists that a lawyer has committed a violation of the Rules Regulating The Florida Bar shall take appropriate action.”); R. Regulating Fla.", "ai_tool_named": null, "archive_url": null, "case_name": "Innocent v. Meraki Installers, LLC", "citation": null, "cited_authorities": [ "LLC v. Seredin", "Russell v. Mells, 426 So" ], "court": "District Court of Appeal of Florida, Fourth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "fladistctapp4-2026-innocent-v-meraki-installers", "disposition": "The court affirmed and referred counsel to the Florida Bar over trial-transcript quotations not found in the record.", "docket_number": "4D2025-1151", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an initial brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and multiple nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2210/Innocent_v._Meraki_Installers_LLC.pdf", "state": "FL", "summary": "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.", "text_sha256": "3baeb345213257c862b168d83a85ca924a8205652e5a0f1345a83cb62550ecc1", "topics": [ "fabricated-citations" ], "tracker_slug": "innocent-v-meraki-installers-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-innocent-v-meraki-installers", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-innocent-v-meraki-installers" }, { "ai_passage": "We denied the “emergency” motion for stay,1 and issued an order requiring counsel to show cause why sanctions should not be imposed because the petition appears AI-generated and raises frivolous arguments, misstates the law, and cites non-existent caselaw. Fla. R. App. P. 9.410(a). As an example, we quoted page 5 of the petition, which argues: Florida appellate courts have recognized that certiorari relief is appropriate where an order lacks sufficient findings to permit meaningful review. See Citigroup Global Mkts., Inc. v. Masek, 982 So. 2d 1231 (Fla. 4th DCA 2008). No such case exists in Florida. The citation links to Liberty Transportation, LLC v. Banyan Air Services, Inc., 982 So. 2d 1231 (Fla. 4th DCA 2008), which does not support this argument and is irrelevant to this proceeding. Additionally, we noted that the petition cites generally to several other cases for legal propositions that the cited cases do not actually represent.2 The petition also cites inapplicable second-tier certiorari cases. 1 The allegation of an “emergency” was frivolous. ... Counsel has responded to our order to show cause and argues that he was not trying to intentionally mislead this Court and that his citation was referring to an Ohio appellate court decision. He does not acknowledge using AI and alleges that he relied on a paralegal for legal research. The false citation was allegedly a “transcription error” and “clerical mistake.” The response states: During multi-jurisdictional research (to find exact match not found in Florida), the Ohio decision was inadvertently assigned the Florida Fourth District Court of Appeal – thereby making the citation a clear transcription error during final compilation. The response argues that “the citation error ...", "ai_tool_named": null, "archive_url": null, "case_name": "Eclectic Synergy, LLC v. Seredin", "citation": null, "cited_authorities": [ "Inc. v. Masek, 982 So", "LLC v. Banyan Air Services" ], "court": "District Court of Appeal of Florida, Fourth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "fladistctapp4-2026-eclectic-synergy-v-seredin", "disposition": "The court ordered counsel to show cause why sanctions should not issue for an apparently AI-generated emergency stay motion.", "docket_number": "4D2026-0781", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a response using several nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2211/Eclectic_Synergy_LLC_v._Seredin.pdf", "state": "FL", "summary": "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.", "text_sha256": "1e83ea60430f8b1b2e22f0fe82efa76b9b9354d34d5b066e76de68afd59dba57", "topics": [ "fabricated-citations" ], "tracker_slug": "eclectic-synergy-llc-v-seredin", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-eclectic-synergy-v-seredin", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-eclectic-synergy-v-seredin" }, { "ai_passage": "Motion,hemoved“tosealorredactimproperanddefamatory material” within the Third-Party Complaint, under Superior Court Civil Rules 5(g), 12(f), “and the Court's inherent equitable authority to seal or redact specific portions....”6 WithintheattachedMemorandumofLawinSupport,Movant asserted four defenses.7 However, he did not object to the Court'sexerciseofjurisdictionoverhisperson.Instead,while seeking dismissal or alternative relief on other grounds, he challenged the merits,8 even noting he “stands prepared to introduce [preserved evidence] at deposition or trial if necessary.”9 *2 At this point, an issue arose regarding Movant's citation to nonexistent legal authorities to this Court. The Court convened an in-person hearing on October 15, 2026. The Court could not verify or locate quoted language from seven casescitedbyMovantintheFirstMotion.Thehearing'sfocus was to clarify that despite Movant's pro se status, the Court will not tolerate citation to nonexistent authorities. Therefore, the First Motion to Dismiss was denied, without prejudice.10 Recognizing Movant's pro se status, the Court provided leave to refile by November 14.11 But Movant took other routes first. Within days of his in- person appearance at the hearing, Movant filed a Letter asserting his intention to seek sanctions.12 Movant argued the Third-Party Complaint was filed while the corporate charter was “forfeited.”13 Movant sought discovery concerning the Third-Party Complaint's filing and Defendant's corporate status.14 On the same day, Movant filed what he deemed a “Supplemental Motion” (hereinafter the “Second Motion”) challenging this litigation on several fronts.15 This new filing raised entirely distinct arguments for dismissal, centering on SWSZ HOLDING INC., Plaintiff, Counterclaim Defendant, v.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "SWSZ Holding v. SZ Global", "citation": "2026 WL 1482293", "cited_authorities": [], "court": "Supreme Court of Delaware", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "delsupct-2026-swsz-holding-v-sz-global", "disposition": "The court denied the sealing motion without prejudice and directed the movant to refile using only existing, accurately quoted authorities.", "docket_number": "N25C-05-105 SSA", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a motion using several nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2239/SWSZ_Holding_Inc._v._SZ_Global_Inc._v._Wich_et_al._USA_27_May_2026.pdf", "state": "DE", "summary": "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.", "text_sha256": "8692443f0ec7e2294058eecb8ebed77ccf23ec4a7fe2df157a43825ac53bf51c", "topics": [ "fabricated-citations" ], "tracker_slug": "swsz-holding-v-sz-global", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/delsupct-2026-swsz-holding-v-sz-global", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/delsupct-2026-swsz-holding-v-sz-global" }, { "ai_passage": "CONCLUSION10 10 In reviewing Plaintiffs briefing, the Court identified at least one existence where Plaintiffhad cited to a non-existent authority and brought this issue to Plaintiffs attention. After investigating, Plaintiffconceded that this fictitious citation was most likely the result of artificial intelligence (“Al”). The Court has not considered any ofPlaintiffs contentions, to the extent that they rely on fabricated authority, and will consider whether any other action is necessary. For the foregoing reasons, Defendants’ Motion (D.I. 26) is granted. Count I is dismissed with prejudice and Counts II-IV are dismissed without prejudice. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DEAN WILLIAMSON, derivatively on behalf of EQUINIX, INC., Plaintiff, Civil Action No. 25-989-GBW V. CHARLES J. MEYERS, ADA1RE FOX­ MARTIN, NANCI CALDWELL, GARY HROMADKO, THOMAS OLINGER, CHRISTOPHER PAISLEY, SANDRA RIVERA, FIDELMA RUSSO, PETER VAN CAMP, JEETU PATEL, THOMAS A. BARTLETT, KEITH D. TAYLOR, SCOTT G. KRIENS, WILLIAM K. LUBY, and IRVING LYONS, III, Defendants, -and- EQUINIX, INC., Nominal Defendant. ORDER At Wilmington this 27th day of May 2026, IT IS HEREBY ORDERED that: 1.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Williamson v. Meyers (derivatively on behalf of Equinix, Inc.)", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Delaware", "court_code": "ded", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-27", "decision_id": "ded-2026-williamson-v-meyers-derivatively-on-behalf-of", "disposition": "The court warned counsel after plaintiff conceded a fictitious citation and withdrew it from the briefing.", "docket_number": "Civil Action No. 25-989-GBW", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a motion using at least one nonexistent or hallucinated authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2215/Williamson_v._Meyers__Equinix_USA_27_May_2026.pdf", "state": "DE", "summary": "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.", "text_sha256": "4656bb58c9eff34ae888428e5ab585667128ed41b8117aca286e99ef28086693", "topics": [ "fabricated-citations" ], "tracker_slug": "williamson-v-meyers-derivatively-on-behalf-of-equinix-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ded-2026-williamson-v-meyers-derivatively-on-behalf-of", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ded-2026-williamson-v-meyers-derivatively-on-behalf-of" }, { "ai_passage": "Meade postulated that the cases were “wholly fictitious.” {¶ 16} On July 10, 2025, Guo opposed Meade’s request for sanctions. He stated in his motion that Davis v. Davis—as well as the three other cases referred to by Meade—was available at the provided citation and was “readily accessible to any attorney who exercises due diligence. It is evident that Defendant’s counsel did not make a genuine effort to research these authorities and instead chose to file a frivolous Request for Sanctions without proper investigation.” {¶ 17} Guo further filed his own motion for sanctions against Meade’s counsel for “engaging in conduct designed to mislead this Court and to improperly delay enforcement of a valid foreign judgment.” {¶ 18} On July 15, 2025, the trial court entered its judgment granting Meade’s motion to vacate the foreign judgment.", "ai_tool_named": "Deepseek", "archive_url": null, "case_name": "Guo v. Meade Motorcars, L.L.C.", "citation": "2026-Ohio-1930", "cited_authorities": [ "He stated in his motion that Davis v. Davis" ], "court": "Court of Appeals of Ohio, Sixth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-26", "decision_id": "ohioctapp6-2026-guo-v-meade-motorcars-l-l-c", "disposition": "The court imposed a $100 monetary sanction for the defective legal authorities.", "docket_number": null, "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "Deepseek", "conduct": "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.", "currency": "USD", "monetary_penalty": 100, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2237/Guo_v._Meade_Motorcars_USA_26_May_2026.pdf", "state": "OH", "summary": "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.", "text_sha256": "b34cdea93cdc5312497599798acd42d390b04aceb773ea71cd970c44c7e86da5", "topics": [ "fabricated-citations" ], "tracker_slug": "guo-v-meade-motorcars-l-l-c", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohioctapp6-2026-guo-v-meade-motorcars-l-l-c", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohioctapp6-2026-guo-v-meade-motorcars-l-l-c" }, { "ai_passage": "This raises concern that these cases may be the result of generative artificial intelligence hallucinations.7 See Smith v. Smith, 5:25-CV-1077 (MAD/DJS), 2025 WL 3706691, at *2-3 (N.D.N.Y. Dec. 22, 2025).8 “Although in some circumstances courts will make ‘some allowances for a pro se Plaintiff's failure to cite to proper legal authority,’ it is ‘no more acceptable for a pro se litigant to submit briefs with fake case citations than it is for a lawyer to do so.’” Fecteau v. Safety Nat’l Cas. Corp., No. 25-CV-3821 (KMK), 2026 WL 821567, at *24 (S.D.N.Y. Mar. 25, 2026) (quoting Dukuray v. Experian Info. Sols., 23 Civ. 9043 (AT)(GS), 2024 WL 3812259, at *11-12 (S.D.N.Y. July 26, 2024)). All page number citations herein refer to the page number assigned upon electronic filing unless otherwise noted. “Generative artificial intelligence tools can fabricate or ‘hallucinate’ legal precedent.” Romero v. Goldman Sachs Bank USA, 1:25-cv-2857-GHW, 2025 WL 1916119, at *1 (S.D.N.Y. ... Further, Plaintiff is advised that “filings with citations to nonexistent cases may result in sanctions, such as [his] submissions being stricken, filing restrictions or monetary penalties being imposed, or the case being dismissed.” Dukuray, 2024 WL 3812259, at *12. B. Motion for a Protective Order Plaintiff moves for a protective order under Federal Rule of Civil Procedure 26(c)(1). (Docket No. 125). Rule 26 governs “[t]he scope of discovery in a federal civil action,” Nat'l Rifle Ass’n of Am. v. Cuomo, 332 F.R.D. 420, 428 (N.D.N.Y. 2019), and sets forth: A party or any person from whom discovery is sought may move for a protective order . . . .", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Hodges v. McGough Enterprises LLC", "citation": null, "cited_authorities": [ "See Smith v. Smith, 5:25-CV-1077 (MAD/DJS)", "Fecteau v. Safety Nat’l Cas. Corp., No. 25-CV-3821 (KMK)", "Dukuray v. Experian Info. Sols., 23 Civ", "Romero v. Goldman Sachs Bank USA, 1:25-cv-2857-GHW, 2025 WL 1916119, at *1 (S.D.N.Y. ... Further, Plaintiff is advised that “filings with citations to nonexistent cases may result in sanctions, such as [his] submissions being stricken, filing restrictions or monetary penalties being imposed, or the case being dismissed.” Dukuray, 2024 WL 3812259, at *12. B. Motion for a Protective Order Plaintiff moves for a protective order under Federal Rule of Civil Procedure 26(c)", "Nat'l Rifle Ass’n of Am. v. Cuomo, 332 F", "Federal Rule of Civil Procedure 26(c)(1)", "Rule 26" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-26", "decision_id": "nysd-2026-hodges-v-mcgough-enterprises", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "23 Civ. 5016 (NSR)(JCM)", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a motion using nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2232/Hodges_v._McGough_USA_26_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "ec92ecf64c5aea3426794730335eced7f5506dd45a97ef0b54d3cb05cf16bb97", "topics": [ "fabricated-citations" ], "tracker_slug": "hodges-v-mcgough-enterprises-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-hodges-v-mcgough-enterprises", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-hodges-v-mcgough-enterprises" }, { "ai_passage": "None of these grounds identifies a part of Although courts make some allowances for a pro se plaintiff's failure to cite to proper legal authority, courts do not excuse the use of fabricated or misleading authorities. Morgan v. Cmty. Against Violence, No. 23-cv-353-WPJ/JMR, 2023 WL 6976510, *7 (D.N.M. Oct. 23, 2023). Plaintiffs are cautioned that they must comply with this Court’s Local Rules, the Court’s Guidefor Pro Se Litigants, andthe Federal Rules of Civil Procedure. Any futurefilings thatcontain citations to nonexistent cases may result in sanctions, including the filing being stricken, filing restrictions being imposed, or dismissal of the case. See id at *8 (collecting cases where sanctions were deemed appropriate). Judge Sweazea’s November 19, 2025 Order that Plaintiffs seek to set aside, much less anything “clearly erroneous or contrary to law.” For at least the following reasons, Plaintiffs’ objection is denied. First, Judge Sweazea has not yet ruled on Plaintiffs’ requested accommodations. Judge Sweazea’s November 19, 2025 Order struck the Motion for Reasonable ADA Accommodation, but as the parties appear to agree, the relief requested in the Motion for Reasonable ADA Accommodation is not new. See Doc.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Sample et al v. Hilton Worldwide Holdings, Inc", "citation": null, "cited_authorities": [ "Morgan v. Cmty. Against Violence, No. 23-cv-353-WPJ/JMR, 2023 WL 6976510, *7 (D.N.M. Oct. 23, 2023)" ], "court": "United States District Court for the District of New Mexico", "court_code": "nmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-26", "decision_id": "nmd-2026-sample-v-hilton-worldwide-holdings", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "1:23-cv-00865-SMD-KRS", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a response using quotations that did not appear in the cited source.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2235/Sample_USA_26_May_2026.pdf", "state": "NM", "summary": "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.", "text_sha256": "005dc8e39ed7ceef745c7ea46b9846a159b77e53a06f032d6fc575683d8f1028", "topics": [ "fabricated-citations" ], "tracker_slug": "sample-et-al-v-hilton-worldwide-holdings-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nmd-2026-sample-v-hilton-worldwide-holdings", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nmd-2026-sample-v-hilton-worldwide-holdings" }, { "ai_passage": "163.] The Court further directed Plaintiff to file a statement showing why he should not be subject to Federal Rule of Civil Procedure 11(c) sanctions for citing and quoting non-existent cases. Plaintiff responded to the Court's order onApril 9, 2026. [Filing No. 165.] Plaintiff does not dispute that certain citations were incorrect, but claims his errors were not intentionally fabricated or designed to mislead the Court. Plaintiff argues his errors fell into two categories: (1) citations he could not locate and failed to correct, and (2) quotations that paraphrased, rather than cited, authority. [Filing No. 165, at ECF p. 2.] He argues that no additional sanctions are Plaintiff filed two motions for reconsideration of the Court's order adopting the report and recommendation. Those motions remain pending with the district judge. [Filing Nos. 173; 176.] warranted, or alternatively, that any sanction imposed be proportionate to the conduct and limited to a formal verified citation requirement going forward. In contrast, Defendants argue significant sanctions are warranted because Plaintiff acted in either bad faith or in reckless reliance on artificial intelligence by citing fake cases or quotations on at least 37 instances throughout this litigation. [Filing No.", "ai_tool_named": "artificial intelligence", "archive_url": null, "case_name": "William C. Maxwell v. Dakota Michael & Chelsey Smith", "citation": null, "cited_authorities": [ "Federal Rule of Civil Procedure 11(c)" ], "court": "United States District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-26", "decision_id": "insd-2026-william-c-maxwell-v-dakota-michael-chelsey-smi", "disposition": "The court imposed a $1,000 Rule 11 sanction for non-existent citations and denied the motion for preliminary injunction.", "docket_number": "1:24-cv-01365-JRS-TAB", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "artificial intelligence", "conduct": "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.", "currency": "USD", "monetary_penalty": 1000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2229/Maxwell_v._Michael_USA_26_May_2026.pdf", "state": "IN", "summary": "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.", "text_sha256": "2aae52bd673573691b5b09a46ce5223283a1b8b1c5d36e11fbb45f0368d4c4a9", "topics": [ "fabricated-citations" ], "tracker_slug": "william-c-maxwell-v-dakota-michael-chelsey-smith", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/insd-2026-william-c-maxwell-v-dakota-michael-chelsey-smi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-william-c-maxwell-v-dakota-michael-chelsey-smi" }, { "ai_passage": "Then we address Kalonji’s citation to nonexistent legal authority and mischaracterization of caselaw. In addition to asking this Court to take judicial notice of the APRA Responses, Kalonji’s Motion for Judicial Notice of Legislative Facts and Alternative Relief also requested that this Court remand this case for a “limited evidentiary hearing,” reverse the trial court’s judgment based on violations of due process, and certify his constitutional questions for review by our Supreme Court. Kalonji v. State, Cause No. ... Section 2—Kalonji, a Pro Se Litigant, Is Held to the Same Legal Standards as Licensed Attorneys, and We Admonish Kalonji for Citing to Nonexistent Legal Authority and Mischaracterizing Caselaw. [25] “It is well settled that pro se litigants are held to the same legal standards as licensed attorneys. This means that pro se litigants are bound to follow the established rules of procedure and must be prepared to accept the consequences of their failure to do so.” Basic v. Amouri, 58 N.E.3d 980, 983-84 (Ind. Ct. App. 2016) (internal citation omitted). “These consequences include waiver for failure to present cogent arguments on appeal.” Dridi v.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Jean-Paul B. Kalonji v. State of Indiana", "citation": null, "cited_authorities": [ "Supreme Court. Kalonji v. State", "Basic v. Amouri, 58 N" ], "court": "Indiana Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-26", "decision_id": "indctapp-2026-jean-paul-b-kalonji-v-state-of-indiana", "disposition": "The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.", "docket_number": "25A-XP-2508", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2234/Kalonji_v._Indiana_USA_26_May_2026.pdf", "state": "IN", "summary": "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.", "text_sha256": "3b0e44fe7519c8897f96ef29f2caca64aa67f8d16dc69501ffe3fb7680643012", "topics": [ "fabricated-citations" ], "tracker_slug": "jean-paul-b-kalonji-v-state-of-indiana", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/indctapp-2026-jean-paul-b-kalonji-v-state-of-indiana", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/indctapp-2026-jean-paul-b-kalonji-v-state-of-indiana" }, { "ai_passage": "2024) (per curiam) (observing that the “attempt to persuade a court or oppose an adversary” by relying on “non-existent precedent” is an “abuse of the adversary system”). (ECF 43). Plaintiff’s response to Defendant’s request for a stay of discovery includes citation to a case, Rate Technology Inc. v. Speakeasy Inc., that does not match the citation provided; the case has an entirely different citation, and the case involves whether a settlement agreement barring a patent licensee from later challenging a patent’s validity was void for public policy reasons. See Rates Tech. Inc. v. Speakeasy, Inc., 685 F.3d 163, 167 (2d Cir. 2012). Plaintiff has denied using AI. Whatever the cause of Plaintiff’s false citations, she is again admonished that presentation of false citations, quotations, or holdings in the future may lead me to impose sanctions. See, e.g., Advani v. App. Term, 2nd Jud. Dep’t, No. 25- CV-1627 (JMF), 2025 WL 2201065, at *3 (S.D.N.Y. Aug. 1, 2025); Reilly v. Conn. Interlocal Risk Mgmt. Agency, No. 25-CV-640 (VDO), 2025 WL 1726366, at *3 (D. Conn.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Sana Hazina Butler v. Fidelity Management & Research Company LLC", "citation": null, "cited_authorities": [ "Rate Technology Inc. v. Speakeasy Inc", "See Rates Tech. Inc. v. Speakeasy", "Advani v. App. Term, 2nd Jud", "Reilly v. Conn. Interlocal Risk Mgmt. Agency, No. 25-CV-640 (VDO)" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-22", "decision_id": "nysd-2026-sana-hazina-butler-v-fidelity-management-resea", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "1:25-cv-09337-RA-RFT", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant cited Rate Technology Inc. v. Speakeasy Inc even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2199/Butler_v._Fidelity_USA_22_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "a312ca4439e61707593a59015f066947766480c2edc546a79995f433ce5ff490", "topics": [ "fabricated-citations" ], "tracker_slug": "sana-hazina-butler-v-fidelity-management-research-company-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-sana-hazina-butler-v-fidelity-management-resea", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-sana-hazina-butler-v-fidelity-management-resea" }, { "ai_passage": "It should further be noted that in her motion [Mother] cites to non-existent case law .... Again, this causes the Court concerns regarding [Mother's] candor with the Court, and she has been advised as such. The circuit court also rejected Mother's argument that relief was warranted under 60.02(f) for extraordinary cause. Significantly, the court determined that Mother had not filed her motion within a reasonable time: [Mother] has known about and had access to these medical records she now relies on since 2016; almost 10 years ago. Thesemedicalrecordsandherallegedinconsistencieshave also been referenced in the civil cases between [Mother] and the custodians of the children beginning in 2021.... These children were infants when [Mother] first had access to those records. They are now nine and ten years old. The Court cannot find under those facts and circumstances that this motion was filed within a reasonable time. Mother appealed. ... According to the allegations of the petition, the Cabinet had received a referral after the child (then four months of age) was seen at the University of Kentucky Emergency Room due to concerns of non-accidental trauma. At that time, the child had redness on the bottom of her feet, a blister covering the majority of her right foot, a scratch on her right eyelid, and a bruise above her left eye and on the right abdomen. The child was admitted. A skeletal survey revealed healing posterolateral 5th rib fracture, three acute rib fractures, and a distal left tibial metaphyseal corner fracture.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "A.T.W. v. Commonwealth of Kentucky", "citation": "2026 WL 1443318", "cited_authorities": [], "court": "Kentucky Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-22", "decision_id": "kyctapp-2026-a-t-w-v-commonwealth-of-kentucky", "disposition": "The court affirmed and noted that the circuit court had already warned mother about non-existent case law.", "docket_number": "2025-CA-1508-ME", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2195/ATW_v._Kentucky_USA_22_May_2026.pdf", "state": "KY", "summary": "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.", "text_sha256": "4fb528e4fe48773c64ffe46608b2108c5194c8385222aa8550c6705b7ed1cec6", "topics": [ "fabricated-citations" ], "tracker_slug": "a-t-w-v-commonwealth-of-kentucky", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/kyctapp-2026-a-t-w-v-commonwealth-of-kentucky", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/kyctapp-2026-a-t-w-v-commonwealth-of-kentucky" }, { "ai_passage": "52, SAC ¶¶ 1, 5, 9-24, 26-28.) Defendant now moves to dismiss the SAC on jurisdictional and other grounds,(seegenerallyR.54,Def.’sMot.toDismiss),andfor sanctions based on Kafeel's reliance on AI-hallucinated case citations and quotations in court filings, (R. 59, Def.’s Mot. for Sanctions). Analysis A. Motion to Dismiss *2 Defendant moves to dismiss the SAC under: (1) Rule 12(b)(1) for lack of subject matter jurisdiction; (2) Rule 12(b) (2)forfailuretoestablishpersonaljurisdiction;(3)Rule12(b) (6) for failure to state a claim; and (4) the doctrine of forum non conveniens pursuant to a forum selection clause included in the parties’ user agreement. (See generally R. 54, Def.’s Mot. to Dismiss.) 1. Rule 12(b)(6) The court turns first to Defendant's principal argument—that Kafeel has not sufficiently stated a Lanham Act claim. (R. SAQIB KAFEEL, Plaintiff, v. CJDROPSHIPPING, Defendant., Slip Copy (2026) 54, Def.’s Mot. to Dismiss at 1-5.) To survive a Rule 12(b)(6) motion, the complaint must assert a facially plausible claim andprovidefairnoticeofitsbasis.BellAtl.Corp.v.Twombly, 550 U.S. 544, 555 (2007). A claim is facially plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Saqib Kafeel v. CJDropshipping", "citation": "2026 WL 1453740", "cited_authorities": [ "Rule 12(b)(1)", "Rule 12(b)", "Rule12(b)", "Rule 12(b)(6)" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-22", "decision_id": "ilnd-2026-saqib-kafeel-v-cjdropshipping", "disposition": "The court dismissed the second amended complaint and declined to award fees for AI-hallucinated citations.", "docket_number": "No. 24 CV 11929", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a motion using record or transcript quotations not found in the record, quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2194/Kafeel_v._CJDropshipping_USA_22_May_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "04f1b958a660d87fae2607534c3866fc4c58b2392fcc0ff5137f7473adc26bda", "topics": [ "fabricated-citations" ], "tracker_slug": "saqib-kafeel-v-cjdropshipping", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-saqib-kafeel-v-cjdropshipping", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-saqib-kafeel-v-cjdropshipping" }, { "ai_passage": "McCommon, Esquire, who, in his Initial Brief, has provided this Court with citations to several cases, some of which appear to be fabricated. The Initial Brief looks as if it was drafted with the assistance of generative artificial intelligence without Mr. McCommon having put sufficient safeguards in place to ensure the existence or accuracy of the cases cited therein. This is unfortunately not the first time our Court has encountered a filing with citations to cases that do not exist or to cases that are cited for inaccurate legal propositions. See, e.g., Rodriguez v. Rodriguez, No. 6D2025-3086, 2026 WL 969721 (Fla. 6th DCA Apr. 10, 2026). As we did in Rodriguez, we hereby direct Mr. McCommon to provide copies of each and every case cited in the Initial Brief that actually exists, with highlighted quotations or language that support the assertions made in the Initial Brief. These cases shall be filed with this Court within ten days of the issuance of this Order. Additionally, Mr.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Kings Roofing v. Fusion Works", "citation": "2026 WL 969721", "cited_authorities": [ "Rodriguez v. Rodriguez, No. 6D2025-3086, 2026 WL 969721 (Fla. 6th DCA Apr. 10, 2026)" ], "court": "District Court of Appeal of Florida, Sixth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-22", "decision_id": "fladistctapp6-2026-kings-roofing-v-fusion-works", "disposition": "The court ordered the filer to show cause why sanctions should not issue for the defective authorities.", "docket_number": "6D2025-1251", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2166/Kings_Roofing_v._Fusion_Works_USA_22_May_2026.pdf", "state": "FL", "summary": "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.", "text_sha256": "16f11d8459e3156c23138ba529cb893a0867a30fc99a7d9e05f33a217607c390", "topics": [ "fabricated-citations" ], "tracker_slug": "kings-roofing-v-fusion-works", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp6-2026-kings-roofing-v-fusion-works", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp6-2026-kings-roofing-v-fusion-works" }, { "ai_passage": "“Although courts make some allowances for the pro se Plaintiff's failure to cite to proper legal authority, courts may not condone actions by a party who cites to false, nonexistent, or misleading authorities.” Meriland Keith Dillard v. CBS Studios, Inc., 2026 WL 790882, at * 11 (C.D. Cal. Mar. 16, 2026) (internal quotation marks omitted). Plaintiff is reminded that all litigants, including those proceeding pro se, are expected to ensure the validity of all sources cited in their filings. See Fed. R. Civ. P. 11(b); Munoz v. United States, 28 F.4th 973, 978 (9th Cir. 2022) (“[I]t is axiomatic that pro se litigants, whatever their ability level, are subject to the same procedural requirements as other litigants.”). Government Works.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Lagac v. Capital One, N.A.", "citation": "2026 WL 1454205", "cited_authorities": [ "Meriland Keith Dillard v. CBS Studios", "Munoz v. United States, 28 F", "Fed. R. Civ. P. 11(b)" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-22", "decision_id": "cacd-2026-lagac-v-capital-one-n-a", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "2:26-cv-02964-RGK-MAA", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed opposition papers using quotations that did not appear in the cited source.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2248/Lagac_v_Capital_One_NA_USA_22_May_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "ed4c530f30c056b5bca6d0fc7edba5b3a3be8758b8a1e14f14e10f398c83566d", "topics": [ "fabricated-citations" ], "tracker_slug": "lagac-v-capital-one-n-a", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-lagac-v-capital-one-n-a", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-lagac-v-capital-one-n-a" }, { "ai_passage": "One, his case citations appear to be from an artificial intelligence hallucination.3 The cases cited in the brief, insofar as they exist, do not stand for the stated propositions for which Mr. Simmons offers them.4 Two, Rule 19 itself and prior caselaw support the opposite conclusion. The Rule itself states that, when a party dies while the appeal is pending, “the appellate court may order substitution of the proper parties” and that the motion “may be made by any party or by the successor or representative of the deceased party.” Tenn. R. App. P. 19(a) (emphasis added). When interpreting statutes, “[t]he traditional, commonly repeated rule is that shall is mandatory and may is permissive.” Antonin Scalia and Bryan A. Garner, Reading Law: The Interpretation of Legal Texts 112 (2012).5 “Tennessee courts have embraced this traditional rule.” Armitage v. Hale, No. E2024-01905-COA-R3-CV, 2025 WL 3765874, at *7 (Tenn. Ct. App. Dec. ... in one important regard:here,Defendantnevermovedthetrialcourttodismiss Plaintiff's action for failure to comply with Rule 25.01’s 90- daydeadline.”).Accordingly,afailureofsubstitutiondoesnot automatically defeat this court's jurisdiction. *8 Thejurisdictionofthiscourtcontinuesbecause“[a]ctions do not abate by the death or other disability of either party, or by the transfer of any interest in the action, if the cause of action survives or continues.”6 Tenn. Code Ann. § 20-5-101; see Tenn. Code Ann.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Simmons v. Shahidul Islam", "citation": "2026 WL 1431143", "cited_authorities": [ "Armitage v. Hale, No. E2024-01905-COA-R3-CV, 2025 WL 3765874, at *7 (Tenn. Ct. App. Dec. ... in one important regard:here,Defendantnevermovedthetrialcourttodismiss Plaintiff's action for failure to comply with Rule 25.01’s 90- daydeadline.”)", "Rule 19", "Rule 25.01" ], "court": "Court of Appeals of Tennessee", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "tennctapp-2026-simmons-v-shahidul-islam", "disposition": "The court affirmed dismissal and rejected briefing that used apparent AI-hallucinated cases and an inaccurate Rule 19 argument.", "docket_number": "01261-COA-R3-CV", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a motion using authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2177/TRAY_SIMMONS_v_DR_SHAHIDUL_ISLAM_ET_AL_USA_21_May_2026.pdf", "state": "TN", "summary": "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.", "text_sha256": "2e53ac1c465e07bef631e97e769a00567e5c62160e65a5f41781803ee19aa7a9", "topics": [ "fabricated-citations" ], "tracker_slug": "simmons-v-shahidul-islam", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/tennctapp-2026-simmons-v-shahidul-islam", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tennctapp-2026-simmons-v-shahidul-islam" }, { "ai_passage": "there can be no clear legal error for the failure of either the Court or the jury to apply a stipulation that does not exist. It is apparent to the Court that the text of the damages stipulation may not comport with the intentions of the Plaintiffs. They have made clear in their briefing on the present motion that they believe this stipulation established a fact saying essentially, if Defendant’s were found liable, the totals listed in the stipulation would be awarded by the jury.84 That is textually not what the stipulation states. “A consensual stipulation of the parties is to be interpreted according to the general principles of contract construction.”85 Here, there is no ambiguity as to what the contract means, and it is not ambiguous. After all, any mention of causation or relation to this incident in the stipulation makes clear that the stipulation does not take that issue off the table for the upcoming trial. Further, “[a] contract is not ambiguous merely because the parties disagree about its proper interpretation.”86 That appears to be what happened in this case. ... Bill of Costs All three parties have filed bills of cost in this case.107 Local Court Rule 54.3 sets out a specific procedure for how these bills are taxed.108 While this process does not require judicial approval before these costs can be taxed, I will provide a brief comment on how I believe these filings will generally progress, without attending to the details of the actual figures.109 On February 13, 2026, the Defendants in this case made a $950,000 offer of judgment to Plaintiffs pursuant to Federal Rule of Civil Procedure 68.110 This offer was not accepted by Plaintiffs, and I have ...", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Twigg v. BSN Sports, Inc., et al.", "citation": null, "cited_authorities": [ "Rule 54.3", "Federal Rule of Civil Procedure 68.110" ], "court": "United States District Court for the Middle District of Pennsylvania", "court_code": "pamd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "pamd-2026-twigg-v-bsn-sports", "disposition": "The court ordered the filer to show cause why sanctions should not issue for the defective authorities.", "docket_number": "4:23-CV-00067", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2179/Twigg_et_al_v_Varsity_Brands_Holding_Co__USA_21_May_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "49e9be59649ac5e1429f886713cba7c7d7f3ffee98aafa60168a96193c7f9aa0", "topics": [ "fabricated-citations" ], "tracker_slug": "twigg-v-bsn-sports-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pamd-2026-twigg-v-bsn-sports", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pamd-2026-twigg-v-bsn-sports" }, { "ai_passage": "McBride to appear before the Court to show cause as to why sanctions should not be imposed under Rule 11 and the Court's inherent authority for citing fictitious cases in his response to Defendant Logan's motion to dismiss. See Doc. 126. 2. On September 5, 2025, the undersigned recommended Mr. McBride pay Defendants' reasonable attorneys' fees and costs incurred for attending the Court's show cause hearing. Doc. 134.3 3. On December 4, 2025, Judge DeGiusti adopted the Report andRecommendation.Doc.143.JudgeDeGiustialsoordered Mr. McBride to “disclose in all future pleadings whether generativeAIwasused,thespecificAItoolthatwasused,and [to] certify in the document that he ... checked the accuracy of any portion of the document drafted by generative AI, including all citations and legal authority.” Id. at 3. 4.OnMarch3,2026,theCourtorderedthepartiestomeetand confer and reach an agreement on the amount of attorney fees owed, given an ongoing dispute between counsel McBride and Defendants. See Doc. 156; Doc. 158, at 3. The Court advised Defendants that they must file an appropriate motion no later than March 17, 2026, if an agreement was not reached. Doc. 156. 5. On March 17, 2026, Defendants filed the present contempt motion. Doc. 158. 3. Violations of the Court's Order.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Dalton Gage Hill v. Oklahoma County Criminal Justice Authority", "citation": "2026 WL 1429765", "cited_authorities": [ "Rule 11" ], "court": "United States District Court for the Western District of Oklahoma", "court_code": "okwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "okwd-2026-dalton-gage-hill-v-oklahoma-county-criminal-ju", "disposition": "The magistrate judge recommended denying the motion to vacate and described earlier Rule 11 sanctions proceedings against counsel.", "docket_number": "CIV-24-1298-D", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2175/Dalton_Gage_Hill_v._Oklahoma_County_Criminal_Justice_Authority_et_al._USA_21_May_2025.pdf", "state": "OK", "summary": "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.", "text_sha256": "b0b0c434b9a114b512110f2c89337d137f9bcbd2a722e2264e74bff04206eef4", "topics": [ "fabricated-citations" ], "tracker_slug": "dalton-gage-hill-v-oklahoma-county-criminal-justice-authority", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/okwd-2026-dalton-gage-hill-v-oklahoma-county-criminal-ju", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/okwd-2026-dalton-gage-hill-v-oklahoma-county-criminal-ju" }, { "ai_passage": "Husband's Motion containedthree citations to nonexistent lawand three citations to cases with inaccurate descriptions ofthe propositions oflawfor which they stood. The errant citations were pointed out to Mr. Johnson on August 25, 2025, at which point the parties agreed to pass that day's setting. This Court was not the assigned Judge at that time and has no direct knowledge of anything other than what is reflected in the minutes. Mr. Johnson sought leave to file acorrectedpleading andthenfiled acorrectedMotion toDismiss. The Court never had a chance to grant leave to file, but it was filed anyway. The Court finds that the mere filing of the corrected Motion does not moot the issue from the Court's perspective. b. The Court does not render a finding that, based upon the affidavit filedby Mr. Johnson and executed byhis paralegal, that there have been similar cases filed.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "In re the Marriage of Amy Haddock and Justin Blu Haddock", "citation": null, "cited_authorities": [], "court": "District Court of Tulsa County, Oklahoma", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "okdistct-2026-in-re-marriage-of-amy-haddock-and-justin-blu-h", "disposition": "The court sanctioned counsel $2,000, ordered attorney-fee proceedings, required a knowledge-base audit, and directed bar referral.", "docket_number": "FD-2021-987", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a motion using authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 2000, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2226/26.05.21._Haddock._Order.pdf", "state": "OK", "summary": "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.", "text_sha256": "e7a203671cbcec502ffa299dc661bd8ca33f89f7bc54bcdcad4ed92e4c3943ac", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-the-marriage-of-amy-haddock-and-justin-blu-haddock", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/okdistct-2026-in-re-marriage-of-amy-haddock-and-justin-blu-h", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/okdistct-2026-in-re-marriage-of-amy-haddock-and-justin-blu-h" }, { "ai_passage": "Likewise, the Complaint does not appear to be attacking a state-court judgment so as to implicate the Rooker-Feldman doctrine. Beyond a vague reference to “court proceedings” (Compl, ECF No. 1-1, PAGEID # 3), Ms. Arron has not alleged the existence of any specific state judicial decision that she wants the Court to overturn.2 See, e.g., HPIL Holding, Inc. v. Zhang, 168 F.4th 944, 951 (6th Cir. 2026) (“Rooker and Feldman apply only to attempts to directly reverse a state court’s judgment.”) (emphasis added); cf. Exxon Mobil Corp., 544 U.S. at 284 (referencing “the narrow ground occupied by Rooker-Feldman”). 2 If it is found that such a state-court case does exist, however, reconsideration of subject-matter jurisdiction under the Rooker-Feldman doctrine may become appropriate. Even assuming that there was some qualifying state-court custody determination, the source of Ms. Arron’s injury is not that determination but rather Defendants’ allegedly improper conduct of detaining her, seizing her children without a warrant, and preventing her from being heard. (See Compl., ECF No. ... Arron’s application to proceed in forma pauperis and recommends dismissal for lack of subject-matter jurisdiction of Ms. Arron’s requested relief in the form of the “immediate reunification with [her] children” (Compl., ECF No. 1-1, PAGEID # 4). The Court further DENIES Ms. Aaron’s motion for a TRO (ECF No. 1-2). The Court otherwise REJECTS the OR&R and accordingly RECOMMITS the remainder of Ms. Arron’s Complaint to the Magistrate Judge for a further screening determination under 28 U.S.C. § 1915(e)(2). IT IS SO ORDERED. /s/ Sarah D. Morrison SARAH D.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Arron v. Custer, et al.", "citation": null, "cited_authorities": [ "Inc. v. Zhang, 168 F" ], "court": "United States District Court for the Southern District of Ohio", "court_code": "ohsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "ohsd-2026-arron-v-custer", "disposition": "The magistrate judge treated the cited Ohio Supreme Court decision as unverified and recommended remand.", "docket_number": "2:26-cv-390", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a motion using unsupported or inaccurate legal authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2198/Shelby_v._Custer_USA_21_May_2026.pdf", "state": "OH", "summary": "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.", "text_sha256": "e840031d12b8eb5672fa892b47a904b683075f4ab073f933c2fb7077e1b2e858", "topics": [ "fabricated-citations" ], "tracker_slug": "arron-v-custer-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohsd-2026-arron-v-custer", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohsd-2026-arron-v-custer" }, { "ai_passage": "Specifically, his brief exhibits all the hallmarks of being generated by artificial intelligence (“AI”) including nonexistent cases, miscited cases, and cases that exist but standfordifferentlegalpropositionsthanwhatisrepresented. See Smith v. Gamble, 2025-Ohio-2381, ¶ 26 (12th Dist.); Gonzalez v. Tex. Taxpayers & Research Assoc., 2025 U.S. Dist. LEXIS 16801 (W.D. Tex. Jan. 29, 2025). App.R. 16(7) requires that an appellant set forth “[a]n argument containing the contentions of the appellant with respect to each assignment of error presented for review and the reasons in support of the contentions, with citations to the authorities, statutes,andpartsoftherecordonwhichtheappellantrelies.” Hunter-Bey's status as a pro se litigant does not relieve him of his obligations to comply with the appellate rules because it is well established that “ ‘pro se litigants are held to the same standard as all other litigants [and] they must accept the consequencesoftheirownmistakes.’”Manningv.Cuyahoga Metro.Hous.Auth.,2025-Ohio-4751,¶17(8thDist.),quoting Bikkaniv.Lee,2008-Ohio-3130,¶29(8thDist.),citingKilroy v. B.H. Lakeshore Co., 111 Ohio App.3d 357, 363 (8th Dist. 1996). Furthermore, App.R. ... Britt, 67 Ohio St.2d 71 (1981), in support of his argument that the trial court must rule on all his pending motions prior to deciding the City's motion to dismiss. His reliance on this case, however, is misguided. Although the case exists, it does not stand for the stated proposition. Similarly, Hunter-Bey cites to “McQueen” without a cite or explanation as to how “McQueen” might apply, and we are unable to decipher which case he is relying upon. *3 {¶ 10} Nevertheless, Hunter-Bay's assertions are mistaken, because “there is no rule of law requiring that a trial court expressly rule on every pretrial motion before it.” N. Star Med. Research, L.L.C. v. Kozlovich, 2025-Ohio-5410, ¶ 26 (8th Dist.).", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Isaiah Hunter-Bey v. City of Cleveland Law Department", "citation": "2026 WL 1434161; 2026-Ohio-1869", "cited_authorities": [ "See Smith v. Gamble, 2025-Ohio-2381, ¶ 26 (12th Dist.)", "Gonzalez v. Tex. Taxpayers & Research Assoc., 2025 U", "L.L.C. v. Kozlovich, 2025-Ohio-5410, ¶ 26 (8th Dist.)" ], "court": "Court of Appeals of Ohio, Eighth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "ohioctapp8-2026-isaiah-hunter-bey-v-city-of-cleveland-law-depa", "disposition": "The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.", "docket_number": "No. 115696", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2176/ISAIAH_HUNTER-BEY_v_CITY_OF_CLEVELAND_LAW_DEPARTMENT_USA_21_May_2026.pdf", "state": "OH", "summary": "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.", "text_sha256": "c26f77b03b1f35688289950cff74db1377e060ebcfd83eea159a4f32df37aea3", "topics": [ "fabricated-citations" ], "tracker_slug": "isaiah-hunter-bey-v-city-of-cleveland-law-department", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohioctapp8-2026-isaiah-hunter-bey-v-city-of-cleveland-law-depa", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohioctapp8-2026-isaiah-hunter-bey-v-city-of-cleveland-law-depa" }, { "ai_passage": "The Hunt Court stated: Hunt's claims that his plea was not knowingly, voluntarily, or intelligently entered or that the trial court failed to comply with the dictates of Green, all of which are dependent on the nonexistent transcript, are without merit. We must presume regularity in the proceedings and that thethree-judgepanelcompliedwithGreenandCrim.R.11. Further, the final entry of conviction indicates that Hunt was notified of his constitutional rights during the plea process and Hunt has not demonstrated any other legal error from the available record of the proceedings. (Emphasis added.) Hunt at ¶ 10-11. {¶ 32} Here, appellant waited nearly two decades to file his first two motions to vacate his conviction and more than two decades to file the motion to withdraw his plea. By that time, any audio recording or transcript of the plea proceedings had long since been lawfully destroyed pursuant to Sup.R. 26.05(C). Appellant, therefore, is at fault with respect to nonproduction of a transcript or recording of the plea proceedings. Hunt and other cases require that we presume regularity, i.e., compliance with Crim.R. ... 2943.031(A) warning, and that failure to do so should not be subject to the manifest-injustice standard even if sentencing has already occurred. Id. at ¶ 26. In other words, the General Assembly “created a substantive statutory right for certain criminal defendants and ... this right therefore prevails over the general procedural provisions of Crim.R. 32.1.” Id. at ¶ 27. Francis, by its terms, was limited to this substantive statutory right. Appellant has notarguedthatanyitemsonhislistofcollateralconsequences fit within any such exceptions. {¶ 43} In State v.", "ai_tool_named": null, "archive_url": null, "case_name": "City of Shaker Heights v. Andre D. Thompson", "citation": "2026 WL 1434248; 2026-Ohio-1871", "cited_authorities": [], "court": "Court of Appeals of Ohio, Eighth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "ohioctapp8-2026-city-of-shaker-heights-v-andre-d-thompson", "disposition": "The court overruled the assignment of error after finding the cited plea-record authority nonexistent or unrelated.", "docket_number": "No. 115785", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "A self-represented appellant cited State v. Banks even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2174/CITY_OF_SHAKER_HEIGHTS_v_ANDRE_D_THOMPSON_USA_21_May_2025.pdf", "state": "OH", "summary": "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.", "text_sha256": "829b443c8852590f9d7c358fe97ffef19ae49b6b4b22715a7e48fc052b2b0427", "topics": [ "fabricated-citations" ], "tracker_slug": "city-of-shaker-heights-v-andre-d-thompson", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohioctapp8-2026-city-of-shaker-heights-v-andre-d-thompson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohioctapp8-2026-city-of-shaker-heights-v-andre-d-thompson" }, { "ai_passage": "The School Defendants cite to the Court’s November 5, 2025, Order in which it issued a warning to Plaintiff regarding his citations to nonexistent cases and/or to case law that misleads and falsely represents legal support for arguments presented. Id. The School Defendants assert that each time Plaintiff files a motion, his duty to present nonfrivolous arguments and legal contentions supported by existing law is triggered. Id. The School Defendants assert that despite the Court’s warning and Plaintiff’s duty, Plaintiff refuses to accept the Court’s rulings, has asserted unsupported legal arguments, and continues to cite case law which is misleading and falsely represents to the Court legal support for his arguments. Id. C. City Defendants’Response The City Defendants contend that Plaintiff’s Motion for a hearing is an effort to gain reconsideration of the Court’s November 5, 2025, and November 13, 2025, Orders. Doc. 53 at 2. The City Defendants contend that here the Court has not misapprehended the facts, the parties’ positions, or the controlling law, and Plaintiff’s Motion seeks to revisit arguments on issues that the Court has already decided. Id.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Lowrey v. City of Rio Rancho et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of New Mexico", "court_code": "nmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "nmd-2026-lowrey-v-city-of-rio-rancho", "disposition": "The court ruled on the merits and separately addressed defective legal authorities in the filing.", "docket_number": "vs. Civ. No. 25-849 JFR/LF", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a response using authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2188/Lowrey_v._City_of_Rio_Rancho_USA_21_May_2026.pdf", "state": "NM", "summary": "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.", "text_sha256": "c312f0aab1412d019ffe8b0b9929eba482758b135aec726c7ea3c1791a496405", "topics": [ "fabricated-citations" ], "tracker_slug": "lowrey-v-city-of-rio-rancho-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nmd-2026-lowrey-v-city-of-rio-rancho", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nmd-2026-lowrey-v-city-of-rio-rancho" }, { "ai_passage": "Petitioner was ordered to provide in his OSC response signed declarations from Petitioner’s counsel, law student Gina Herrera, and any and all other staff who assisted Petitioner’s counsel regarding compliance with the Court’s January 13, 2026 Order; a detailed description of how the hallucinated citations were included in Petitioner’s reply brief at ECF No. 12; a detailed description of what steps were taken to confirm whether counsel’s filings in other immigration habeas cases filed in the Eastern District of California also contained hallucinated citations and what steps were taken to bring those issues to the district court’s attention; a table of authorities of all cases Petitioner has cited in all of Petitioner’s filings in this action, Case No. 1:25-cv-2004-CSK, organized by filing, including (1) the verbatim citation in Petitioner’s filing, the ECF number of the filing, and the page number of the filing on which the authority is cited; (2) identification of whether each citation is an accurate citation or whether it is a hallucinated or fictitious citation; and (3) for each citation, if the citation is an accurate citation for an actual case, a complete copy of the actual case/decision cited attached to the table of authorities. ... 49) and declines to impose sanctions on Petitioner’s counsel Cummings or law student Herrera for counsel’s failure to fully comply with the Court’s January 13, 2026 order. The Court repeats its admonishment that while AI and generative AI tools can assist counsel and parties, these tools must be used responsibly.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "That Xiong v. Minga Wofford", "citation": null, "cited_authorities": [], "court": "United States District Court for the Eastern District of California", "court_code": "caed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "caed-2026-that-xiong-v-minga-wofford", "disposition": "The court declined sanctions in light of remedial steps but required counsel to verify all future case and record citations.", "docket_number": "1:25-cv-2004", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2187/Xiong_v._Wofford_USA_21_May_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "4ab2d24354b57a3382cf809880ab44d353fb98aa2b832babd89bf42b76553bdb", "topics": [ "fabricated-citations" ], "tracker_slug": "that-xiong-v-minga-wofford", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/caed-2026-that-xiong-v-minga-wofford", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/caed-2026-that-xiong-v-minga-wofford" }, { "ai_passage": "Harp includes four false quotations. (See Doc. 23 at 22, 24, 25, 32). These quotations—along with the cases to which they are attributed and any language necessary for context—are as follows: SeeHolly v. Clairson Indus., L.L.C., 492 F.3d 1247, 1256–57 (11th Cir. 2007) (questions regarding the extent of limitations and need for accommodation are “classic jury issues”). Id. at 22; See EEOC v. St. Joseph’s Hosp., Inc., 842 F.3d 1333, 1345 (11th Cir. 2016) (“The ADA does not mandate a particular interactive process, but it does require the employer to provide a reasonable accommodation when one is needed.”). Id. at 24; See, e.g., Breen v. Dep’t of Transp., 282 F.3d 839, 842 (D.C. Cir. 2002) (“The interactive process does not end with generic, non-responsive offers untethered to the employee’s disability-related limitations.”). Id. at 25; The Eleventh Circuit broadly interprets adverse action in the FMLA retaliation context to include “any action that might dissuade a reasonable worker from exercising FMLA rights.” Batson v.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Jackie L. Miller v. Regions Bank", "citation": null, "cited_authorities": [ "SeeHolly v. Clairson Indus", "See EEOC v. St. Joseph’s Hosp", "Breen v. Dep’t of Transp., 282 F" ], "court": "United States District Court for the Northern District of Alabama", "court_code": "alnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "alnd-2026-jackie-l-miller-v-regions-bank", "disposition": "The court disqualified counsel from the case and from appearing before the judge for six months and referred the order to bar authorities.", "docket_number": "2:24-cv-1324-HDM", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Counsel submitted a filing using quotations that did not appear in the cited source.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2169/Miller_v._Regions_Bank_USA_21_May_2026.pdf", "state": "AL", "summary": "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.", "text_sha256": "407f501026e4171e5944ba48d51c871aee26f6a61a8bcedb8a3aea315e6f49fc", "topics": [ "fabricated-citations" ], "tracker_slug": "jackie-l-miller-v-regions-bank", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/alnd-2026-jackie-l-miller-v-regions-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alnd-2026-jackie-l-miller-v-regions-bank" }, { "ai_passage": "5), but these quotations do not appear anywhere in these cases or in any other case the Court can find. Generative artificial intelligence likely produced these unreliable quotations. The Court does not prohibit the use of AI, but to comply with Rule 11 of the Federal Rules of Civil Procedure and other applicable legal and ethical standards, attorneys and pro se litigants must review and verify computer-generated content to ensure that the content is entirely accurate and complies with all governing standards. TERM Docs. 18 and 19 and mail a copy of this order to Mr.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Chapel v. Americredit Financial Services & Experian", "citation": null, "cited_authorities": [ "Rule 11" ], "court": "United States District Court for the Northern District of Alabama", "court_code": "alnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-21", "decision_id": "alnd-2026-chapel-v-americredit-financial-services-experi", "disposition": "The court admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations.", "docket_number": "2:25-cv-01341-MHH", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant submitted a filing using quotations that did not appear in the cited source.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2178/Chapel_v._Americredit_USA_21_May_2026.pdf", "state": "AL", "summary": "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.", "text_sha256": "c4bbdfb67034af3a7f6931649d5a1400bbab07933128a5fc6d985f99685df268", "topics": [ "fabricated-citations" ], "tracker_slug": "chapel-v-americredit-financial-services-experian", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/alnd-2026-chapel-v-americredit-financial-services-experi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alnd-2026-chapel-v-americredit-financial-services-experi" }, { "ai_passage": "The Sherwoods’ sweeping claims appear to stem from incorrect interpretations of law and include citations to hallucinated law ostensibly obtained from generative AI tools. A fundamental misunderstanding about (1) the requirements for a misdemeanor warrant under Virginia Code § 19.2-72;and (2) the effect of a nolo contendere plea in Virginia court underlies all twenty counts. CLERKS OFFICE US DISTRICT COURT AT ROANOKE, VA FILED LAURA A. AUSTIN, CLERK BY: /s/ E. Jones DEPUTY CLERK May 21, 2026 Ten motions are pending before the court, including: defendants’ motions to quash service of the original complaint, ECF Nos. 34, 36, 38, 41, 44; defendants’ motions to dismiss for failure to state a claim, ECF Nos. 71, 76, 79, 82, 84; and plaintiffs’ motion to amend their amended complaint, ECF No. 93. The court has carefully considered the various motions of the parties, the parties’ briefing on those motions, and the parties’ oral arguments presented at the February 2, 2026, hearing on the pending motions.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Sherwood v. County of Botetourt, Virginia, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Western District of Virginia", "court_code": "vawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-20", "decision_id": "vawd-2026-sherwood-v-county-of-botetourt-virginia", "disposition": "The court granted dismissal of most claims and warned that any future filing must be supported by real law.", "docket_number": "7:25-cv-821", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel cited Peal v. Commonwealth even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2161/Sherwood_v_Botetourt.pdf", "state": "VA", "summary": "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.", "text_sha256": "41ac8ba8ef813ee97c069248ca5261f493016362e6e087c8a45f5b03ec0eda15", "topics": [ "fabricated-citations" ], "tracker_slug": "sherwood-v-county-of-botetourt-virginia-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/vawd-2026-sherwood-v-county-of-botetourt-virginia", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/vawd-2026-sherwood-v-county-of-botetourt-virginia" }, { "ai_passage": "Lamonsoff, PLLC, and Michael Sanders, Esq., pursuant to 22 NYCRR 130-1.1, for filing briefs containing fabricated and/or erroneous legal authority and/or citations, by serving and filing an affirmation or affidavit on that issue, via NYSCEF, on or before June 3, 2026; and it is further, ORDERED that the Clerk of this Court, or his designee, shall serve a copy of this ordertoshowcauseuponthepartiesbyuploadingacopyofthisordertoshowcausetotheNYSCEF system. LASALLE, P.J., BRATHWAITE NELSON, WARHIT and GOLDBERG VELAZQUEZ, JJ., concur. ENTER: Darrell M.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Landberg v City of New York", "citation": null, "cited_authorities": [ "22 NYCRR 130-1.1" ], "court": "Supreme Court of New York, Appellate Division, Second Department", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-20", "decision_id": "nyappdiv2-2026-landberg-v-city-of-new-york", "disposition": "The court ordered the filer to show cause why sanctions should not issue for the defective authorities.", "docket_number": "2025-02380", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a brief using unsupported or inaccurate legal authorities.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2167/Landberg_v._City_of_New_York_USA_20_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "83ed040dce936564f08f81e30cb9dfc4c61c3983d42615212301f493fc980d5c", "topics": [ "fabricated-citations" ], "tracker_slug": "landberg-v-city-of-new-york-2026", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nyappdiv2-2026-landberg-v-city-of-new-york", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyappdiv2-2026-landberg-v-city-of-new-york" }, { "ai_passage": "The Inapplicable or Non-Existent Cases Cited by Debtor In her supplemental submission, the Debtor cites three cases in support of her position that there is a willful stay violation. None of those cases involved a legally required notification such as what is at issue here, nor did any of those cases analyze the sufficiency of a disclaimer in the particular circumstances of the case. # Td. #1 In re Kirby, 599 B.R. 427, 44445 (B.A.P. 1st Cir. 2019) (noting that the inclusion ofa bankruptcy disclaimer does not insulate a creditor from liability for a stay violation but finding on those facts that there was no violation of the discharge injunction) 42 See, e.g., Sears Roebuck & Co. v. Epperson (In re Epperson), 189 B.R. 195, 198-99 (E.D. Mo. 1995); In re Youngkin, 2014 Bankr. LEXIS 765, at *16 (Bankr. E.D.N.C. ... For the reasons stated, the Sanctions Motion is DIENIED. The Court will enter an Order in accordance with this Opinion. May 20, 2026 - A Hon. Vincent F.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "In re Nicholia Cherry-Crockette", "citation": null, "cited_authorities": [ "Sears Roebuck & Co. v. Epperson" ], "court": "United States Bankruptcy Court for the District of New Jersey", "court_code": "njb", "court_level": "federal-bankruptcy", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-20", "decision_id": "njb-2026-in-re-nicholia-cherry-crockette", "disposition": "The bankruptcy court denied the sanctions motion and rejected authorities that were nonexistent or did not support the debtor's position.", "docket_number": "25-21600", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a motion using nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2192/In_re_Crockette_USA_20_May_2026.pdf", "state": "NJ", "summary": "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.", "text_sha256": "7b5440e92353cba052915f7a79a6c0ac1a54092395a291f0549bcf49547a094e", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-nicholia-cherry-crockette", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/njb-2026-in-re-nicholia-cherry-crockette", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/njb-2026-in-re-nicholia-cherry-crockette" }, { "ai_passage": "Rule 11(b) and Fabrication of Legal Authority Finally, Curtin points to reprimands issued against Cyberlux in other litigation, specifically an order to pay attorneys’ fees and a show-cause order for fabricating or misrepresenting legal authorities. (Doc. 48 at 9.) He contends that Cyberlux has engaged in a “persistent pattern of deception and obstruction” that undermines Cyberlux's argument that the complaint’s “well- documented facts” are implausible. (Id.) There is a certain irony in all of this. Curtin’s brief contains fabricated quotations that directly contradict the actual holdings of the cited cases – the same misconduct he invokes to discredit Cyberlux. Cyberlux’s conduct has already been addressed by those courts.6 Meanwhile, this court must address Curtin’s conduct in the present case. Curtin represents that in Sinochem International Co. Ltd. v. Malaysia International Shipping Corp., 549 U.S. 422, 430 (2007), the United States Supreme Court held that “[a] court lacking jurisdiction . . . must dismiss, it cannot transfer.” (See Doc. 29 at 7.) This quotation is a fabrication.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Curtin v. Watts, et al.", "citation": null, "cited_authorities": [ "Sinochem International Co. Ltd. v. Malaysia International Shipping Corp., 549 U", "Rule 11(b)" ], "court": "United States District Court for the Middle District of North Carolina", "court_code": "ncmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-20", "decision_id": "ncmd-2026-curtin-v-watts", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "1:25-cv-00782-TDS-JGM", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2183/Curtin_v._Watts_USA_19_May_2026.pdf", "state": "NC", "summary": "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.", "text_sha256": "bec0505b999fc4d987fe2bc2ce2c9ef52c22f75f4615d9046429e719deef78e8", "topics": [ "fabricated-citations" ], "tracker_slug": "curtin-v-watts-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ncmd-2026-curtin-v-watts", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ncmd-2026-curtin-v-watts" }, { "ai_passage": "Submission of nonexistent or inaccurate legal authority is improper and wastes judicial resources. Mother's brief contains numerous citations to cases and other legal authorities. We suspect that Mother may have used generative artificial intelligence (“AI”) to assist in drafting her brief, as several cited authorities are fictitious, and others do not support the stated proposition.5 We identify these problematic citations in footnotes as relevant. In Mezu v. Mezu, 267 Md. App. 354 (2025), we highlighted the potential dangers of using AI to conduct legal research or generatefilings,includingtheriskof“hallucinated”citations. Id. at 367–68. Moreover, “[t]he citation of fake cases in a brief or other pleading filed with a court implicates multiple Maryland Rules.” Id. at 368. Attorneys who submit filings containing fake citations may be referred to the Attorney Grievance Commission depending on the nature and severity of the misconduct. See id. at 374. Although there is no parallel disciplinary action for pro se litigants, Maryland Rule 1-311(c) authorizes us to strike the offending filing.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Brandy Dorsey v. Walter Livramento, III", "citation": "2026 WL 1413152", "cited_authorities": [ "In Mezu v. Mezu, 267 Md", "Rule 1-311(c)" ], "court": "Appellate Court of Maryland", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-20", "decision_id": "mdctapp-2026-brandy-dorsey-v-walter-livramento-iii", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "2237 September Term, 2025", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a brief using numerous nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2173/Dorsey_v._Livramento_USA_20_May_2026.pdf", "state": "MD", "summary": "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.", "text_sha256": "ff015eeb3617fd0d781d2d0aa196974642c80fe97a824c2d786161ce6a193845", "topics": [ "fabricated-citations" ], "tracker_slug": "brandy-dorsey-v-walter-livramento-iii", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdctapp-2026-brandy-dorsey-v-walter-livramento-iii", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdctapp-2026-brandy-dorsey-v-walter-livramento-iii" }, { "ai_passage": "Plaintiff requested,13 and the Court granted,14 leave to file a Second Amended Complaint, which was then filed into the record.15 Experian then answered the Second Amended Complaint,16 and Trans Union filed a Motion to Dismiss the same.17 On September 26, 2025, Plaintiff requested leave to file a Third Amended Complaint.18 Trans Union opposed the request,19 and Plaintiff filed a reply.20 Trans Union thenfiledaMotionforLeavetoFileaSur-reply, representing that “[a] closer examination of Plaintiff’s Motion reveals Plaintiff’s reliance on fabricated and/or non-existent legal authorities,” and requested leave “to briefly address the misrepresentations in Plaintiff’s 9 R. Doc. 1 at ¶¶ 108-121. 10 R. Doc. 39. 11 R. Doc. 105. 12 Id. at pp. 4-5. 13 R. Doc. 145. 14 R. Doc. 151. 15 R. Doc. 152. 16 R. Doc. 154. 17 R. Doc. 163. 18 R. Doc. 169. 19 R. Doc. 179. 20 R. Doc.", "ai_tool_named": "Gemini", "archive_url": null, "case_name": "Taiujuan Burches v. Equifax Information Services, LLC, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Eastern District of Louisiana", "court_code": "laed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-20", "decision_id": "laed-2026-taiujuan-burches-v-equifax-information-service", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "VERSUS NO. 25-804", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "Gemini", "conduct": "A self-represented litigant filed a motion using nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2190/Burches_v._Equifax_USA_20_May_2026.pdf", "state": "LA", "summary": "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.", "text_sha256": "68e351c92daa57a865b923b665960f2238a9fed5d7c82f7c221192a21e0cc72d", "topics": [ "fabricated-citations" ], "tracker_slug": "taiujuan-burches-v-equifax-information-services-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/laed-2026-taiujuan-burches-v-equifax-information-service", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/laed-2026-taiujuan-burches-v-equifax-information-service" }, { "ai_passage": "The Magistrate Judge has recommended that the Undersigned personally sanction Plaintiff’s counsel, Tae Sture, for including two non-existent legal citations in a brief responding to a motion to compel. The legal citations were hallucinations generated by an artificial intelligence (“AI”) research tool. The Magistrate Judge found Mr. Sture’s conduct violated the Indiana Rules of Professional Conduct as well as Federal Rule of Civil Procedure 11(b). For the Rule 11 violation, the Magistrate Judge recommends that Mr. Sture be personally sanctioned in the amount of $7,500.00. Mr. Sture has objected to DAVIS v. MARION COUNTY SUPERIOR COURT JUVENILE DETENTION CENTER et al Doc. 127 Dockets.Justia.com the R&R’s findings regarding violation of the Indiana rules as well as the amount of the recommended monetary sanction. See Fed. R. Civ. P. 72(b). As further explained below, the Court respectfully REJECTS the Magistrate Judge’s R&R insofar as it concludes Mr. Sture violated the Indiana Rules of Professional Conduct. Those issues have been referred to the Indiana Disciplinary Commission by the Chief Judge.", "ai_tool_named": "Fastcase", "archive_url": null, "case_name": "Davis v. Marion County Juvenile Detention Center", "citation": null, "cited_authorities": [ "Mr. Sture has objected to DAVIS v. MARION COUNTY SUPERIOR COURT JUVENILE DETENTION CENTER et al Doc", "Federal Rule of Civil Procedure 11(b)", "Rule 11", "Fed. R. Civ. P. 72(b)" ], "court": "United States District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-20", "decision_id": "insd-2026-davis-v-marion-county-juvenile-detention-cente", "disposition": "The magistrate judge recommended a $2,000 sanction against counsel for two AI-generated non-existent citations.", "docket_number": "1:24-cv-01918-JRO-MJD", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "Fastcase", "conduct": "Counsel filed a motion using multiple nonexistent or hallucinated authorities and authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 2000, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2191/Davis_v._Marion_Country_Juvenile_DC_USA_20_May_2026.pdf", "state": "IN", "summary": "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.", "text_sha256": "695fe630b4e273cb9e35919bf7aed4d7825c777bc808ee8d3582b822c1634fd3", "topics": [ "fabricated-citations" ], "tracker_slug": "davis-v-marion-county-juvenile-detention-center", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/insd-2026-davis-v-marion-county-juvenile-detention-cente", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-davis-v-marion-county-juvenile-detention-cente" }, { "ai_passage": "First, Downing’s argument is supported almost exclusively by fabricated legal authorities. Throughout her appellate brief, USCA11 Case: 25-14133 Document: 14-1 Date Filed: 05/20/2026 Page: 4 of 8 25-14133 Opinion of the Court 5 Downing relies on precedents that do not exist. For example, she quotes UnitedStatesv. Jones, 29 F.4th 1290, 1294 (11th Cir. 2022), as providingthat“[C]ourtsmustconfinethemselvestotherecordde- veloped in the proceeding before them.” Neither that precedent nor the quoted text exists in any of this Court’s precedents in any form. She also provides seemingly fake quotations from real prec- edents. For example, she says our real decision in In re Worldwide Web Sys., Inc., 328 F.3d 1291, 1299 (11th Cir. 2003), includes the holdingthat“Dueprocessrequiresthatapartybegivennoticeand an opportunity to respond before a court takes adverse action based on disputed factual matters.” But that precedent addresses service of process and does not include anything like the alleged quotation. Although we give liberal construction to the filings of pro se litigants, “we nevertheless have required them to conform to procedural rules.” Loren v. ... And to conclude that Downing was not the administrator of her father’s estate, the district court referred to the Fulton County Probate Court’s order appointing Luanne Bonnie to that role. These records had already been filed as exhibits in another case pending before the same district judge. USCA11 Case: 25-14133 Document: 14-1 Date Filed: 05/20/2026 Page: 6 of 8 25-14133 Opinion of the Court 7 See United States v. Glover, 179 F.3d 1300, 1302 n.5 (11th Cir. 1999) (“a court may take judicial notice of its own records . . . .”). Finally,werejectDowning’scontentionthatshewasdenied an adequate opportunity to be heard.", "ai_tool_named": null, "archive_url": null, "case_name": "Downing v. Dwayne Brown, et al.", "citation": null, "cited_authorities": [ "Opinion of the Court 7 See United States v. Glover, 179 F" ], "court": "United States Court of Appeals for the Eleventh Circuit", "court_code": "ca11", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-20", "decision_id": "ca11-2026-downing-v-dwayne-brown", "disposition": "The court struck fabricated-authority portions of the brief and affirmed dismissal.", "docket_number": "25-14133", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2185/Downing_v._Brown_USA_20_May_2026.pdf", "state": null, "summary": "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.", "text_sha256": "38efb4426fae2895eedc0f6a6e66436209cbc2c2a2a00069d08f156c6dcf240b", "topics": [ "fabricated-citations" ], "tracker_slug": "downing-v-dwayne-brown-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca11-2026-downing-v-dwayne-brown", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca11-2026-downing-v-dwayne-brown" }, { "ai_passage": "§ 1421(c) (“Aperson whose application for naturalization under this subchapter is denied, after a hearing before an immigration officer under section 1447(a) of this title, may seek review of such denial before the United States district court for the district in USCIS’s counsel submitted two court filings that contained hallucinated case citations. (See Defs.’Suggested Findings Fact Conclusions Law, ECF No. 34 and Resp’t’s Resp. Pl.’s Objs., ECF No. 36.) The Court allowed USCIS to file amended versions of those documents. (See Defs.’Am. Suggested Findings Fact Conclusions Law, ECF No. 40 and Resp’t’sAm. Resp. Pl.’s Objs., ECF No. 41.) PAGE 10 – FINDINGS OF FACTAND CONCLUSIONS OF LAW which such person resides in accordance with chapter 7 of title 5.”); see also 28 U.S.C. § 1331 (federal question jurisdiction). Venue is proper in the District of Oregon because resides in Oregon. See 8 U.S.C. § 1421(c). 4. The Court’s review of USCIS’s denial of naturalization application is de novo. See 8 U.S.C. § 1421(c) (“Such review shall be de novo, and the court shall make its own findings of fact and conclusions of law and shall, at the request of the petitioner, conduct a hearing de novo on the application.”); see also 8 C.F.R. ... Jurisdiction over an award of attorney’s fees and costs under the EqualAccess to JusticeAct, 5 U.S.C. § 504 and 28 U.S.C. § 2412, is proper in this action. may apply for attorney’s fees and costs following entry of final judgment. CONCLUSION For the reasons stated, the Court GRANTS application for naturalization and ORDERS USCIS to naturalize as a citizen of the United States ofAmerica, make arrangements for him to take the oath of allegiance, and issue a certificate of naturalization upon administration of the oath; and RESERVES jurisdiction to determine if is entitled to an award of reasonable attorney’s fees and costs under the EqualAccess to ...", "ai_tool_named": "GAI", "archive_url": null, "case_name": "REDACTED v. United States Citizenship and Immigration Services", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Oregon", "court_code": "ord", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-19", "decision_id": "ord-2026-redacted-v-united-states-citizenship-and-immig", "disposition": "The court allowed counsel to correct suggested findings after fabricated citations were identified.", "docket_number": "3:24-cv-02135-SB", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a response using nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2390/X_v._US_Immigration_USA_9_June_2026.pdf", "state": "OR", "summary": "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.", "text_sha256": "1e002d28609e87f59a1a7d834f7b5c19f654783ba727e5e3e937b1f32b115f00", "topics": [ "fabricated-citations" ], "tracker_slug": "redacted-v-united-states-citizenship-and-immigration-services", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ord-2026-redacted-v-united-states-citizenship-and-immig", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ord-2026-redacted-v-united-states-citizenship-and-immig" }, { "ai_passage": "Specifically, on July 15, 2025, Plaintiffs brought to the attention of the Court that Defendants had fabricated legal authority in at least two submissions to the Court. (See Dkt. #101 (alerting the Court to Defendants’ improper citations)). The most egregious examples appeared in Defendants’ July 8, 2025 letter regarding their interference with the class notice process. There, Defendants cited Federal Rule of Civil Procedure 23 and OConner v. Agilant Solutions, Inc., 444 F. Supp. 3d 593 (S.D.N.Y. 2020), for the proposition that text messages from K. Tun could not establish misconduct by Defendants because they were inadmissible hearsay. (Dkt. #94). But Rule 23 concerns class actions, and OConner’s relevance is therefore limited because it discusses when a court may enjoin an employer-defendant from contacting putative class members through a protective order. See 444 F. Supp. 3d at 606-07. In that same letter, Defendants again cited OConner, as well as Haider v. Lyft, Inc., No. 20 Civ. 2997 (AJN), 2021 WL 3475621 (S.D.N.Y. Aug. ... Defendants did not seek to replace their submissions until January 21, 2026, over six months after Defendants’ original filings, and only after Plaintiffs raised these same concerns in the instant sanctions motion. (See Dkt. #133 (Defendants’ request to replace the submissions); Dkt. #125 (“Pl. Br.”) at 19 (Plaintiffs’ brief noting that Defendants “have done nothing” to “remedy the false submissions”)). C. The Instant Motion Taking all of the above into account, the Court set a briefing schedule at the September 16, 2025 hearing for Plaintiffs to file a motion for sanctions. (See September 16, 2025 Minute Entry). On November 13, 2025, Plaintiffs filed their motion for sanctions and supporting papers. (Dkt. #124-126). Defendants filed their opposition and supporting papers on January 13, 2026. (Dkt. #131-132).", "ai_tool_named": "LexisNexis AI", "archive_url": null, "case_name": "Chakma v. Sushi Katsuei, Inc.", "citation": null, "cited_authorities": [ "Federal Rule of Civil Procedure 23 and OConner v. Agilant Solutions", "Haider v. Lyft", "Federal Rule of Civil Procedure 23", "Rule 23" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-19", "decision_id": "nysd-2026-chakma-v-sushi-katsuei", "disposition": "The court imposed a $2,712 monetary sanction for the defective legal authorities.", "docket_number": "1:23-cv-07804-KPF", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "LexisNexis AI", "conduct": "Counsel filed opposition papers using authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 2712, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2160/Chakma_et_al_v_Sushi_Katsuei_Inc_et_al_USA_19_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "da38baf109fd931b3ed554b3564b59643064dbca38664384bb2517d4d7d340af", "topics": [ "fabricated-citations" ], "tracker_slug": "chakma-v-sushi-katsuei-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-chakma-v-sushi-katsuei", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-chakma-v-sushi-katsuei" }, { "ai_passage": "Plaintiff alleges in the Amended Complaint that various Defendants revealed her private information and defamed her by calling her a “fake attorney,” among other things. The facts relayed by the Court about Plaintiff’s disciplinary history—all matters of public record and permissible to consider on a motion to dismiss, Stahl, 327 F.3d at 700—are relevant to the viability of Plaintiff’s claims in that they show that certain information was not private, see, e.g., Doc. [318] at 29, and they undermine the plausibility of Plaintiff’s allegations of ‘actual malice,’ see id. at 36-37. The Court thus declines to strike the references to Plaintiff’s disciplinary history, as they are relevant to the disposition of her claims. For related reasons, Plaintiff also seeks to disqualify and recuse the undersigned pursuant to 28 U.S.C. § 455. Doc. [323] at 7. “By independently introducing derogatory information unrelated to the pleadings,” Plaintiff argues, “the Court has [d]eparted from its neutral adjudicative role; [c]reated the appearance of partiality; [and] [u]ndermined public confidence in the fairness of the proceedings.” Id.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Syreeta LaShawn McNeal v. Vera L. Calvin, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Eastern District of Missouri", "court_code": "moed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-19", "decision_id": "moed-2026-syreeta-lashawn-mcneal-v-vera-l-calvin", "disposition": "The court required the litigant to certify citation verification with every future filing.", "docket_number": "4:23-cv-01732-SEP", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant cited Weniger v. Dynamic Recovery Solutions, LLC even though the court found the authority did not exist.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2189/McNeal_v._Calvin_USA_19_May_2026.pdf", "state": "MO", "summary": "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.", "text_sha256": "4e4773fba93a5614350d919915fbf208f629f145cef80d943e7c27a8ea4d6421", "topics": [ "fabricated-citations" ], "tracker_slug": "syreeta-lashawn-mcneal-v-vera-l-calvin-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/moed-2026-syreeta-lashawn-mcneal-v-vera-l-calvin", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/moed-2026-syreeta-lashawn-mcneal-v-vera-l-calvin" }, { "ai_passage": "that “Avidity’s agents acted on behalf of both Avidity and St. Peter Investors, establishing joint and vicarious liability.” ECF No. 1 at 4 (emphasis added). As a result, the Court believes that the “better approach to remedy this problem” is “to defer judgment against the defaulting party until the merits have been resolved.” Rankin v. Direct Recovery Servs., LLC, No. 21-cv-1560 (MJD/LIB), 2023 WL 3597724, at *2 (D. Minn. May 23, 2023) (citation omitted). II. Hallucinated Citations As a final matter, the Court notes that Harris repeatedly misquotes caselaw cited in his motion and provides completely hallucinated citations. For instance, he provides purported quotations from Pfannenstiel Architects, Inc. v. Chouteau Petroleum Co., 978 F.2d 430, 433 (8th Cir. 1992); Johnson v. Dayton Elec. Mfg. Co., 140 F.3d 781 (8th Cir. 1998); and Stephenson v. El-Batrawi, 524 F.3d 907 (8th Cir. 2008). See ECF No. 55 at 1– 2. Each case is real and concerns the subject matter contained within the purported quotation. But the specific quotations Harris provides are not found in any of those cases. Worse, Harris provides at least two citations—Taylor v. City of Minneapolis, 202 F. Supp. 3d 933, 941–42 (D. Minn. 2016) and Berg v. Copeland, 2019WL1493461, at *5 (D. Minn. Apr. 4, 2019)—which do not appear to exist at all. ... Rule 11 also authorizes the Court to impose an appropriate sanction “to deter repetition of the conduct or comparable conduct by others similarly situated.” Fed. R. Civ. P. 11(c)(4); see also Vallejo v. Amgen, Inc., 903 F.3d 733, 747 (8th Cir. 2018) (citation omitted) (recognizing that district courts have “broad discretion in the choice of sanctions”). That includes the authority to strike pleadings entirely. Sanders v. United States, 176 Fed. Cl.", "ai_tool_named": "GenAI", "archive_url": null, "case_name": "Harris v. St. Peter Investors, LLC et al.", "citation": null, "cited_authorities": [ "Rankin v. Direct Recovery Servs", "Inc. v. Chouteau Petroleum Co., 978 F", "Johnson v. Dayton Elec. Mfg. Co., 140 F", "Stephenson v. El-Batrawi, 524 F", "Taylor v. City of Minneapolis, 202 F", "Berg v. Copeland, 2019WL1493461, at *5 (D. Minn. Apr. 4, 2019)", "Vallejo v. Amgen", "Sanders v. United States, 176 Fed", "Rule 11", "Fed. R. Civ. P. 11(c)(4)" ], "court": "United States District Court for the District of Minnesota", "court_code": "mnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-18", "decision_id": "mnd-2026-harris-v-st-peter-investors", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "Case No. 25-cv-2237 (LMP/DLM)", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GenAI", "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2180/Harris_v._St_Peter_Investors_USA_18_May_2026.pdf", "state": "MN", "summary": "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.", "text_sha256": "3d9bb04fe1a63458a1d6e0c92d6ab5536da5e64197faeaf7ac4965f6d5f9d95d", "topics": [ "fabricated-citations" ], "tracker_slug": "harris-v-st-peter-investors-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mnd-2026-harris-v-st-peter-investors", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mnd-2026-harris-v-st-peter-investors" }, { "ai_passage": "11(b) because he signed motions in limine without reading them and, as a result, permitted the filing of motions citing eight non-existent cases that had been hallucinated by Morgan & Morgan’s in-house Artificial Intelligence (“AI”) platform. See Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. Feb. 24, 2025). The Court will exercise its discretion to deny Attorney Morgan’s motion for permission to appear in this case pro hac vice. The Court is troubled by Morgan’s demonstrated failure in the Wyoming case to live up to the ethical - 2 - standards required of trial lawyers. Its concern is heightened by Morgan’s decision to practice law in Massachusetts without permission, by filing his motion in violation of the statute (G.L. c. 221, § 46A) and the Massachusetts Supreme Judicial Court rule (SJC Rule 3:15) that govern pro hac vice motions. In light of Morgan’s recent misconduct in Federal court, and his disregard of Massachusettslawandproceduralrules inthiscase,theCourtisnotpersuaded that Morgan should be granted permission to appear before the Massachusetts Superior Court. 1. Legal Background. ... In February 2025, a Federal District Judge sanctioned Attorney Morgan for submitting motions citing to cases that had been hallucinated by an AI - 3 - platform. Judge Kelly H. Rankin set forth his findings and conclusions about Morgan’s ethical lapses in an “Order on Sanctions and Other Disciplinary Action.” See Wadsworth, 348 F.R.D. 489. Judge Rankin found that in January 2025 Attorney Morgan, as well as his associate at Morgan & Morgan and his local counsel, violated Fed. R. Civ. P. 11(b) by filing motions in limine that cited nine cases, eight of which did not exist.", "ai_tool_named": "MX2.law", "archive_url": null, "case_name": "Glenn Wilder and Others v. President & Fellows of Harvard College and Others", "citation": null, "cited_authorities": [ "See Wadsworth v. Walmart Inc., 348 F", "Rule 3", "Fed. R. Civ. P. 11(b)" ], "court": "Supreme Judicial Court of Massachusetts", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-18", "decision_id": "masssupjudct-2026-glenn-wilder-and-others-v-president-fellows-of", "disposition": "The court denied pro hac vice admission because counsel had signed AI-hallucinated filings in a prior federal case.", "docket_number": "2384CV01461-BLS2", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "MX2.law", "conduct": "Counsel filed a motion using nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2158/Wilder_v__President.pdf", "state": "MA", "summary": "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.", "text_sha256": "da02fc2e175d6a350c23f65ee553bb1cadb283dd5789026292f4b6d0ff666b9c", "topics": [ "fabricated-citations" ], "tracker_slug": "glenn-wilder-and-others-v-president-fellows-of-harvard-college-and-others", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/masssupjudct-2026-glenn-wilder-and-others-v-president-fellows-of", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/masssupjudct-2026-glenn-wilder-and-others-v-president-fellows-of" }, { "ai_passage": "Many of Claxton's factual assertions lack specific record cites, he includes several fictitious or inaccurate case citations, and he relies on numerouslawfirmarticleswithoutexplainingtheirrelevance or persuasive value. Though we could conclude that he has waived his arguments, in our discretion we decline to do so. See Delmastro & Eells v. Taco Bell Corp., 228 Ariz. 134, 137, ¶ 7 n.2 (App. 2011) (acknowledging ARCAP 13 waiver is discretionary). ¶9 Turning to the merits of Claxton's appeal, Brooks filed the closing statement in December 2022. In July 2025, well beyond the six-month limitations period for asserting claims against a personal representative for breach of fiduciary duty, see A.R.S. § 14-3935, Claxton moved to reopen the probate. Thus, the superior court properly concluded that Claxton's breach of fiduciary duty claim against Brooks as personal representative is barred. To the extent Claxton claims that Brooks breached a separate duty as Account trustee, he has waived that claim because he did not raise it in the superior court. See BMO Harris Bank N.A. v. Espiau, 251 Ariz. 588, 594, ¶ 25 (App. 2021).", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Estate of Claxton", "citation": "2026 WL 1383355", "cited_authorities": [ "See Delmastro & Eells v. Taco Bell Corp., 228 Ariz", "See BMO Harris Bank N.A. v. Espiau, 251 Ariz" ], "court": "Arizona Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-18", "decision_id": "arizctapp-2026-estate-of-claxton", "disposition": "The court affirmed and declined to find waiver despite several fictitious or inaccurate citations in the appellant's brief.", "docket_number": "1 CA-CV 25-0685 PB", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a brief using several nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2201/Estate_of_Claxton_USA_18_May_2026.pdf", "state": "AZ", "summary": "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.", "text_sha256": "b25ccb82b68f30221f0b6085de59c5487e1bab63a14790aca709eaf723371812", "topics": [ "fabricated-citations" ], "tracker_slug": "estate-of-claxton", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/arizctapp-2026-estate-of-claxton", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arizctapp-2026-estate-of-claxton" }, { "ai_passage": "9-10.) As set forth at the end of this Opinion and Order, in response to an Order to Show Cause from the Court, Petitioner admits that these cases were incorrectly cited do not support his argument with respect to the ALJ’s decision and has withdrawn such argument. (See Hardy 4/29/25 Decl., ECF No. 47, ¶¶ 5-8.) (CBA, ECF No. 22-1 at 60.) This clause on its face protects union members from layoffs due to technological changes. However, Petitioner was not terminated due to technological changes. Rather, he was terminated due to allegations of falsified entries into a computer template. Thus, the clause has no application here and the Union could have breached no duty by failing to raise it with the arbitrator. In sum, the Petition does not plausibly allege that the Union’s conduct in this case was arbitrary, discriminatory or in bad faith. Rather, the actions taken by the Union in the course of representing Petitioner were tactical choices that cannot support a hybrid § 301/fair representation claim.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Waggeh v. Utility Workers Union of America Local 1-2 et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-16", "decision_id": "nysd-2026-waggeh-v-utility-workers-union-of-america-loca", "disposition": "The court publicly admonished counsel after accepting the withdrawal of incorrectly cited cases.", "docket_number": "1:25-cv-10258 (SDA)", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a response using authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2236/Waggeh_v._Utility_Workers_Union_of_America_USA_16_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "e4c456c704ea8c028db542dccb902d4c2dc3d572a92762165e977b5054180973", "topics": [ "fabricated-citations" ], "tracker_slug": "waggeh-v-utility-workers-union-of-america-local-1-2-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-waggeh-v-utility-workers-union-of-america-loca", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-waggeh-v-utility-workers-union-of-america-loca" }, { "ai_passage": "To start it appears her objection on this front relies on hallucinated case law. Brock cites to Jansen v. City of Cincinnati, 904 F.3d 336, 349–50 (6th Cir. 2018), which she describes as specifically holding that “§ 1983 claims against child welfare workers for fabricating evidence are not barred by Rooker-Feldman.” (Doc. 21, #2408 (emphasis omitted)). She further says that the case is “directly on point and binding.” (Id. at #2409 (emphasis in original)). But there are a couple of problems with that. First, 904 F.3d 336 is the citation for Gilkers v. Vannoy, a Fifth Circuit case involving a habeas petition. Admittedly, there is a Jansen v. City of Cincinnati, 904 F.2d 336 (6th Cir. 1990). And as Brock is proceeding pro se, the Court could perhaps forgive her referring to F.3d, as opposed to F.2d. But that still leaves the second problem—that Jansen opinion likewise says nothing about childcare workers and § 1983. Rather, it involves a challenge to race-based quotas for city employment. Id. at 338–39.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Brock et al. v. Hamilton County JFS Children Services et al.", "citation": null, "cited_authorities": [ "Brock cites to Jansen v. City of Cincinnati, 904 F", "F.3d 336 is the citation for Gilkers v. Vannoy", "Jansen v. City of Cincinnati, 904 F" ], "court": "United States District Court for the Southern District of Ohio", "court_code": "ohsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-15", "decision_id": "ohsd-2026-brock-v-hamilton-county-jfs-children-services", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "1:25-cv-685", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a petition using nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2182/Brock_v._Hamilton_CS_USA_15_May_2026.pdf", "state": "OH", "summary": "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.", "text_sha256": "dddb85d4ec83d6ad21c888459c6a83ba6d250ff7b5720a28483629c98df317cc", "topics": [ "fabricated-citations" ], "tracker_slug": "brock-et-al-v-hamilton-county-jfs-children-services-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohsd-2026-brock-v-hamilton-county-jfs-children-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohsd-2026-brock-v-hamilton-county-jfs-children-services" }, { "ai_passage": "Rule 11(b)(2) provides that by signing a filing, an attorney or unrepresented party certifies that, to the best of his knowledge and after a reasonable inquiry, “the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law.” The rule permits courts to sanction litigants for citations to non-existent case law, misrepresentations of case law, or frivolous legal arguments, regardless of the filer’s pro se status. See, e.g., Ferris v. Amazon.com Servs., LLC, 778 F. Supp. 3d 879, 882 (N.D. Miss. 2025) (ordering a pro se plaintiff to pay the defendant’s costs incurred in responding to fabricated citations). “Courts across the country have issued sanctions against attorneys and pro se parties for submitting fictitious case citations, fictitious quotations, and related misrepresentations to the court.” United States v. Hayes, 763 F. Supp. 3d 1054, 1071 (E.D. Cal. 2025) (emphasis added) (collecting cases). This court has seen an increased use of Artificial Intelligence in briefs, especially by pro se filers. Any user of such tools, including a pro se filer, is still “obligated to read the legal authority he intends to rely upon, confirm its existence and validity, and confirm that it supports his legal contentions, before citing to that authority in any submission to this Court.” Allen v. W. Governors Univ., No.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Bank of America v. Mapp", "citation": null, "cited_authorities": [ "Ferris v. Amazon.com Servs", "United States v. Hayes, 763 F", "Allen v. W. Governors Univ., No", "Rule 11(b)(2)" ], "court": "United States District Court for the Middle District of North Carolina", "court_code": "ncmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-15", "decision_id": "ncmd-2026-bank-of-america-v-mapp", "disposition": "The court remanded the collection case and ordered the defendant to show cause within fourteen days why Rule 11 sanctions should not issue.", "docket_number": "1:26cv77", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions they did not support, and a nonexistent rule or legal standard.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2186/BoA_v._Mapp_USA_15_May_2026.pdf", "state": "NC", "summary": "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.", "text_sha256": "6c5ea9da65c883edda364d921119238d6aa1a0cc51f22a652af0c2e5107edc79", "topics": [ "fabricated-citations" ], "tracker_slug": "bank-of-america-v-mapp", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ncmd-2026-bank-of-america-v-mapp", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ncmd-2026-bank-of-america-v-mapp" }, { "ai_passage": "Rajala referred to is not in the com- plaint, but the secondisasfollows, withexpletivescleanedup for this opinion: Speak for yourself you ugly vial [sic] fake whore. Your ego matches that fake f****** face where you can’t even smile in pictures because your teethare sof*****.The truthhurtsb**** and my message will stay with you forever c***. The manner in which Ms. Rajala took the screenshot did not reveal D’Ambrosio’s alternate phone number or any other identifying information. Despite several opportunities, D’Ambrosio never disputed that he sent this last message un- til oral argument in this appeal. Several users responded to Ms. Rajala’s comments with messages of support and consolation. At least one unidenti- fieduser askedfor informationaboutD’Ambrosio’semployer for the stated purpose of trying to have him fired, but D’Am- brosio does not allege that Ms. Rajala or anyone else disclosed any such information. Another unidentified user with the screenname “Monica Tska” responded with a link to a news article about a man 4 No. 25-2231 charged with sexual assault. ... Rajala, her parents, the STT defendants, and Meta each filed separate motions under Federal Rule of Civil Pro- cedure 12(b)(6) to dismiss the Second Amended Complaint for failure to state a claim. The district court granted the mo- tions, concluded that any further amendment would be futile, and dismissed the case with prejudice. D’Ambrosio appeals. The operative complaint asserts di- versity jurisdiction under 28 U.S.C. § 1332(a).", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Nikko D’Ambrosio v. Meta Platforms Inc.", "citation": null, "cited_authorities": [], "court": "United States Court of Appeals for the Seventh Circuit", "court_code": "ca7", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-15", "decision_id": "ca7-2026-nikko-dambrosio-v-meta-platforms", "disposition": "The court ordered counsel to show cause by June 5, 2026, why sanctions should not issue for citations to cases that do not exist.", "docket_number": "25-2231", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a motion using quotations that did not appear in the cited source, at least one nonexistent or hallucinated authority, authorities used for propositions they did not support, and a nonexistent rule or legal standard.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2157/dAMbrosio_v._Meta_USA_May_2026.pdf", "state": null, "summary": "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.", "text_sha256": "9d5ed0ec36a37fd8cd71e0da2ce05d902e9bbcf757ee9831445498b95d2fc463", "topics": [ "fabricated-citations" ], "tracker_slug": "nikko-dambrosio-v-meta-platforms-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca7-2026-nikko-dambrosio-v-meta-platforms", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca7-2026-nikko-dambrosio-v-meta-platforms" }, { "ai_passage": "Respondent’s draft, however, was replete with citations to non-existent cases attributed by the court to hallucinations by ChatGPT or a similar artificial intelligence program. Complainant was fined $1,500 and ordered to contact the internet platform, self-report their sanction, and report respondent to the New York disciplinary authorities. In furtherance of the AGC’s investigation, on October 3, 2025, the AGC and respondent agreed to November 6, 2025 as the date for respondent’s virtual examination under oath (EUO). However, on October 6, 2025, respondent informed the AGC that she would not be appearing for the scheduled EUO because the AGC’s investigation was “a racist attack and a form of racial and gender harassment.” The AGC then sought respondent’s consent to serve her with a judicial subpoena via email. The subpoena directed respondent to appear for a virtual EUO and to produce specified records.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law", "citation": null, "cited_authorities": [], "court": "Supreme Court of New York, Appellate Division, First Department", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-14", "decision_id": "nyappdiv1-2026-in-matter-of-janelle-melissa-lewis-an-attorney", "disposition": "The court suspended the attorney for three months and imposed a $1,500 sanction for filing an AI-hallucinated judicial-order draft.", "docket_number": "2026-01135; 2026-00170", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Counsel filed a brief using numerous nonexistent or hallucinated authorities.", "currency": "USD", "monetary_penalty": 1500, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2151/In_re_Lewis_USA_14_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "401eae427b9e6cba95c51235eab4e077e18d2dacd3ca4a967a12d0bb986fe081", "topics": [ "fabricated-citations" ], "tracker_slug": "in-the-matter-of-janelle-melissa-lewis-an-attorney-and-counselor-at-law", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nyappdiv1-2026-in-matter-of-janelle-melissa-lewis-an-attorney", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyappdiv1-2026-in-matter-of-janelle-melissa-lewis-an-attorney" }, { "ai_passage": "The record cites that Plaintiff references to support this statement either do not exist (Doc. No. 35-3, at 57:19-58:11; Doc. No. 35-5, at 72:15-74:2), or do not establish that Plaintiff engaged in any such conduct. Doc. No. 35-17. In addition, Plaintiff cites to Nadler v. Harvey, No. 06-12692, 2007 WL 2404705, at *9 (11th Cir. Aug. 24, 2007) to support her argument that Defendant did not maintain an interactive process and therefore must be held liable. Doc. No. 43, at 2. But Nadler addresses the question of whether the McDonnell Douglas burden shifting analysis applies to claims for reasonable accommodation, and the word “interactive” is nowhere mentioned in that case. And the Court is at a loss as to why Plaintiff cites to Kolstad v. American Dental Association, 527 U.S. 526, 536 (1999), (Doc. No. 43, at 21), which addresses whether punitive damages are available under Title VII. 16 Plaintiff cites to Stewart v. Happy Herman’s Cheshire Bridge Inc., 117 F.3d 1278, 1286 (11th Cir. 1997) and Todd v. ... But Plaintiff submitted no evidence to support these assertions, the email chain between Herman and Valencia nowhere mentions any ADA accommodations or work schedule, and Valencia’s Notice of Dismissal discusses Plaintiff’s own admissions on several of these points. See Doc. No. 35-20; Doc. No. 35-22. -25- Doc No. 43, at 4, 9-12, 19-20. But none of these facts rise to the level of direct evidence as they are susceptible to differing interpretations, and therefore require inferences and presumptions to support a finding of discrimination. See Merritt v. Dillard Paper Co., 120 F.3d 1181, 1189 (11th Cir. 1997) (“[D]irect evidence . . . [is] evidence, which if believed, proves [the] existence of [a] fact in issue without inference or presumption.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Stringer v. White Cap Supply Holdings, LLC", "citation": null, "cited_authorities": [ "Plaintiff cites to Nadler v. Harvey, No. 06-12692, 2007 WL 2404705, at *9 (11th Cir. Aug. 24, 2007)", "Court is at a loss as to why Plaintiff cites to Kolstad v. American Dental Association, 527 U", "Title VII. 16 Plaintiff cites to Stewart v. Happy Herman’s Cheshire Bridge Inc., 117 F", "See Merritt v. Dillard Paper Co., 120 F" ], "court": "United States District Court for the Middle District of Florida", "court_code": "flmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-14", "decision_id": "flmd-2026-stringer-v-white-cap-supply-holdings", "disposition": "The court ordered the filer to show cause why sanctions should not issue for the defective authorities.", "docket_number": "6:24-cv-01224-LHP", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a response using record or transcript quotations not found in the record, quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2197/Stringer_v._White_Cap_Supply_Holdings_USA_14_May_2026.pdf", "state": "FL", "summary": "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.", "text_sha256": "ceac6ea4ba6f602e2ef9ed7038e2b47c078109e0418b1a1f9051b033faea2fee", "topics": [ "fabricated-citations" ], "tracker_slug": "stringer-v-white-cap-supply-holdings-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/flmd-2026-stringer-v-white-cap-supply-holdings", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flmd-2026-stringer-v-white-cap-supply-holdings" }, { "ai_passage": "(ECF 11; ECF 13.) On May 13, 2026, the parties filed a joint status report and supplemental brief responding to inquiries from the Court, including the authority for a bond hearing and the status of Petitioner’s 4 Petitioner also cites what appears to be a nonexistent case: Sanchez-Perez v. Garland, 2023 WL 5663021, at *3 (C.D. Cal. Aug. 29, 2023). (ECF 1 at 8.) withholding of removal proceedings. (ECF 12.) With an unopposed petition, the Court rules in conformance therewith.5 ORDER IT IS ORDERED that Judgment shall be entered (1) granting the petition; and (2) enjoining Respondents from continuing to detain Petitioner unless no later than May 20, 2026, he is provided with an individualized bond hearing at which the government must bear the 5 The Supreme Court has made clear that 8 U.S.C. § 1231 applies to noncitizens, like Petitioner, “who were removed from the United States but later reentered without authorization, were subject to reinstated orders of removal, and then sought withholding of removal based on fear of persecution in the particular countries designated by their removal orders.” Johnson v. Guzman Chavez, 594 U.S. 523, 526 (2021). The high court has also made clear that such individuals do not have a statutory right to a bond hearing.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Oscar Danilo Montealto Garcia v. Todd Lyons, et al.", "citation": null, "cited_authorities": [ "Sanchez-Perez v. Garland, 2023 WL 5663021, at *3 (C.D. Cal. Aug. 29, 2023)", "Johnson v. Guzman Chavez, 594 U" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-14", "decision_id": "cacd-2026-oscar-danilo-montealto-garcia-v-todd-lyons", "disposition": "The court granted the habeas petition and noted a non-existent case citation in counsel's briefing.", "docket_number": "5:26-cv-01416-SSC", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed a petition using unsupported or inaccurate legal authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2200/Garcia_v._Lyons_USA_14_May_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "a06d36b108abea4e47e7529bdc0e144ba45a322ba36dddde22593338a3d00395", "topics": [ "fabricated-citations" ], "tracker_slug": "oscar-danilo-montealto-garcia-v-todd-lyons-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-oscar-danilo-montealto-garcia-v-todd-lyons", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-oscar-danilo-montealto-garcia-v-todd-lyons" }, { "ai_passage": "Introduction This matter concerns an issue that has unfortunately become all too common: an attorney’s violation of her ethical and professional responsibilities via the inclusion of fake or misleading case citations in a legal brief. The proliferation of this issue is the result of some attorneys misusing new technological tools – specifically generative AI – to prepare legal briefs.1 In this Court’s opinion, the legal profession’s growing reliance on the use of generative AI to prepare legal briefs is profoundly troubling for two reasons. The primary reason is that there is a willingness by some attorneys (too many) to use generative AI to draft briefs without verifying the accuracy of the content, leading to the inclusion of fake cases and misleading arguments. This conduct is a patent violation of an attorney’s ethical and professional responsibilities. The second reason is that the preparation of a persuasive legal brief requires more than just citation to accurate cases – it requires the exercise of sound judgment. ... The response brief was signed and filed by Plaintiffs’ counsel, Rachel Bussett.2 The response was stricken because the document that was filed included comments and editing notions indicating that it was a draft brief. The response was re-filed [Doc. No. 116] without the notations. Although the response was untimely, Ms. Bussett did not seek leave to file the response or provide any explanation for the delay. Defendants filed separate reply briefs [Doc. Nos. 121, 122] pointing out that Plaintiffs’ response was late, included reference to legal authorities that were either nonexistent or misleading, made inflammatory and inappropriate attacks on defense counsel, and referenced material that was subject to a Protective Order.", "ai_tool_named": "GenAI", "archive_url": null, "case_name": "Jane Doe 1, et al. v. Mount Saint Mary High School Corporation", "citation": null, "cited_authorities": [], "court": "United States District Court for the Western District of Oklahoma", "court_code": "okwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-13", "decision_id": "okwd-2026-jane-doe-v-mount-saint-mary-high-school", "disposition": "The court publicly reprimanded counsel, ordered notice to the client, and required self-reporting to the Oklahoma Bar Association.", "docket_number": "CIV-22-992-R", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GenAI", "conduct": "Counsel filed a reply brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2140/Jane_Does_1-13_and_15-17_et_al_v_Mount_Saint_Mary_High_School_Corporation_USA__HNb0Hcv.pdf", "state": "OK", "summary": "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.", "text_sha256": "9604b9e3e27fce7bc4ccfb6a5f9cc485047efb8fd3aced4bfed8fd068e198246", "topics": [ "fabricated-citations" ], "tracker_slug": "jane-doe-1-et-al-v-mount-saint-mary-high-school-corporation", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/okwd-2026-jane-doe-v-mount-saint-mary-high-school", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/okwd-2026-jane-doe-v-mount-saint-mary-high-school" }, { "ai_passage": "And she relied on an abrogated Supreme Court case and at least one nonexistent case. It was always going to be difficult for petitioner to prevail, but at least he would've had the benefit of liberal construction had he proceeded pro HENRI GIOVANI MORALES JIMENEZ, Petitioner, v...., Slip Copy (2026) se.Individualsinpetitioner'spositionneedzealousadvocates, not“cut-and-pastelawyering.”TubaPullav.Lyons,No.1:26- cv-2682, 2026 WL 906251, at *1 (S.D.N.Y. Apr. 1, 2026). CONCLUSION *4 For the reasons set forth above, the habeas petition is denied. SO ORDERED. Dated: Brooklyn, New York May 12, 2026 All Citations Slip Copy, 2026 WL 1309291 Footnotes 1 Petitioner also argues, in only conclusory terms, that his detention violates the Trafficking Victims Protection Act (“TVPA”) and the “Flores Settlement.” The TVPA has no bearing on the lawfulness of petitioner's detention, as the relevant portions apply only to individuals under the age of 18, and petitioner was 35 when last taken into custody. See 8 U.S.C.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Henri Giovani Morales Jimenez v. Christopher Shanahan", "citation": "2026 WL 1309291", "cited_authorities": [], "court": "United States District Court for the Eastern District of New York", "court_code": "nyed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-13", "decision_id": "nyed-2026-henri-giovani-morales-jimenez-v-christopher-sh", "disposition": "The court denied habeas relief and admonished counsel for briefing that relied on an abrogated decision and a nonexistent case.", "docket_number": null, "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a petition using unsupported or inaccurate legal authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2148/Jimenez_v._Shanahan_USA_13_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "ded95a9fd71483eef21816917a6d67666cba45f997252e4bf35ad61c84194bf6", "topics": [ "fabricated-citations" ], "tracker_slug": "henri-giovani-morales-jimenez-v-christopher-shanahan", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nyed-2026-henri-giovani-morales-jimenez-v-christopher-sh", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyed-2026-henri-giovani-morales-jimenez-v-christopher-sh" }, { "ai_passage": "With respect to the citation errors identified in the Reply [Dkt. No. 222] and acknowledged in the Corrective Notice [Dkt. No. 223], the Court acknowledges and accepts the apologytenderedbyDebtor’scounsel.However,theCourtfindsthatanapology,whileappropriate, does not fully resolve Debtor’s counsel’s obligations under Bankruptcy Rule 9011. The standard governing submissions to this Court is objective: legal contentions must be warranted by existing law at the time of filing. Bankruptcy Rule 9011(b)(2). The citation errors identified in the Reply failed to meet that standard. These deficiencies were not discovered by Debtor’s counsel prior to filing; they were identified by opposing counsel and documented in the Reply. Debtor’s counsel waived further hearing on the Rule 9011 issue. ORDER Based uponthe foregoing findings offact andconclusionsoflaw,andforthe reasons stated on the record at the hearing held on May 6, 2026, it is hereby ORDERED that the Motion is GRANTED IN PART and DENIED IN PART WITHOUT PREJUDICE as set forth below: 1. Cease and Desist; Removal of Prohibited Content. ... Civil Contempt. Debtor is found to be in civil contempt of the Confirmation Order [Dkt. No. 197] by reason of her multiple violations of Paragraph 14 thereof, as set forth in the Findings of Fact and Conclusions of Law above. 3. Attorneys’ Fees and Costs. Ms. Almánzar is awarded her attorneys’ fees and costs in two separate categories. First, Ms.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "In re: Latasha Transrina Kebe", "citation": null, "cited_authorities": [ "Bankruptcy Rule 9011", "Bankruptcy Rule 9011(b)(2)", "Rule 9011" ], "court": "United States Bankruptcy Court for the Southern District of Florida", "court_code": "flsb", "court_level": "federal-bankruptcy", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-13", "decision_id": "flsb-2026-in-re-latasha-transrina-kebe", "disposition": "The bankruptcy court imposed a Rule 9011 sanction against debtor's counsel equal to ten percent of the reply-fee award.", "docket_number": "23-14082-SMG", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "GAI", "conduct": "Counsel filed a motion using authorities used for propositions they did not support.", "currency": "USD", "monetary_penalty": 2232, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending. The bundled PDF also contains a June 30, 2026 agreed order establishing the later fee and Rule 9011 sanction amounts; this row covers the May 13, 2026 sanctions order.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2926/In_re_Kebe_USA_13_May_2026_-_Two_docs.pdf", "state": "FL", "summary": "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.", "text_sha256": "3f2a6efffa58afc59654eb8d04150f297373ad60e05b975e0ba1aee54a45b094", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-latasha-transrina-kebe", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/flsb-2026-in-re-latasha-transrina-kebe", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flsb-2026-in-re-latasha-transrina-kebe" }, { "ai_passage": "His briefs cite numerous cases that do not exist, and they frequently quote case law for propositions that appear nowhere in the cases cited. We have cautioned on the dangers of using generative artificial intelligence before, see, e.g., Russell v. Mells, 426 So. 3d 913, 920 (Fla. 2d DCA 2025), and we again sound the alarm. “This technology is very good at sounding right, but less adept at being right,” and “blind reliance” on it is unwise, unacceptable, and sanctionable. See Gouveia v. Meridian Fin. Invs., LLC, No. 4D2025-0843, 2026 WL 816497, at *3 (Fla. 4th DCA Mar. 25, 2026) (Lott, J., concurring); see also Gutierrez v. Gutierrez, 399 So. 3d 1185, 1187–88 (Fla. 3d DCA 2024) (sanctioning pro se litigant for citing multiple nonexistent cases in his appellate briefs). We notify Mr. Gleason that future filings of this nature will not receive favorable treatment, and we remind all litigants—bothproseandrepresented—thattheymustensure the accuracy of their filings or risk the consequences. See Fla. R. App. P. 9.045(d); Fla. R. Jud. Admin.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Christopher Gleason v. Julie Marcus", "citation": "2026 WL 1311959", "cited_authorities": [ "Russell v. Mells, 426 So", "See Gouveia v. Meridian Fin. Invs", "Gutierrez v. Gutierrez, 399 So" ], "court": "District Court of Appeal of Florida, Second District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-13", "decision_id": "fladistctapp2-2026-christopher-gleason-v-julie-marcus", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "2D2024-2688", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities, and authorities used for propositions they did not support.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2142/Gleason_v._MArcus_USA_13_May_2026.pdf", "state": "FL", "summary": "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.", "text_sha256": "32b6a655b4ef14f6f9c8c83102fd2104c63dd513d4a41398f91c67ff9b9723e1", "topics": [ "fabricated-citations" ], "tracker_slug": "gleason-v-marcus", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp2-2026-christopher-gleason-v-julie-marcus", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp2-2026-christopher-gleason-v-julie-marcus" }, { "ai_passage": "United States District Court Northern District of California Guy cites no authority, apart from a misquoted case regarding the limits of discovery under the federal rules of civil procedure, for the proposition that the Fourth Amendment has any bearing on relevant discovery in a civil lawsuit. See Mot. at 8 (misquoting Henson v. Turn, Inc., No. 15-cv- 01497-JSW (LB), 2018 WL 5281629, at *5 (N.D. Cal. Oct. 22, 2018) as saying compelled production of mobile devices for forensic imaging “is highly intrusive”). The Court finds his argument to be frivolous. See United States v. Int’l Bus. Machines Corp., 83 F.R.D. 97, 102 (S.D.N.Y. 1979) (“It strains common sense and constitutional analysis to conclude that the fourth amendment was meant to protect against unreasonablediscovery demands madebyaprivatelitigant in the course of civil litigation.”); Ariz. Yage Assembly v. Barr,No. CV-20-02373-PHX-ROS, 2024 WL 1011677, *2 (D. Ariz. Feb. 22, 2024), appeal dismissed sub nom. Ariz. Yage Assembly v. Garland, No.", "ai_tool_named": "Claude", "archive_url": null, "case_name": "Joseph Guy v. AFGE", "citation": null, "cited_authorities": [ "Henson v. Turn", "See United States v. Int’l Bus. Machines Corp., 83 F", "Ariz. Yage Assembly v. Barr,No. CV-20-02373-PHX-ROS, 2024 WL 1011677, *2 (D. Ariz. Feb. 22, 2024)", "Ariz. Yage Assembly v. Garland, No" ], "court": "United States District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-13", "decision_id": "cand-2026-joseph-guy-v-afge", "disposition": "The court ordered the plaintiff to explain why sanctions should not issue for misquoting a discovery case.", "docket_number": "Case Nos. 25-cv-03698-SI", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "lawyer", "ai_tool": "Claude", "conduct": "Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2153/Guy_v._AFL-CIO_USA_13_May_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "8da41c6581c159df56667106fd6d9c552ab24487a20a854d18b21568bd9696bd", "topics": [ "fabricated-citations" ], "tracker_slug": "joseph-guy-v-afge", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cand-2026-joseph-guy-v-afge", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-joseph-guy-v-afge" }, { "ai_passage": "Jones included citations that appear to ref- erence cases that do not exist, or at the least contain sig- nificant errors, apparently resulting from the use of artificial intelligence. See, e.g., Pet’r’s Br. 20 (purporting to cite Riley v. Dep’t of Veterans Affs., 64 M.S.P.R. 42, 44–46 (1994), which does not appear to exist); Dkt. No. 14 at 13 (citing Lipscomb v. Dep’t of the Army, 301 F.3d 1356 (Fed. Cir. 2002), which does not appear to exist); Resp’t’s Br. 10–11 & n.5 (listing other apparently fraudulent cita- tions). Mr. Jones does not attempt to explain or justify the inclusion of these citations in his filings before this court in his reply. The use of these false citations is sanctionable, and repetition of this conduct can result in serious conse- quences, potentially including dismissal of his petition for review. JONES v. ARMY 7 We have considered Mr. Jones’s remaining arguments and find them unpersuasive.3 AFFIRMED-IN-PART, VACATED-IN-PART, AND REMANDED COSTS No costs. 3 Mr.", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Jones v. Department of the Army", "citation": null, "cited_authorities": [ "Riley v. Dep’t of Veterans Affs., 64 M", "Lipscomb v. Dep’t of the Army, 301 F", "JONES v. ARMY 7 We have considered Mr. Jones’s remaining arguments and find" ], "court": "United States Court of Appeals for the Federal Circuit", "court_code": "cafc", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-13", "decision_id": "cafc-2026-jones-v-department-of-army", "disposition": "The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.", "docket_number": "25-1822", "document_type": "order", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented appellant filed a petition using nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2136/jones_v._army.pdf", "state": null, "summary": "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.", "text_sha256": "960192966337062fff47921f2769d9be39303d8184191b168a288b618f37d28e", "topics": [ "fabricated-citations" ], "tracker_slug": "jones-v-department-of-the-army", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cafc-2026-jones-v-department-of-army", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cafc-2026-jones-v-department-of-army" }, { "ai_passage": "Law :: Justia https://law.justia.com/cases/new-york/other-courts/2026/2026-ny-slip-op-50864-u.html 3/13 After plaintiff made her reply submission, defendants filed a reply affirmation of counsel, in which they point out that the case citations set forth in plaintiff's filings do not exist, and argues that plaintiff's use of such false citations renders her entire summary judgment motion frivolous (Attorney Affirmation in Reply to Plaintiff's Opposition to Defendants' Cross-Motion for SJ, dated April 8, 2026 [Def Reply Aff] ¶¶ 6-8). They also note that the Court may sanction plaintiff sua sponte under Part 130 of the Rules of the Chief Administrative Judge for using false case citations (id. ¶¶ 11-16). In response, plaintiff sought permission to submit a sur-reply so that she could be heard on defendants' application for sanctions. I granted the motion, and in her sur-reply plaintiff acknowledged that the cases she purports to cite do not exist, but she asserts that she included them without knowing that they were inaccurate (Sur-Reply, dated April 13, 2026 [\"Sur-Reply\"] ¶¶ 1-3). Plaintiff further contends that her use of non-existent case citations was not completely without merit or otherwise frivolous under 22 NYCRR 130-1.1, and defendants were not prejudiced thereby (id. ¶¶ 2-4).", "ai_tool_named": "GAI", "archive_url": null, "case_name": "Gully v Varghese", "citation": "2026 NY Slip Op 50864 (U); 2026 NY Slip Op 50864(U)", "cited_authorities": [ "22 NYCRR 130-1.1" ], "court": "Supreme Court of New York", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-12", "decision_id": "nysupct-2026-gully-v-varghese", "disposition": "The court struck the self-represented plaintiff's reply submission because its case citations could not be located.", "docket_number": "900514-25", "document_type": "opinion", "fetched_at": "2026-09-07T21:36:58Z", "incident": { "actor": "litigant-in-person", "ai_tool": "GAI", "conduct": "A self-represented litigant filed opposition papers using nonexistent or hallucinated authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2482/Gully_v_Varghese__USA_12_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "6b3c60b34800fff195bb0531cf5521805e5b570c942dc7240e7f413ece20011a", "topics": [ "fabricated-citations" ], "tracker_slug": "gully-v-varghese", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-gully-v-varghese", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-gully-v-varghese" }, { "ai_passage": "App. 4 Cir. 10/30/13), 127 So. 3d 156; or 2) explain the source of the citation and whether the citation is erroneous. Counsel's brief shall also address whether any generative artificial intelligence tool was used in the preparation of the instant writ application and, if so, what steps Counsel took to verify the existence and validity of the legal authorities cited therein. Gretna, Louisiana, this 12th day of May, 2026. MEJ FHW SUS FIFTH CIRCUIT 101 DERBIGNY STREET (70053) POST OFFICE BOX 489 GRETNA, LOUISIANA 70054 www. fifthcircuit. org SUSAN M. CHEHARDY CHIEF JUDGE FREDERICKA H. WICKER JUDE G. GRAVOIS MARC E.", "ai_tool_named": null, "archive_url": null, "case_name": "Jacobs v. Timberlake", "citation": "2026 WL 1304558", "cited_authorities": [ "Counsel cited Harvey v. Harvey, 13-0253 (La. App. 4 Cir. 10/30/13), 127 So.3d 156, which the Court and Responden" ], "court": "Louisiana Court of Appeal, Fifth Circuit", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-12", "decision_id": "laapp5-2026-jacobs-v-timberlake", "disposition": "The court ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "26-C-184", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with one fabricated case citation, including Harvey v. Harvey.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2150/Jacobs_v._Timberlake_USA_12_May_2026.pdf", "state": "LA", "summary": "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.", "text_sha256": "324f1cb1f13b0ada0ad5bcd40390d0fbe863c51705192b09848e6123bc592802", "topics": [ "fabricated-citations" ], "tracker_slug": "jacobs-v-timberlake", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/laapp5-2026-jacobs-v-timberlake", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/laapp5-2026-jacobs-v-timberlake" }, { "ai_passage": "But Powell does not make any allegations regarding her plans to return to Bergenfield, including the definiteness of her plan to return and the frequency of traveling there. Therefore, the Court will GRANT Defendant’s Motion and DISMISS Plaintiffs claim for injunctive relief as pled. D. Plaintiff’s Apparent Use of Generative Artificial Intelligence Finally, when reviewing Plaintiff’s Opposition, the Court, like Defendants, identified several inaccurate quotations and citations. Namely, Plaintiffincludes quotations from real cases, but the quotations are fabricated. Defendants list numerous examples. See Reply at 2-3. The presence of fabricated quotations in a brief is a sign that the brief’s author may have used generative artificial intelligence (“GAI”). Pursuant to Section I(B) of the Undersigned’s Judicial Preferences, if a party uses GAI in any court filings, they must include a mandatory disclosure that: “(1) identifies the GAI program: (2) identifies the portionofthe filing drafted by the GAI;", "ai_tool_named": null, "archive_url": null, "case_name": "Zena L. Powell v. The Borough of Bergenfield", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of New Jersey", "court_code": "dnj", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-12", "decision_id": "dnj-2026-zena-l-powell-v-borough-of-bergenfield", "disposition": "The court ordered the self-represented plaintiff to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "2:23-cv-21399-EP-JRA", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed an opposition with one false case quotation and one misstated record or submission point.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2149/Powell_v_8JHRX0s._Borough_USA_12_May_2026.pdf", "state": "NJ", "summary": "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.", "text_sha256": "ab76f79a4233419724f499ed9ba9294d0a520f674c780ce1077200404b5ce23b", "topics": [ "fabricated-citations" ], "tracker_slug": "zena-l-powell-v-the-borough-of-bergenfield", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/dnj-2026-zena-l-powell-v-borough-of-bergenfield", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/dnj-2026-zena-l-powell-v-borough-of-bergenfield" }, { "ai_passage": ", 559 F. 3d 1061, 1071 (9th Cir. 2009). The Court notes that Plaintiff’s SAC appears to have been drafted with the help of generative artificial intelligence (“GenAI”) or similar tools because it contains apparent GenAI responses to prompts. See SAC at 2:19-21, 3:26-28, 4:25-28, 6:22-24, 7:11-13. Of particular concern is an apparent reference to “Sheriff Owens” in one of the responses, who is not named elsewhere in the SAC. See SAC at 3:26-27. This raises concerns that the SAC may contain facts that the generative AI “hallucinated,” that is, made up. The Court previously warned Plaintiff that a misuse of generative AI that includes hallucinations of facts or legal authority can violate Rule 11.", "ai_tool_named": null, "archive_url": null, "case_name": "Pyle v. Glenn County Sheriff's Department", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Eastern District of California", "court_code": "caed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-12", "decision_id": "caed-2026-pyle-v-glenn-county-sheriff-s-department", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "2:24-cv-02940-TLN-CSK", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2139/Pyle_v._Glenn_USA_12_May_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "c8c59479e438f9a7667f5fee5fdcc3f19acf89f5528b44ab2fd94ffc3230faf7", "topics": [ "fabricated-citations" ], "tracker_slug": "pyle-v-glenn-county-sheriffs-department", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/caed-2026-pyle-v-glenn-county-sheriff-s-department", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/caed-2026-pyle-v-glenn-county-sheriff-s-department" }, { "ai_passage": "As a preliminary matter, the County moved for leave to file a corrected reply brief. ECF No. 44. Although the Court agrees withArmstrong'sassessmentthatthemotionwasnecessitated bytheinclusionofafictitiouscase,ECFNo. 47at2,theCourt does not have more information as to why that happened. Regardless, the County caught and corrected the error the same day, meaning that there is no prejudice in allowing the correction. Further, the County's original reply brief included real case law in support of the proposition that the County sought to make, meaning that the fictitious case would be redundant even if it were real. Thus, the Court will grant the County's motion to amend and correct the brief, ECF No. 44, and has considered the corrected brief, ECF No.", "ai_tool_named": null, "archive_url": null, "case_name": "Armstrong v. City of Milwaukee", "citation": "2026 WL 1283883", "cited_authorities": [], "court": "United States District Court for the Eastern District of Wisconsin", "court_code": "wied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-11", "decision_id": "wied-2026-armstrong-v-city-of-milwaukee", "disposition": "The court granted the County leave to file a corrected reply brief after the same-day removal of a fictitious citation and found no prejudice.", "docket_number": "24-CV-1389-JPS", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a reply brief with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2147/Armstrong_v._Milwaukee_USA_11_May_2026.pdf", "state": "WI", "summary": "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.", "text_sha256": "7a26b62fd50b85db0cbfb15b386e4bb592950333d02344e3098ffa047017d2a4", "topics": [ "fabricated-citations" ], "tracker_slug": "armstrong-v-city-of-milwaukee", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wied-2026-armstrong-v-city-of-milwaukee", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wied-2026-armstrong-v-city-of-milwaukee" }, { "ai_passage": "As will be borne out by our discussion infra, that would be a gross misreading of the burdens of proof for the § 5327(b) parental presumption. 3 Mother testified that she has a medical marijuana card, but the trial court reminded her that the Medical Marijuana Act does not permit individuals to smoke marijuana. 4 We note that our research indicates this case does not exist, at least as cited. See also Maternal Grandmother's brief at 21 (noting the cited case “has proven to be unlocatable”). 5 We recognize that Mother's prayer for relief includes a request that we find Maternal Grandmother lacks standing to seek custody. Notwithstanding that demand, Mother has made no argument in support thereof and her statement of questions cannot be read to advance any issue pertaining to Maternal Grandmother's standing.", "ai_tool_named": null, "archive_url": null, "case_name": "Dorothea Bell v. Kelly Bell", "citation": "2026 WL 1286509", "cited_authorities": [], "court": "Superior Court of Pennsylvania", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-11", "decision_id": "pasuperct-2026-dorothea-bell-v-kelly-bell", "disposition": "The court vacated the portion of the custody order awarding primary physical custody, remanded, and noted the mother’s cited case was unlocatable.", "docket_number": "1256 MDA 2025", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented mother filed a brief with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2141/Bell_v._Bell_USA_11_May_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "4e4d413c033945d357fdb9ee7547b6f99c7340a0ca7f7cb185b40b83beba993b", "topics": [ "fabricated-citations" ], "tracker_slug": "dorothea-bell-v-kelly-bell", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pasuperct-2026-dorothea-bell-v-kelly-bell", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pasuperct-2026-dorothea-bell-v-kelly-bell" }, { "ai_passage": "m. BACKGROUND Plaintiff has repeatedly filed briefs containing fabricated, inaccurate, or unverifiable legal citations. The issue first arose in connection with Plaintiff’s Motion for Leave to File a Third Amended Complaint,1 when Defendant Trans Union LLC (“Trans Union”) filed an Ex Parte Motion for Leave to File a Surreply,2 representing that “[a] closer examination of Plaintiff’s Motion reveals Plaintiff’s reliance on fabricated and/or non-existent legal authorities. ”3 The Court granted the Motion,4 and Trans Union’s Surreply was filed onto the record. 5 The Court then set oral argument on the Motion. 6 Before oral argument, Plaintiff filed a Notice of Clarification admitting the citations in his Reply were fabricated and apologizing for the error.", "ai_tool_named": null, "archive_url": null, "case_name": "Burches v. Equifax Information Services, LLC, et al.", "citation": null, "cited_authorities": [ "Plaintiff cited a purported holding from Hays v. HCA Holdings, Inc", "Plaintiff cited Turner v. Murphy Oil USA, Inc., 2006 WL 1984362 (E.D. La. July 13, 2006)" ], "court": "United States District Court for the Eastern District of Louisiana", "court_code": "laed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-11", "decision_id": "laed-2026-burches-v-equifax-information-services", "disposition": "The court ordered the self-represented plaintiff to pay $500 for filing unverified or fabricated authorities.", "docket_number": "2:25-cv-00804-SM-MBN", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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 and Turner v. Murphy Oil USA.", "currency": "USD", "monetary_penalty": 500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2146/Burches_v._Equifax_USA_11_May_2026.pdf", "state": "LA", "summary": "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.", "text_sha256": "9e065fcc76e88dce003b290e20faf3db67d173d998b5badeb186cbc9b264b6e7", "topics": [ "fabricated-citations" ], "tracker_slug": "burches-v-equifax-information-services-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/laed-2026-burches-v-equifax-information-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/laed-2026-burches-v-equifax-information-services" }, { "ai_passage": "3 Because the Court dismisses Plaintiff’s only count for failure to state a claim, the Court declines to address Defendants’ arguments that Plaintiff’s allegations should be stricken as time-barred and that Defendant is protected by qualified immunity. Plaintiff failed to adequately address any of the deficiencies previously identified, so the FAC is dismissed with prejudice. D. Defendant’s citations Despite having granted Defendant’s motion to dismiss, the Court notes with some concern that Defendant appears to have cited a non-existent case in support of her argument. While arguing that Plaintiff’s claim was time barred, Defendant cited to Beecham v. City of Anniston, 42 F. 4th 1130, 1135 (11th Cir. 2022) for the proposition that “discrete acts of speech deletion must occur within limitations period.", "ai_tool_named": null, "archive_url": null, "case_name": "DeVore v. McCombie", "citation": null, "cited_authorities": [ "Defendant cited Alvarez v. City of Chicago with page cites" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-11", "decision_id": "ilnd-2026-devore-v-mccombie", "disposition": "The court ordered defense counsel to file a declaration explaining how the brief was generated and how Beecham and Alvarez were located.", "docket_number": "1:25-cv-00323", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a motion with one fabricated case citation and one mischaracterized case citation, including Alvarez v. City of Chicago with page cites.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2138/DeVore_v._McCombie_USA_11_May_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "5dbd0b448fd1d840df58048339b36fafa8670a944e391b407ba1d259ca1c8834", "topics": [ "fabricated-citations" ], "tracker_slug": "devore-v-mccombie", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-devore-v-mccombie", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-devore-v-mccombie" }, { "ai_passage": "McNeal's brief argues that Broyles used a chatbot to prepare his brief. While there are incorrect citations in the brief, at least one is a correct citation. We caution parties that the products marketed to them as “artificial intelligence,” like calculators, can be useful tools, but any language-like strings of words or citation-like strings of numbers and letters provided therefrommustbeverifiedagainstactualauthorityandshould not be assumed to exist or be correct propositions of law or fact. That said, McNeal's response brief, which was drafted by a licensed attorney, contains no supporting citation to case law, noteventothestandardofreview,andcontainsonlystatutory authorityinresponsetotheissuesraisedbyBroyles. Theonly case law that McNeal references are those cited in Broyles's brief. The lack of a transcript only creates a presumption of regularity, not a requirement that we affirm if the legal basis is questionable.", "ai_tool_named": null, "archive_url": null, "case_name": "Broyles v. McNeal", "citation": "2026 WL 1263356", "cited_authorities": [], "court": "Court of Appeals of Georgia", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-08", "decision_id": "gactapp-2026-broyles-v-mcneal", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a brief with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2130/Broyles_v_McNeal_USA_8_May_2026.pdf", "state": "GA", "summary": "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.", "text_sha256": "454310377f626033361a1b9a3faca919258cddb673a86f5be1a307cc5b56378d", "topics": [ "fabricated-citations" ], "tracker_slug": "broyles-v-mcneal", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gactapp-2026-broyles-v-mcneal", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gactapp-2026-broyles-v-mcneal" }, { "ai_passage": "(2026) 1 In an attempt to further understand the father's arguments, the Court attempted to review his pleadings from the dissolution case. The cases he cites for some of his propositions, such as “In re David W. , 58 Conn. App. 237 (2000)” and “In re Marriage of Doyle, 190 Conn. 748 (1983)”, do not exist and are likely artificial intelligence hallucinations. 2 The child resides with two half-siblings, ages ten and eleven, who also bear the surname Kyne. Kyne v. Ehima, Memorandum of Decision at 2 (Dec. 31, 2025, Egan, J. ). The mother's surname is therefore the operative family surname in the household in which Evelyn will be raised. 3 See Androvic v.", "ai_tool_named": null, "archive_url": null, "case_name": "Kyne v. Ehima", "citation": "2026 WL 1330009", "cited_authorities": [ "Kyne. Kyne v. Ehima" ], "court": "Connecticut Superior Court", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-08", "decision_id": "ctsuperct-2026-kyne-v-ehima", "disposition": "The court denied the name-change petition and contempt motion, added travel-notice directions, and noted likely AI-generated pleadings and nonexistent authority.", "docket_number": "NNH-FA-24-5061240-S, DOCKET NO. NNH-FA-26-5066382-S", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented father filed a pleading with two fabricated case citations and one fabricated factual or other assertion.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2329/02_-_Kyne_v_Ehima.pdf", "state": "CT", "summary": "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.", "text_sha256": "53b07f82ee775bce4d1d1a46b6768a4adf50b3ee19804b23734551b2129a18ce", "topics": [ "fabricated-citations" ], "tracker_slug": "kyne-v-ehima", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ctsuperct-2026-kyne-v-ehima", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ctsuperct-2026-kyne-v-ehima" }, { "ai_passage": "Bussett blames the briefing errors on her use of a “trusted legal vendor’s AI tool” to research and draft the brief as well as some “more traditional errors. ” Id. at p. 3. Ms. Bussett concedes that she failed to perform the essential step of personally verifying the case citations and has apologized for her conduct. Id. The Court finds that Ms. Bussett’s conduct – specifically the inclusion of fake or misleading authority in a written brief – violates Rule 11(b)(2). See Wadsworth v. Walmart Inc. , 348 F. R. D. 489, 495 (D. Wyo. 2025) (“[U]sing a fake opinion to support an argument is a violation of Rule 11(b)(2). ”);", "ai_tool_named": null, "archive_url": null, "case_name": "Kristina Crist v. Roy Chris West, et al.", "citation": null, "cited_authorities": [ "See Wadsworth v. Walmart Inc. , 348 F", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Western District of Oklahoma", "court_code": "okwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-07", "decision_id": "okwd-2026-kristina-crist-v-roy-chris-west", "disposition": "The court publicly reprimanded counsel, fined counsel $250, and ordered counsel to notify the client of the sanctions order.", "docket_number": "5:25-cv-01446-R", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with one fabricated case citation and one mischaracterized case citation.", "currency": "USD", "monetary_penalty": 250, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2101/Crist_v_Canadian_County_et_al_USA_7_May_2025.pdf", "state": "OK", "summary": "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.", "text_sha256": "a19d009285aaba9fe7f18a38b5b2e74d88da04882890ebd4fb12ed470a7b02ac", "topics": [ "fabricated-citations" ], "tracker_slug": "kristina-crist-v-roy-chris-west-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/okwd-2026-kristina-crist-v-roy-chris-west", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/okwd-2026-kristina-crist-v-roy-chris-west" }, { "ai_passage": "262 at 1 (citing “United States v. Stone, 988 F. 2d 1056, 1061 (10th Cir. 1993). ”). The Court assumes Neri either erroneously combined a case name and legal citation or carelessly relied on an artificial intelligence program to craft this citation. 1 If this reference was indeed the product of artificial intelligence, then the Court issues a warning to Neri: courts “make some allowances for Upon review, the legal citation corresponds to Hall v. Western Production Co. , 988 F. 2d 1050 (10th Cir. 1993). the pro se plaintiff’s failure to cite proper legal authority,” but courts ordinarily do not coddle a plaintiff who cites to fake, nonexistent, or misleading authorities. Fomby v.", "ai_tool_named": null, "archive_url": null, "case_name": "Neri v. Board of Education for Albuquerque Public Schools", "citation": null, "cited_authorities": [ "United States v. Stone, 988 F", "Hall v. Western Production Co. , 988 F", "Tenth Circuit case 'United States v. Stone, 988 F.2d 1056, 1061 (10th Cir. 1993)'", "Hall v. Western Production Co., 988 F.2d 1050 (10th Cir. 1993)" ], "court": "United States District Court for the District of New Mexico", "court_code": "nmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-07", "decision_id": "nmd-2026-neri-v-board-of-education-for-albuquerque-public-schools", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:19-cv-00008-JCH-SCY", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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 and Hall v. Western Production Co after using Centient AI.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2129/Neri_v_Albuquerque_Public_Schools_et_USA_7_May_2026.pdf", "state": "NM", "summary": "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.", "text_sha256": "c7baddfdb1ba0a7ca2ed108bfb1f9995e2a9fc779b28915b7dd67b8cfd55f4fc", "topics": [ "fabricated-citations" ], "tracker_slug": "neri-v-board-of-education-for-albuquerque-public-schools", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nmd-2026-neri-v-board-of-education-for-albuquerque-public-schools", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nmd-2026-neri-v-board-of-education-for-albuquerque-public-schools" }, { "ai_passage": "and the appellant's legal argument, including the authorities on which the appellant relies. Without these essential elements included in the appellant's brief, we decline to address the alleged errors because the case is not properly before us. [¶4] Stokka's brief lacks reference to the evidentiary record supporting his statement of the facts and the legal authorities on which he relies. The few legal authorities cited by Stokka are either irrelevant, fictitious, or nonexistent. See City of Dickinson v. Helgeson, 2026 ND 34, ¶¶ 16, 19, 31 N. W. 3d 672 (explaining fake or nonexistent legal citations typically are the result of AI hallucinations and awarding $500 as a sanctionformisconduct). Stokka'sbriefdoesnotcomplywith the minimum requirements of N.", "ai_tool_named": null, "archive_url": null, "case_name": "Stokka v. Stokka", "citation": "2026 ND 94", "cited_authorities": [ "See City of Dickinson v. Helgeson, 2026 ND 34, ¶¶ 16, 19, 31 N" ], "court": "Supreme Court of North Dakota", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-07", "decision_id": "nd-2026-stokka-v-stokka", "disposition": "The court awarded double costs and $1,000 in attorney fees because the brief cited irrelevant, fictitious, or nonexistent authorities.", "docket_number": "20250298", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented appellant filed a brief with one fabricated case citation.", "currency": "USD", "monetary_penalty": 1000, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2132/Stokka_v_Stokka_USA_7_May_2026.pdf", "state": "ND", "summary": "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.", "text_sha256": "dba672c22b4eb3cb06c681173ce4bc76c97e7ef8c3d45142ad116f8a12ba24fe", "topics": [ "fabricated-citations" ], "tracker_slug": "stokka-v-stokka", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nd-2026-stokka-v-stokka", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nd-2026-stokka-v-stokka" }, { "ai_passage": "(emphasis in original). Plaintiff was cautioned yet again on April 1, 2026, that his repeated violations of Rule 11 and court orders could result in dismissal of this action without further notice. See [Doc. 52]. Despite these repeated warnings, Plaintiff filed another motion containing fictitious legal authorities the day before his third show cause hearing. See [Doc. 57]. At the April 29, 2026 hearing, Plaintiff acknowledged both that he repeatedly submitted fabricated citations and that dismissal was an appropriate sanction under the circumstances. The record demonstrates a clear pattern of delay, contumacious conduct, and disregard for the Court’s orders. Plaintiff’s repeated submission of fabricated legal authority substantially delayed the progress of this litigation and resulted in “significant periods of total inactivity.", "ai_tool_named": null, "archive_url": null, "case_name": "Joshua Harris v. Pinnacle Bank", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Northern District of Mississippi", "court_code": "msnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-07", "decision_id": "msnd-2026-joshua-harris-v-pinnacle-bank", "disposition": "The court dismissed the case with prejudice as a sanction for repeated fabricated citations and other Rule 11 violations.", "docket_number": "3:25-cv-157. Case: 3:25-cv-00157-RPC-RP Doc", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2128/Harris_v._Pinnacle_Bank_USA_7_May_2026.pdf", "state": "MS", "summary": "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.", "text_sha256": "0320746989b0dc840eb5a3a8f0e10cac640130208ea6d9dda37901c9aeeb1bd4", "topics": [ "fabricated-citations" ], "tracker_slug": "joshua-harris-v-pinnacle-bank", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/msnd-2026-joshua-harris-v-pinnacle-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/msnd-2026-joshua-harris-v-pinnacle-bank" }, { "ai_passage": "But Tobler provides no factual support for his assertion that Diane Kelly told his process server that she was authorized to accept service on behalf of the firm. And the firm’s reply brief notes that Tobler’s reliance on Bunner is worse than just misplaced; Tobler included a fake quote and holding. Plaintiff hallucinates the holding and his quote from Bunner. Bunner involved the issue of whether service of process under the Michigan Court Rules was proper on a bankruptcy trustee where the defendant corporation was defunct. Bunner is not controlling or relevant to any of the issues here. Further, the Case 5:25-cv-13384-JEL-EAS ECF No.", "ai_tool_named": null, "archive_url": null, "case_name": "Eric Tobler v. Stephen Tobler, et al.", "citation": null, "cited_authorities": [ "Bunner v. Blow-Rite Insulation Co" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-07", "decision_id": "mied-2026-eric-tobler-v-stephen-tobler", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "25-13384 Honorable Judith E. Levy Magistrate", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a reply brief with one false case quotation, including Bunner v. Blow-Rite Insulation Co.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2127/Tobler_v._Tobler_USA_7_May_2026.pdf", "state": "MI", "summary": "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.", "text_sha256": "798973296a755d027c5ed1cb849dd1b5c043f7fd5417cda63971559c9eca975a", "topics": [ "fabricated-citations" ], "tracker_slug": "eric-tobler-v-stephen-tobler-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-eric-tobler-v-stephen-tobler", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-eric-tobler-v-stephen-tobler" }, { "ai_passage": "¶ 29 Given this context, combined with the history of the case, we concur with the district court’s conclusion that father’s motions “lacked substantial justification” and appeared to be part of a vexatious “pattern of behavior where [father] asks for reconsideration of any decision he does not agree with, despite legal precedent. ” We therefore affirm the district court’s April 14, 2025, award of attorney fees against father in the amount of $1,665. 3 Although there is perhaps another explanation for father’s citations of nonexistent cases, we observe that they bear many of the hallmarks of “hallucinations” that are a well-publicized problem associated with generative artificial intelligence large language models. See, e. g. , Al-Hamim v.", "ai_tool_named": null, "archive_url": null, "case_name": "Marriage of Nash", "citation": null, "cited_authorities": [], "court": "Colorado Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-07", "decision_id": "coloctapp-2026-marriage-of-nash", "disposition": "The court affirmed the $1,665 attorney-fee sanction and awarded appellate fees and costs after noting nonexistent authorities.", "docket_number": "25CA0978 Larimer County District Court No. 19DR3016", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented father filed a motion with one fabricated case citation and one mischaracterized case citation.", "currency": "USD", "monetary_penalty": 1665, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2233/In_re_mcKay_USA_7_May_2026.pdf", "state": "CO", "summary": "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.", "text_sha256": "99762ab5d9d1191058db3878fe328f104e25149241d87f6f17920f4c190d3836", "topics": [ "fabricated-citations" ], "tracker_slug": "marriage-of-nash", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/coloctapp-2026-marriage-of-nash", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/coloctapp-2026-marriage-of-nash" }, { "ai_passage": "36 at 11, Plaintiffs failed to correct those misrepresentations in their Proposed Statement of Decision filed on April 15, 2026 (Docket No. 39). Accordingly, Plaintiffs' counsel are ordered to show cause, in writing,onorbeforeMay11,2026,whythisCourtshouldnot impose sanctions on counsel in the amount of $2,500. 00 and/ ordismissthisaction. Plaintiffs'counselshallfiledeclarations in support of their response to the order to show cause, which shall address, inter alia, whether artificial intelligence was used to draft Plaintiffs' Opposition and Proposed Statement of Decision, and what actions counsel took to determine that any of the propositions of law relied on by Plaintiffs were accurate. Nooralargumentonthismatterwillbeheardunless otherwise ordered by the Court. See Fed. R. Civ. P.", "ai_tool_named": null, "archive_url": null, "case_name": "Song Dow Lee, et al. v. HSBC Bank USA, National Association, et al.", "citation": "2026 WL 1270038", "cited_authorities": [ "Inc. v. Umpqua Holding Corp., 669 F.Supp.3d 904, 906 (N.D. Cal. 2023).' The court noted the citation/quote did" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-07", "decision_id": "cacd-2026-song-dow-lee-v-hsbc-bank", "disposition": "The court ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "CV 26-1198-JFW", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an opposition with one fabricated case citation and one mischaracterized case citation, including Inc. v. Umpqua Holding Corp.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2131/Song_Dow_Lee_et_al_v_HSBC_Bank_USA_National_Association_et_al_USA_7_May_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "57e47a85691e68f92405992d6b87cb405e1d14972737c9e75466f22c97b090f4", "topics": [ "fabricated-citations" ], "tracker_slug": "song-dow-lee-et-al-v-hsbc-bank-usa-national-association-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-song-dow-lee-v-hsbc-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-song-dow-lee-v-hsbc-bank" }, { "ai_passage": "We issued an order to show cause “(1) why plaintiff's opening brief should not be stricken in part or in whole and (2) why this court should not, on its own motion, impose monetary sanctions for submitting briefing to this court that contained nonexistent case law. ” In plaintiff's response to the order to show cause, she claimed that she conducted her research in good faith despite limited access to legal research tools, did not intend to submit fabricated authority, and had been “subjected to heightened scrutiny for minor or correctable citation issues” while defendants relied on questionable legal authority without consequences in the trial court. She also pointed us toward her “prior experience regarding citation errors” as evidence that she has a history *270 of acting in good faith and being willing to correct errors once they are identified. Specifically, she pointed us toward her actions in a separate appeal before this court.", "ai_tool_named": null, "archive_url": null, "case_name": "Boersma v. Davenport", "citation": null, "cited_authorities": [], "court": "Oregon Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-06", "decision_id": "orctapp-2026-boersma-v-davenport", "disposition": "The court ordered the self-represented plaintiff to pay $500 for filing unverified or fabricated authorities.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed an opening brief with one fabricated case citation and one mischaracterized case citation.", "currency": "USD", "monetary_penalty": 500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2113/Boersma_v_Davenport_USA_6_May_2026.pdf", "state": "OR", "summary": "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.", "text_sha256": "c92c6452062754dfb5b8c8f0d79a32ad0334818aedd12ca8b0b4f3c28437d973", "topics": [ "fabricated-citations" ], "tracker_slug": "boersma-v-davenport", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/orctapp-2026-boersma-v-davenport", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/orctapp-2026-boersma-v-davenport" }, { "ai_passage": "Applewhite v. N. Y. C. Dep’t of Educ. , No. 24-cv-2131, 2025 WL 783650 (2d Cir. Mar. 12, 2025). Plaintiff is therefore denied a further opportunity to amend. III. Warning About Fake Quotes and Citations Defendant brings to the Court’s attention that Plaintiff’s Opposition includes citations to a nonexistent case, GAI Consultants, Inc. v. Homestead Vill. Ltd. P’ship, 961 F. Supp. 1437, 1445 (E. D. Pa. 1997), see Opp. at 16, and nonexistent quotations in several other cases. 7 See Reply at 9–10. The Second Circuit has explained that a party’s attempt to persuade a court or oppose an adversary by relying on non-existent precedent “is an abuse of the adversary system. ” Park v.", "ai_tool_named": null, "archive_url": null, "case_name": "Terrance Anthony Norris v. JPMorgan Chase Bank N.A.", "citation": null, "cited_authorities": [ "Applewhite v. N. Y. C. Dep’t of Educ. , No. 24-cv-2131, 2025 WL 783650 (2d Cir", "Inc. v. Homestead Vill. Ltd. P’ship, 961 F", "Inc. v. Homestead Vill. Ltd. P’ship, 961 F. Supp. 1437 (E.D. Pa. 1997)", "Plaintiff attributes a quotation to Diesel Props S.r.l. v. Greystone Bus. Credit II LLC, 631 F.3d 42 (2d Cir. 2011) that does not appear in that opinion", "Plaintiff attributes a quotation to Dalton v. Educ. Testing Serv., 87 N.Y.2d 384, 394 (1995) that does not exist in that opinion" ], "court": "United States District Court for the Eastern District of New York", "court_code": "nyed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-06", "decision_id": "nyed-2026-terrance-anthony-norris-v-jpmorgan-chase-bank-n-a", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "2:25-cv-03231-HG-JMW", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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 and Diesel Props S.r.l. v. Greystone Bus. Credit II LLC.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2099/Norris_v._JP_Morgan_USA_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "e3d071f8bb853ae419398fbe093bad75bc243cb31edd5c6c6213b0bfcd24260a", "topics": [ "fabricated-citations" ], "tracker_slug": "terrance-anthony-norris-v-jpmorgan-chase-bank-n-a", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nyed-2026-terrance-anthony-norris-v-jpmorgan-chase-bank-n-a", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyed-2026-terrance-anthony-norris-v-jpmorgan-chase-bank-n-a" }, { "ai_passage": "After reviewing Plaintiff’s opposition, the Court was unable to locate three of the four cases cited therein. 1 Concerned that these inaccuracies suggest hallucinations from the use of The Court does not include the names of these cases here, as doing so could inadvertently amplify any error that these cases exist. United States District Court Northern District of California generative artificial intelligence tools, the Court issued a second show cause order, directing Ms. Barsotti to file a declaration by May 4, 2026 that: (1) identifies, verbatim and by page and line, each statement or quotation in the opposition that cites to a legal authority; (2) explains the origin of each such statement and citation, including whether any generative artificial intelligence tool was used in preparing any portion of the filing, and, if so, which tool(s) and how they were used;", "ai_tool_named": null, "archive_url": null, "case_name": "Gregoire v. Board of Trustees of SF BART", "citation": null, "cited_authorities": [], "court": "United States District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-06", "decision_id": "cand-2026-gregoire-v-board-of-trustees-of-sf-bart", "disposition": "The court fined counsel $1,000, ordered live CLE, and required service of the order on the client and the California State Bar.", "docket_number": "3:25-cv-02150-TSH", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an opposition with one fabricated case citation.", "currency": "USD", "monetary_penalty": 1000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2093/Gregoire_v._BART_USA_6_May_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "99d321f9aef2c5dc7a7e3c560eb6f6471079a4247acf78f3b1c381d6613f6013", "topics": [ "fabricated-citations" ], "tracker_slug": "gregoire-v-board-of-trustees-of-sf-bart", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cand-2026-gregoire-v-board-of-trustees-of-sf-bart", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-gregoire-v-board-of-trustees-of-sf-bart" }, { "ai_passage": "It points to, among other deficiencies in her brief, several citations by Adams that appear to be non-existent. It points also to fictitious quotations Adams attributed to real cases that do not contain such language, Adams’s inaccurate descriptions of case holdings and mischaracterizations of the clerk’s and reporter’s records, and Adams’s failure to comply with Texas Rules of Appellate Procedure, including failing to provide the required Appendix and Certificate of Compliance. Our review of Adams’s brief reveals ABCI’s contentions to be true. We note also the trial court previously admonished Adams as follows: Ms. Adams is reminded that, as a pro se litigant, she is held to the same standards as licensed attorneys and must comply with applicable laws and rules of procedure.", "ai_tool_named": null, "archive_url": null, "case_name": "Amanda Adams v. Allen Butler Construction, Inc.", "citation": null, "cited_authorities": [], "court": "Texas Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-05", "decision_id": "texapp-2026-amanda-adams-v-allen-butler-construction", "disposition": "The court affirmed the order awarding attorney fees and dismissing the case, rejecting arguments supported by nonexistent cases and false quotations.", "docket_number": "07-25-00191-CV AMANDA ADAMS, APPELLANT V. ALLEN BUT", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2111/Adams_v._Butler_USA_5_May_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "590bb3c16ce5a8c7ff4db74fe7f6e03d9f44536458bed53d918f4868fc6d7699", "topics": [ "fabricated-citations" ], "tracker_slug": "amanda-adams-v-allen-butler-construction-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp-2026-amanda-adams-v-allen-butler-construction", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp-2026-amanda-adams-v-allen-butler-construction" }, { "ai_passage": "For this reason, the Court need not reach the other dismissal arguments made, including those regarding service. A Caution on AI Hallucinations As a postscript to these motions, the Court must address certain AI-generated hallucinations in Petitioners’ papers. After the fake citations were pointed out in the reply papers, Petitioners’ counsel wrote a letter to the Court acknowledging the false citations, withdrawing them, and apologizing. At oral argument held on these motions, counsel reiterated the apology, acknowledged that the use of AI without proper checking was wrong, and identified the specific ways that steps were being taken by him and his firm to prevent future problems. While the Court does not deem it necessary to issue sanctions here, it does wish to issue a warning about the use of AI in preparing court documents.", "ai_tool_named": null, "archive_url": null, "case_name": "DOE, J. et al v. The Trustees of Columbia University", "citation": null, "cited_authorities": [], "court": "Supreme Court of the State of New York", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-05", "decision_id": "nysupct-2026-doe-j-v-trustees-of-columbia-university", "disposition": "The court granted dismissal motions, denied the Article 78 petition, and noted counsel’s withdrawal and apology for AI-fabricated citations.", "docket_number": "002 003 004", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a reply brief with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2392/Doe_v._Columbia_U_USA_5_May_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "92f096f4b5e0365ff87ed5820eae654e2a7fcb9d4ad3a3d0e8265f4df17e1b26", "topics": [ "fabricated-citations" ], "tracker_slug": "doe-j-et-al-v-the-trustees-of-columbia-university", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-doe-j-v-trustees-of-columbia-university", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-doe-j-v-trustees-of-columbia-university" }, { "ai_passage": "ECF No. 50 at 4. While AI tools can be useful, and this court does not prohibit litigants from using them, those services pull information from across the web—including from unreliable sources—and they often hallucinate (or make up fake) legal authority. Using AI to supply legal authority for briefs an unrepresented litigant or attorney signs any filing before this court, he certifies that “the claims, defenses, and other legal contentions are warranted by existing law. ”35 Parties must verify that the authorities they mention are accurate before presenting them to a court. Repeated violations of this sort may invite sanctions—including case dismissal. Conclusion IT IS THEREFORE ORDERED that plaintiff Ryne Seeto’s motion for summary judgment [ECF No.", "ai_tool_named": null, "archive_url": null, "case_name": "Seeto v. Kendall", "citation": null, "cited_authorities": [ "Withrow v. Larkin, but the court found that language does not appear in Withrow", "Plaintiff cited Bittinger v. Tecumseh Products Co. for the proposition that voluntary engagemen" ], "court": "United States District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-05", "decision_id": "nvd-2026-seeto-v-kendall", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "2:25-cv-00038-JAD-EJY Order Denying Motions", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a brief with one false case quotation, one mischaracterized case citation, and one fabricated factual or other assertion.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2109/Seeto_v._Kendall_USA_5_May_2026.pdf", "state": "NV", "summary": "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.", "text_sha256": "b49aaaf54419c49903cb08d4310e67a381a922068b7e341f1c031ba599baee8e", "topics": [ "fabricated-citations" ], "tracker_slug": "seeto-v-kendall", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nvd-2026-seeto-v-kendall", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-seeto-v-kendall" }, { "ai_passage": "3d ----, 2026 WL 1216594 Footnotes 1 All Rule references are to Missouri Supreme Court Rules (2018) unless otherwise specified. Van Deel v. A-Plus Contracting, LLC, --- S. W. 3d ---- (2026) 2 Appellant's brief contains other deficiencies impeding appellate review, including multiple inaccurate or nonexistent caselaw citations. It also mistakenly denominates this Court as the “U. S. District Court for the Eastern District of Missouri,” rather than our proper name “The Missouri Court of Appeals Eastern District. ” 3 Rule 84. 04(d)(1) also provides a format for points on appeal, stating that, “The point shall be in substantially the following form: ‘The trial court erred in [identify the challenged ruling or action], because [state the legal reasons for the claim of reversible error], in that [explain why the legal reasons, in the context of the case, support the claim of reversible error]. ’ ” 4 Appellant's argument section for her second point on appeal includes only one caselaw citation, “B.", "ai_tool_named": null, "archive_url": null, "case_name": "Van Deel v. A-Plus Contracting, LLC", "citation": "2026 WL 1216594", "cited_authorities": [ "Van Deel v. A-Plus Contracting", "Appellant cited 'B.M. v. J.S., 775 S.W. 2d 917 (Mo. App. W.P. 1989)', which the court was unable to verify as a" ], "court": "Missouri Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-05", "decision_id": "moctapp-2026-van-deel-v-a-plus-contracting", "disposition": "The court dismissed the appeal because the appellant’s brief violated appellate briefing rules and included inaccurate or nonexistent caselaw citations.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with two fabricated case citations, including B.M. v. J.S.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2112/Van_Deel_v_A-Plus_Contracting_LLC_USA_5_May_2026.pdf", "state": "MO", "summary": "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.", "text_sha256": "6867a944fb3a1d51968a00736b74af0291825415d9332c67d343d0929ee40db6", "topics": [ "fabricated-citations" ], "tracker_slug": "van-deel-v-a-plus-contracting-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/moctapp-2026-van-deel-v-a-plus-contracting", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/moctapp-2026-van-deel-v-a-plus-contracting" }, { "ai_passage": "7. 1(j). Because Randolph failed to obtain prior permission, his motions are unauthorized and are therefore denied. The Court notes that Randolph’s motions contain citations to non‐existent cases as well as quotes that do not appear in the cited case, suggesting that he used generative AI to create his memoranda and did not verify that his citations were accurate. By filing motions and other papers, a litigant “certifies that to the best of [his] knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . -2- the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law. ” Fed.", "ai_tool_named": null, "archive_url": null, "case_name": "Randolph v. Erick Berscheid Trucking, LLC et al", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Minnesota", "court_code": "mnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-05", "decision_id": "mnd-2026-randolph-v-erick-berscheid-trucking", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "17. Accordingly, the Court treated EB Trucking", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a motion with one fabricated case citation and one false case quotation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2184/Randolph_v._Trucking_USA_5_May_2026.pdf", "state": "MN", "summary": "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.", "text_sha256": "56556760e8c61726196770eafd20a36f7247aee0c56f861b7bc23bcbac3d240d", "topics": [ "fabricated-citations" ], "tracker_slug": "randolph-v-erick-berscheid-trucking-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mnd-2026-randolph-v-erick-berscheid-trucking", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mnd-2026-randolph-v-erick-berscheid-trucking" }, { "ai_passage": "An attorney who chooses to use such tools must ensure that every citation and quoted passage has been independently confirmed using reliable legal sources, and that any limitations of AI tools are fully understood and accounted for. Here, the Courtfinds that several specific aspects of counsel’s conductdid notsatisfy thestandard required by Rule 11. She relied on generative AI to produce case citations and descriptions but did not confirm that those authorities existed or accurately stated the law before filing. After Defendants identified significant errors in the original filing, she did not promptly withdrawor correctit, and it remains on the docket. In her Noticeof Errata,sherepeated and extended some of the same problems instead of fully remedying them. She has not shown that she reimbursed her client for time spent on the faulty filings.", "ai_tool_named": "Claude or ChatGPT", "archive_url": null, "case_name": "Jessica Fuller v. Hyde School, et al.", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11" ], "court": "United States District Court for the District of Maine", "court_code": "med", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-05", "decision_id": "med-2026-jessica-fuller-v-hyde-school", "disposition": "The court struck the defective opposition, ordered counsel to serve the order on the client, complete CLE, and certify firm AI procedures.", "docket_number": "2:25-cv-00354-SDN", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": "Claude or ChatGPT", "conduct": "Counsel filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation after using Claude or ChatGPT.", "currency": null, "monetary_penalty": null, "outcome": "strike-off" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2091/USCOURTS-med-2_25-cv-00354-0.pdf", "state": "ME", "summary": "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.", "text_sha256": "4dcd131d8e435328254c95cd066789ab3d8b62e3eeaea81b7830fc8d9c6eca60", "topics": [ "fabricated-citations" ], "tracker_slug": "jessica-fuller-v-hyde-school-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/med-2026-jessica-fuller-v-hyde-school", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/med-2026-jessica-fuller-v-hyde-school" }, { "ai_passage": "S. 544, 570 (2007)). The complaint “may not simply recite the elements of a cause of action,” and instead “must contain sufficient allegations of underlying facts to give Before the April 8, 2026 hearing, the court issued an order identifying a number of record- and case-citation issues in Moore’s oppositions and directing Moore’s counsel to be “prepared to explain these issues, and in particular, whether they resulted from the use of artificial intelligence (‘AI’) tools. ” ECF No. 75. During the hearing, Moore’s counsel explained that Moore (that is, the client) had taken a lead role in preparing the oppositions and had used AI tools in the process of doing so. ECF No.", "ai_tool_named": null, "archive_url": null, "case_name": "Moore v. MC Architects Inc., et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Hawaii", "court_code": "hid", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-05", "decision_id": "hid-2026-moore-v-mc-architects", "disposition": "The court ordered counsel to pay $1,000 for filing unverified or fabricated authorities.", "docket_number": "24-00367 JMS-KJM", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed oppositions with multiple record- and case-citation errors tied to AI use by the client and accepted responsibility for filing them.", "currency": "USD", "monetary_penalty": 1000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2100/Moore_v._MC_Architect_USA_5_May_2026.pdf", "state": "HI", "summary": "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.", "text_sha256": "67ec89ac970698dc29c6ca65a30d43755fb1405b676c3af665f6e86f46b654ca", "topics": [ "fabricated-citations" ], "tracker_slug": "moore-v-mc-architects-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/hid-2026-moore-v-mc-architects", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/hid-2026-moore-v-mc-architects" }, { "ai_passage": "1. On March 20, 2026, after oral argument in this case, this Court entered an order directing counsel for the State to file a supplemental brief explaining, among other things, how the September 12, 2025 order of the trial court denying Payne’s motion for new trial (which reflects that ADA Leslie prepared that order) came to include nine case citations that either do not exist or do not stand for the propositions for which they are cited. 1 On March 27, 2026, Clayton County ADA Leslie filed a supplemental brief and affidavit in which she acknowledged using artificial intelligence software to draft the State’s briefs in opposition to Payne’s motion for new trial and the trial court’s proposed order denying the motion for new trial. ADA Leslie acknowledged that the case citations generated by artificial intelligence software were not independently verified before inclusion in the State’s briefs or proposed order and represented that she had implemented safeguards to ensure that fictitious or misattributed authorities would not appear in any future filings.", "ai_tool_named": null, "archive_url": null, "case_name": "Hannah Renee Payne v. The State", "citation": null, "cited_authorities": [], "court": "Supreme Court of Georgia", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-05", "decision_id": "ga-2026-hannah-renee-payne-v-state", "disposition": "The court vacated and remanded the trial-court order, barred the prosecutor from appearing for six months, and ordered twelve CLE hours.", "docket_number": "S26A0459 Hannah Renee Payne v. The State On Appeal", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "prosecutor", "ai_tool": null, "conduct": "The prosecutor’s appellate briefing and the trial-court order used AI-generated authorities that did not exist or did not support the propositions cited.", "currency": null, "monetary_penalty": null, "outcome": "suspension" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2090/Payne_v._State.pdf", "state": "GA", "summary": "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.", "text_sha256": "b2f61a9ac78a3d9eaecee725639c97481b7a49c2141c47c7eb4b1906a78d0688", "topics": [ "fabricated-citations" ], "tracker_slug": "hannah-renee-payne-v-the-state", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ga-2026-hannah-renee-payne-v-state", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ga-2026-hannah-renee-payne-v-state" }, { "ai_passage": "Defendants, during the hearing, asserted that they were wary of Plaintiffs’ explanation, given that the holdings of the “correct” cases were not the holdings that were cited to in the Amended Complaint, and likewise were not cited in Plaintiffs’ Opposition to the Motion to Dismiss. Defendants requested that the court, at a minimum, award attorney fees incurred due to theuseofnon-existentcaselaw. Further,Defendantsrequestedthatthecourt impose,as asanction, a dismissal of the entire Amended Complaint; or, in the alternative, grant partial or full dismissal of the Second Cause of Action as a sanction1 as requested by Defendants in their Motion to Dismiss. The court ordered the parties to meet and confer to determine whether they could stipulate to a monetary amount that Plaintiffs would pay Defendants for the attorney fees incurred.", "ai_tool_named": null, "archive_url": null, "case_name": "Regan Wilkes, et al. v. Canyons School District, et al.", "citation": null, "cited_authorities": [ "Amended Complaint cited a non-existent 'A.S. v. Norwalk Public Schools", "J.M. v. Francis Howell School District", "Amended Complaint cited a non-existent 'F.C. v. Capistrano Unified School District'", "Amended Complaint cited a non-existent 'A.D. v. Puyallup School District No. 3, 2015' (purported 4th Cir.) to support statute-of-limitations arguments" ], "court": "United States District Court for the District of Utah", "court_code": "utd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-04", "decision_id": "utd-2026-regan-wilkes-v-canyons-school-district", "disposition": "The court imposed Rule 11 sanctions and ordered plaintiffs’ counsel to pay defendants $7,000 for expenses caused by non-existent case law.", "docket_number": "2:25-cv-00218-CMR", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an opposition with three fabricated case citations and one mischaracterized case citation, including A.S. v. Norwalk Public Schools and J.M. v. Francis Howell School District.", "currency": "USD", "monetary_penalty": 7000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2092/Wilkes_v._Canyon_School_USA_4_May_2026.pdf", "state": "UT", "summary": "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.", "text_sha256": "543c042c93d7464f81eb02b06179bdcf8c5a4e8f20070744d09ac32978b82f25", "topics": [ "fabricated-citations" ], "tracker_slug": "regan-wilkes-et-al-v-canyons-school-district-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/utd-2026-regan-wilkes-v-canyons-school-district", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/utd-2026-regan-wilkes-v-canyons-school-district" }, { "ai_passage": "Defendants filed the pending motion to dismiss, Mr. Robinson filed a response, and Defendants filed a reply. ECF Nos. 34, 36, 40. Mr. Robinson also filed a “Declaration Regarding Citation Clarifications” in which he attempts to explain why his response brief contains nonexistent cases and quotations, as pointed out in Defendants’ reply brief. ECF No. 41. On April 22, 2026, the Court held a hearing on Defendants’ motion for sanctions, during which the Court provided the parties an opportunity to address the motion to dismiss. DISCUSSION Among other things, Defendants argue that the release in the Agreement bars Mr. Robinson’s claims. The Court agrees.", "ai_tool_named": null, "archive_url": null, "case_name": "Devin A. Robinson v. Velosio, LLC", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Maryland", "court_code": "mdd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-04", "decision_id": "mdd-2026-devin-a-robinson-v-velosio", "disposition": "The court granted defendants’ motion to dismiss and dismissed the third amended complaint with prejudice after noting non-existent cases and quotations.", "docket_number": "1:25-cv-02270-ABA", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a reply brief with one fabricated case citation and one false case quotation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2125/Robinson_v_Velosio_LLC_et_al_USA_5_May_2026Y.pdf", "state": "MD", "summary": "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.", "text_sha256": "809a68295e96d34e781b8cc317932eeccc3419870cd8973e8259a78465905233", "topics": [ "fabricated-citations" ], "tracker_slug": "devin-a-robinson-v-velosio-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdd-2026-devin-a-robinson-v-velosio", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdd-2026-devin-a-robinson-v-velosio" }, { "ai_passage": "At this second show-cause hearing, Williamson stated that the errors were unintentional and based on his lack of legal knowledge. He admitted that some of the cases he cited did not exist, and that he had found them using artificial intelligence. He also admitted that he did not follow the Local Rules because they were confusing to him as a pro se litigant and he could not locate them. The magistrate judge found that Williamson’s errors were USCA11 Case: 25-13045 Document: 29-1 Date Filed: 05/04/2026 Page: 3 of 6 4 Opinion of the Court 25-13045 “some of the most egregious things” she had seen from a pro se litigant,” and that she had given him many chances to comply with theLocalRulesandcourtorders, andhadtoldhimwherehecould findthem. Themagistratejudgeultimatelystayedthelitigationsua sponte to consider the arguments presented at the hearing.", "ai_tool_named": null, "archive_url": null, "case_name": "Eliott Williamson v. TransUnion LLC, Experian Information Solutions, Inc.", "citation": null, "cited_authorities": [], "court": "United States Court of Appeals for the Eleventh Circuit", "court_code": "ca11", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-04", "decision_id": "ca11-2026-eliott-williamson-v-transunion-experian-information-solutions", "disposition": "The Eleventh Circuit affirmed dismissal with prejudice after the magistrate judge found willful misuse of nonexistent and misquoted cases.", "docket_number": "3:24-cv-00043-WWB-PDB", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2116/Williamson_v._Transunion_USA_4_May_2026.pdf", "state": null, "summary": "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.", "text_sha256": "4b3c81f3db2e8bc68ba8ec221c17b5eab1ed8d20e4568d7ddffb18ecede5cf30", "topics": [ "fabricated-citations" ], "tracker_slug": "eliott-williamson-v-transunion-llc-experian-information-solutions-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca11-2026-eliott-williamson-v-transunion-experian-information-solutions", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca11-2026-eliott-williamson-v-transunion-experian-information-solutions" }, { "ai_passage": "However, in light of the history of this action and baseless arguments that have been proffered defendants are strongly cautioned that if they fail to comply or engage in further frivolous conduct serious coercive sanctions may be imposed. The court also may reconsider whether a receiver is necessary if it appears that the approach here is akin to what occurred in Herman. Hopefully, that will not be necessary. Finally, as a separate but no less serious matter, defense counsel included what appear to be AI hallucinations in the opposition brief (see Dkt. 74 at 16-17). He cites two cases (“Jones Wolf Realty v 2 E. 79th St. Corp.", "ai_tool_named": null, "archive_url": null, "case_name": "Drip Capital, Inc. v. SGM Socher Inc.", "citation": "2026 WL 1279092", "cited_authorities": [], "court": "Supreme Court of the State of New York", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-01", "decision_id": "nysupct-2026-drip-capital-v-sgm-socher", "disposition": "The court ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "651061/2025. May 1, 2026", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an opposition with two fabricated case citations, including Gildea v Sheridan and Jones Wolf Realty v 2 E. 79th St. Corp.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2325/1_-_Drip_Capital_Inc_v_SGM_Socher_Inc.pdf", "state": "NY", "summary": "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.", "text_sha256": "250806cd4429c07c0e84c30fc2a31728fe0292903cba5f1b54c0dd5b0ebbb628", "topics": [ "fabricated-citations" ], "tracker_slug": "drip-capital-inc-v-sgm-socher-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-drip-capital-v-sgm-socher", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-drip-capital-v-sgm-socher" }, { "ai_passage": "On June 27, 2025, theCourtissued its first showcauseorder,identifying threeadditionalcases in theMarch response brief that it could not locate. [Doc. 101, at 2]. The Court ordered Plaintiffs to (1) produce PDF versions of every case cited in the March response brief and three motions to compel; (2) describetheactionsofeachattorneyinvolvedinthecreationofthebriefs; (3)describehowcounsel became aware of the non-existent cases; (4) identify any other filings that could contain nonexistent cases; and (5) show cause why counsel should not be sanctioned. Id. at 3. II. BRIEFING SUMMARY Plaintiffs identified sixteen total cases across the March response brief and two motions to compel that did not exist. [Doc.", "ai_tool_named": null, "archive_url": null, "case_name": "Rasheem Carter, et al. v. UZGlobal LLC, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of New Mexico", "court_code": "nmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-01", "decision_id": "nmd-2026-rasheem-carter-v-uzglobal", "disposition": "The court fined counsel $1,000 payable to the clerk, ordered bar reporting, required proof of AI CLE, and barred passing costs to clients.", "docket_number": "1:23-cv-01013-MV-JHR", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with four fabricated case citations.", "currency": "USD", "monetary_penalty": 1000, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2106/Carter_et_al_v_UZGlobal_LLC_USA_1_May_2025.pdf", "state": "NM", "summary": "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.", "text_sha256": "f37fc948240a4e5426ed6f3a6684bac745e66ab065f0fca1a8bec2a744431a53", "topics": [ "fabricated-citations" ], "tracker_slug": "rasheem-carter-et-al-v-uzglobal-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nmd-2026-rasheem-carter-v-uzglobal", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nmd-2026-rasheem-carter-v-uzglobal" }, { "ai_passage": "Mississippi, 2025 WL 3691876, at *3-5 (discussing an attorney’s obligations under Rule 11 and their duty to conduct a reasonable inquiry into the law and facts of the case). Based on the instances outlined above, Mr. Rice is directed to SHOW CAUSE on or before May 15, 2026, why the Court should not impose sanctions for citing an apparently fictitious case and misrepresenting the quotations from a Supreme Court case. In addition to explaining his actions, Mr. Rice is ORDERED to do all the following in his response: (1) Disclose the extent to which he used artificial intelligence (“AI”) in conducting legal research; (2) Disclose the extent to which he used AI to draft his Response [20] and all other briefs submitted in this case;", "ai_tool_named": null, "archive_url": null, "case_name": "Johnny Fuselier v. John S. Riscassi", "citation": "2013 WL 12173926", "cited_authorities": [ "Fed. R. Civ. P. 11", "Plaintiff cited 'Rodriguez v. It’s Just Lunch, Int’l, 2013 WL 12173926 (5th Cir. 2013)', which the Court found appears fictitio" ], "court": "United States District Court for the Southern District of Mississippi", "court_code": "mssd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-01", "decision_id": "mssd-2026-johnny-fuselier-v-john-s-riscassi", "disposition": "The court admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct.", "docket_number": "1:25-cv-00268-HSO-BWR", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "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 after using Fastcase; Google AI.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2110/Fuselier_v._Riscassi_USA_1_May_2026.pdf", "state": "MS", "summary": "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.", "text_sha256": "cc20d04779c84a67ceec4eed43423bbb1889e316d40c570da99824d958bdc8e5", "topics": [ "fabricated-citations" ], "tracker_slug": "johnny-fuselier-v-john-s-riscassi", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mssd-2026-johnny-fuselier-v-john-s-riscassi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mssd-2026-johnny-fuselier-v-john-s-riscassi" }, { "ai_passage": "therefore, Defendants state that, although they are no longer able to promise adjudication within sixty days of remand, they still request that the case be remanded to USCIS to comprehensively review Mr. Gurri Rubio’s application. ECF No. 37 ¶ 6. First, the Court must again note that Mr. Gurri Rubio’s complaint and his response to the motion to remand also include nonexistent quotations. In his complaint, he claims to quote from Tutun v. United States, 270 U. S. 568, 578 (1926), which he claims states “When the applicant shows his eligibility, the court has the duty to grant the application. ” ECF No. 1 at 7.", "ai_tool_named": null, "archive_url": null, "case_name": "Yasmani Gurri Rubio v. Markwayne Mullin, et al.", "citation": null, "cited_authorities": [ "Tutun v. United States, 270 U", "Plaintiff attributed a nonexistent quotation to Hahn v. United States", "Hazel-Atlas Glass Co. v. Hartford-Empire Co", "Plaintiff attributed a nonexistent quotation to Tutun v. United States", "Taalebinezhaad v. Chertoff" ], "court": "United States District Court for the District of Maryland", "court_code": "mdd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-01", "decision_id": "mdd-2026-yasmani-gurri-rubio-v-markwayne-mullin", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:25-cv-02756-ABA", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a pleading with five false case quotations, including Hahn v. United States and Hazel-Atlas Glass Co. v. Hartford-Empire Co.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2097/Rubio_v._Mullin_USA_1_May_2026.pdf", "state": "MD", "summary": "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.", "text_sha256": "ea1ab38cf0ea1c0f4ffee195353b91f3c06008dd75edc55fa04fe7ca4984cc81", "topics": [ "fabricated-citations" ], "tracker_slug": "yasmani-gurri-rubio-v-markwayne-mullin-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdd-2026-yasmani-gurri-rubio-v-markwayne-mullin", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdd-2026-yasmani-gurri-rubio-v-markwayne-mullin" }, { "ai_passage": "However, her status as a pro se litigant does not exempt her from following the Kentucky Rules of Appellate Procedure (RAP). Koester v. Koester, 569 S. W. 3d 412, 415 (Ky. App. 2019). Pertinent to the case sub judice, RAP 32(4) mandates an appellant’s argument must have “ample . . . citations of authority pertinent to each issue of law[. ]” It is obvious to this Court that Sherdena used Generative AI to write her brief. Notably, two cases cited therein do not exist or were “hallucinated”: E. D. v. D. T. , 338 S. W. 3d 56 (Ky. App. 2011), and Commonwealth v. Thurman, -8- 691 S. W.", "ai_tool_named": null, "archive_url": null, "case_name": "Sherdena Rocky Ali v. Carlos Efre Idiokitas", "citation": null, "cited_authorities": [ "Koester v. Koester, 569 S", "E. D. v. D. T. , 338 S", "Commonwealth v. Thurman" ], "court": "Kentucky Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-01", "decision_id": "kyctapp-2026-sherdena-rocky-ali-v-carlos-efre-idiokitas", "disposition": "The court warned the self-represented appellant to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "25-D-00106-003 CARLOS EFRE IDIOKITAS", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented appellant filed a brief with two fabricated case citations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2098/Sherdena_Rocky_Ali_v._Carlos_USA_1_May_2026.pdf", "state": "KY", "summary": "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.", "text_sha256": "d6340ee0b59e1666e153a41c44c1e0b220d3f95bec924e0808160355dd7f268e", "topics": [ "fabricated-citations" ], "tracker_slug": "sherdena-rocky-ali-v-carlos-efre-idiokitas", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/kyctapp-2026-sherdena-rocky-ali-v-carlos-efre-idiokitas", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/kyctapp-2026-sherdena-rocky-ali-v-carlos-efre-idiokitas" }, { "ai_passage": "(2) the claims, defenses, and other legal contentions therein are warranted by existing law or by a nonfrivolous argument for the extension, modification, or reversal of existing law or the establishment of new law; [and] (3) the allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary support after a reasonable opportunity for further investigation or discovery[. ] Fed. R. Civ. P. 11(b). “While there is no general prohibition on using [artificial intelligence] during the course of litigation, Plaintiff [must] ensure he is not citing to fake opinions in his filings. ” Gordon v. Wells Fargo Bank N. A. Inc. , No. 5:24-CV-388 (CAR), 2025 WL 1057211 (M. D. Ga.", "ai_tool_named": null, "archive_url": null, "case_name": "Chamberlain v. City of Albany", "citation": null, "cited_authorities": [ "Gordon v. Wells Fargo Bank N. A. Inc. , No. 5:24-CV-388 (CAR", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Middle District of Georgia", "court_code": "gamd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-01", "decision_id": "gamd-2026-chamberlain-v-city-of-albany", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:25-CV-123", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a submission with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2108/Chamberlain_v._ALbany_USA_1_May_2026.pdf", "state": "GA", "summary": "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.", "text_sha256": "74436a6c81ae21c93b532827a61b06184f04322ffda62cf50efa787bc2b19475", "topics": [ "fabricated-citations" ], "tracker_slug": "chamberlain-v-city-of-albany", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gamd-2026-chamberlain-v-city-of-albany", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gamd-2026-chamberlain-v-city-of-albany" }, { "ai_passage": "48) at 32–33, 41. Sullivan timely responded and “does not dispute the errors identified in the Order. ” Resp. (Doc. 50) at 2. Sullivan acknowledges that he used artificial intelligence tools, including ChatGPT, to research and draft the School Board's motion to dismiss. See id. at 2–3. He admits that he did not “complete an independent verification of each citation before filing and did not realize at the time that the cited authorities were inaccurate or unsupported. ” Id. at 3. Sullivan accepts full responsibility for the errors and does not attribute them to the School Board or anyone else. Id.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Richard Paul Smith v. Verra Mobility Corporation et al.", "citation": "2026 WL 1197241", "cited_authorities": [ "School Board relied on 'Morgulis v. BusPatrol Am., LLC, 2020 WL 1923164, at *8–9 (E.D.N.Y. Apr. 21, 2020)' as authority", "School Board cited a non-existent decision 'Gonzalez v. City of Coral Gables, 2018 WL 2392077 (S.D. Fla. May 25, 2018)'", "School Board cited a non-existent decision 'Abreu v. City of Miami Beach, 2021 WL 3625049 (S.D. Fla. Aug. 16, 2021)'" ], "court": "United States District Court for the Middle District of Florida", "court_code": "flmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-05-01", "decision_id": "flmd-2026-richard-paul-smith-v-verra-mobility", "disposition": "The court ordered counsel to notify the client about mis-cited and nonexistent cases and required a client-signed certification.", "docket_number": "8:25-cv-2300-KKM-NHA", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Counsel filed a motion with three fabricated case citations and one mischaracterized case citation, including Morgulis v. BusPatrol Am and Gonzalez v. City of Coral Gables after using ChatGPT.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2107/Smith_v._Verra_USA_1_May_2025.pdf", "state": "FL", "summary": "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.", "text_sha256": "587ff4fc0ac132985c633e815502ef542872792189abdf2a66bbc4ba1de92eab", "topics": [ "fabricated-citations" ], "tracker_slug": "richard-paul-smith-v-verra-mobility-corporation-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/flmd-2026-richard-paul-smith-v-verra-mobility", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flmd-2026-richard-paul-smith-v-verra-mobility" }, { "ai_passage": "3d 341, 345 (Tex. App. —El Paso 2015, no pet. ); and Clements v. Haskovec, 251 S. W. 3d 79, 83 (Tex. App. —Corpus Christi–Edinburg 2008, no pet. ). Moreover, from Allen, Cane provided a purported quote that does not exist, and regarding Clements, she represented that the court of appeals reversed a trial court's protective order, when in fact, the court affirmed it. Second, and equally concerning, is Cane's citing three cases that do not appear to exist: In re J. B. G. , 540 S. W. 3d 446, 450 (Tex. App. —Houston [1st. Dist. ] 2018); Ex parte Hughes, 133 S. W.", "ai_tool_named": null, "archive_url": null, "case_name": "K.C. v. D.R.", "citation": "2026 WL 1190661", "cited_authorities": [ "Clements v. Haskovec, 251 S" ], "court": "Texas Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "texapp-2026-k-c-v-d-r", "disposition": "The court affirmed the family-violence protective order after disregarding unsupported arguments based on false quotations and nonexistent cases.", "docket_number": "02-25-00234-CV", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a submission with three fabricated case citations, one false case quotation, and two mischaracterized case citations.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2115/KC_Appellant_v_DR_Appellee_USA_30_April_2026.pdf", "state": "TX", "summary": "The Texas Court of Appeals on 2026-04-30 affirmed the family-violence protective order after disregarding unsupported arguments based on false quotations and nonexistent cases in K.C. v. D.R. The self-represented party filed a submission with three fabricated case citations, one false case quotation, and two mischaracterized case citations.", "text_sha256": "9879f163c3c6db97ee8bcaa45f45211a34b5fb0d96c4a531c64819ea11fcfb7d", "topics": [ "fabricated-citations" ], "tracker_slug": "k-c-v-d-r", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp-2026-k-c-v-d-r", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp-2026-k-c-v-d-r" }, { "ai_passage": "Agents, Emps. or Officers, 855 F. 2d 1080, 1091 (3d Cir. 1988). It has come to the court’s attention that plaintiff, in his opposition to the motion to dismiss, submitted legal citations to cases that do not exist, fake quotes from real cases, and inaccurate legal arguments attributed to real cases. For example, plaintiff quoted the following from McIvor v. Credit Control Services, 773 F. 3d 909 (8th Cir. 2014): “A CRA may be liable under §1681i if it receives sufficient information to identify the disputed account, regardless of the channel through which the dispute is transmitted. ” Response in Opposition, Berry v. Early Warning Services, Civ.", "ai_tool_named": null, "archive_url": null, "case_name": "Jamal Berry v. Early Warning Services", "citation": null, "cited_authorities": [ "McIvor v. Credit Control Services, 773 F", "Berry v. Early Warning Services", "Plaintiff quoted a passage purportedly from McIvor v. Credit Control Servs., 773 F.3d 909 (8th Cir. 2014)", "Plaintiff cited Gonzalez v. Experian Info. Sols., Inc., No. 20-cv-8997, 2021 WL 7285265 (C.D. Cal. 2021)", "Plaintiff relied on Weseman v. Wells Fargo Home Mortg., No. 06-1338, 2008 WL 542961 (D. Or. Feb. 22, 2008) and attributed to it a rule a" ], "court": "United States District Court for the Eastern District of Pennsylvania", "court_code": "paed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "paed-2026-jamal-berry-v-early-warning-services", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "2:25-cv-04638-HB", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed an opposition with one fabricated case citation, one false case quotation, and one mischaracterized case citation, including McIvor v. Credit Control Servs and Gonzalez v. Experian Info. Sols.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2064/Berry_v._Early_Warning_USA_30_April_2026.pdf", "state": "PA", "summary": "The Eastern District of Pennsylvania on 2026-04-30 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jamal Berry v. Early Warning Services. The self-represented plaintiff filed an opposition with one fabricated case citation, one false case quotation, and one mischaracterized case citation, including McIvor v. Credit Control Servs.", "text_sha256": "c9a0538155c6f6f3ffc8d1d02b0b080cef44f839758454cebed2a7338c6de35d", "topics": [ "fabricated-citations" ], "tracker_slug": "jamal-berry-v-early-warning-services", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/paed-2026-jamal-berry-v-early-warning-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/paed-2026-jamal-berry-v-early-warning-services" }, { "ai_passage": "Y. 2008) exists, but it has nothing to do with removal, and none of the quoted language appears in the opinion; Whitaker v. Am. Telecasting, Inc. , 261 F. 3d 196 (2d Cir. 2001) exists and involves removal, but says nothing about whether a removed complaint may be filed as an exhibit to another document. due to Plaintiff’s use of generative AI tools. See, e. g. , Romero v. Goldman Sachs Bank USA, No. 25-CV-2857 (GHW), 2025 WL 1916119, at *1-2 (S. D. N. Y. June 25, 2025) (cautioning that “citations, quotations, and holdings that have been generated by generative artificial intelligence may be hallucinations”). But no matter what the cause, the “presentation of false citations, quotations, and holdings by a party .", "ai_tool_named": null, "archive_url": null, "case_name": "Sana Hazina Butler v. Fidelity Management & Research Company LLC", "citation": null, "cited_authorities": [ "Whitaker v. Am. Telecasting", "Romero v. Goldman Sachs Bank USA, No. 25-CV-2857 (GHW", "Inc. v. Neewra, Inc. with quoted language the court determined does not appear in that opinion", "Plaintiff cited Parisie v. Greer, which exists but the court noted it has nothing to do with removal (misstated re", "Plaintiff cited Whitaker v. American Telecasting, which involves removal but does not support the specific proposition about filin", "Plaintiff cited 'Rong Zhu v. BNP Paribas, 997 F. Supp. 2d 242 (S.D.N.Y. 2014)', which the court found does not exist", "Plaintiff cited Azer v. Connell and included quoted language the court found does not appe" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "nysd-2026-sana-hazina-butler-v-fidelity-management-and-research", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:25-cv-09337-RA-RFT", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a pleading with one fabricated case citation, three false case quotations, and two mischaracterized case citations, including Inc. v. Neewra and Parisie v. Greer.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2078/Butler_v._Fidelity_USA_30_April_2026.pdf", "state": "NY", "summary": "The Southern District of New York on 2026-04-30 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions. The self-represented party filed a pleading with one fabricated case citation, three false case quotations, and two mischaracterized case citations, including Inc. v. Neewra.", "text_sha256": "9d0ea9b84d2bd620c1415ad1f0cf72ae5c1aa7692eb653580c2444e530a13f50", "topics": [ "fabricated-citations" ], "tracker_slug": "sana-hazina-butler-v-fidelity-management-research-company-llc-2026", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-sana-hazina-butler-v-fidelity-management-and-research", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-sana-hazina-butler-v-fidelity-management-and-research" }, { "ai_passage": "Nonexistent Legal Authority Before this Court begins its analysis, it must address Wellington’s pervasive citations to non-existent authority in her briefing. This is unacceptable. Defendants point out that Wellington’s initial opposition brief contains six “purported authorities that, on information and belief, do not appear in any legal database. ” Reply at 1-2. The Court was likewise unable to locate these authorities, which seem to be cases that were “hallucinated” using an artificial intelligence tool. “Without question, it is improper and unacceptable for litigants — including pro se litigants — to submit ‘non-existent judicial opinions with fake quotes and citations. ’” Anonymous v. New York City Dep’t of Educ. , No. 24- cv-04232 (JLR), 2024 WL 3460049, at *7 (S.", "ai_tool_named": null, "archive_url": null, "case_name": "Mercy Wellington v. City of New York", "citation": null, "cited_authorities": [ "Anonymous v. New York City Dep’t of Educ. , No. 24- cv-04232 (JLR" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "nysd-2026-mercy-wellington-v-city-of-new-york", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:24-cv-08743-JLR", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed an opposition with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2062/Wellington_v._New_York_USA_30_April_2026.pdf", "state": "NY", "summary": "The Southern District of New York on 2026-04-30 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Mercy Wellington v. City of New York. The self-represented party filed an opposition with one fabricated case citation.", "text_sha256": "6a23e891be371ada65b30fe45af23975f5ce79effde548a41d52348b1b8c2d24", "topics": [ "fabricated-citations" ], "tracker_slug": "mercy-wellington-v-city-of-new-york", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-mercy-wellington-v-city-of-new-york", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-mercy-wellington-v-city-of-new-york" }, { "ai_passage": "Under the circumstances presented here and considering Thomasson’s response to the OSC, this Court is left with no choice but to impose sanctions under Rule 11 which is well in line with the developing case law. See e. g. , United States v. Cohen, 724 F. Supp. 3d 251, 258 (S. D. N. Y. 2024) (collecting cases) (“There is no doubt that sanctions can be imposed on at least some of these grounds for the citation to non-existent cases); Cartagena v. Dixon, No. 25-CV- 03552 (JLR), 2026 WL 673811, at *5 (S. D. N. Y. Mar. 10, 2026) (“Sanctions may be imposed for submitting false or nonexistent legal authority to the Court”); Kaur v. Desso, No. 25-CV-726 (AMN), 2025 WL 1895859, at *3 (N.", "ai_tool_named": null, "archive_url": null, "case_name": "Superb Motors Inc. et al. v. Anthony Deo et al.", "citation": "2025 WL 2256653", "cited_authorities": [ "United States v. Cohen, 724 F", "Cartagena v. Dixon, No. 25-CV- 03552 (JLR", "Kaur v. Desso, No. 25-CV-726 (AMN", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Eastern District of New York", "court_code": "nyed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "nyed-2026-superb-motors-v-anthony-deo", "disposition": "The court ordered counsel to pay $1,500 for filing unverified or fabricated authorities.", "docket_number": "2:23-cv-06188-JMW", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a submission with two fabricated case citations, including In re Marcus, 491 F.2d 56, 60 (2nd Cir. 1974).", "currency": "USD", "monetary_penalty": 1500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2079/Superb_Motors_v._Deo_USA_30_April_2026.pdf", "state": "NY", "summary": "The Eastern District of New York on 2026-04-30 ordered counsel to pay $1,500 for filing unverified or fabricated authorities in Superb Motors Inc. et al. v. Anthony Deo et al. Counsel filed a submission with two fabricated case citations, including In re Marcus, 491 F.2d 56, 60 (2nd Cir. 1974).", "text_sha256": "7df5f545271de68caa66df0ca129ec7d7b96088bbb1514403f2b81c4a1d78187", "topics": [ "fabricated-citations" ], "tracker_slug": "superb-motors-inc-et-al-v-anthony-deo-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nyed-2026-superb-motors-v-anthony-deo", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyed-2026-superb-motors-v-anthony-deo" }, { "ai_passage": "), quoting Black's Law Dictionary, 1103 (6 Ed. 1991). ensure that they support the proposition they are representing. 19 It goes without saying that submitting fake or materially misleading citations means that the attorney failed to read and verify the cases. R. C. 2323. 51(A)(2) defines “frivolous conduct” as: Conduct of … other party to a civil action… that satisfies any of the following: (i) It obviously serves merely to harass or maliciously injure another party to the civil action or appeal or is for another improper purpose, including, but not limited to, causing unnecessary delay or a needless increase in the cost of litigation. (ii) It is not warranted under existing law, cannot be supported by a good faith argument for an extension, modification, or reversal of existing law, or cannot be supported by a good faith argument for the establishment of new law.", "ai_tool_named": null, "archive_url": null, "case_name": "Ascent Management, Inc. et al v. Shell Oil Company et al", "citation": null, "cited_authorities": [ "Perrico v. Verizon, 2018-Ohio-3994.' Court found no such opinion on search and treated it as a fabri", "Kyser v. Summit County Children Services, 2022-Ohio-1207,' but court's search showed the reporter corresponds to a differe", "Citation to 'Baker v. Coast to Coast Manpower, LLC, 2020-Ohio-4533' corresponded to a different published decision on search" ], "court": "Court of Common Pleas of Montgomery County, Ohio", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "montgomery-oh-ccp-2026-ascent-management-v-shell-oil", "disposition": "The court awarded $5,237 against the filing party for expenses caused by fabricated or misrepresented authorities.", "docket_number": "2024 CV 03112 JUDGE STEVEN K. DANKOF", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a submission with one fabricated case citation and three mischaracterized case citations, including Perrico v. Verizon and Kyser v. Summit County Children Services.", "currency": "USD", "monetary_penalty": 5237, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2464/Ascent_Management_v._Shell_USA_30_April_2026.pdf", "state": "OH", "summary": "The Court of Common Pleas of Montgomery County, Ohio on 2026-04-30 awarded $5,237 against the filing party for expenses caused by fabricated or misrepresented authorities in Ascent Management, Inc. et al v. Shell Oil Company et al. Counsel filed a submission with one fabricated case citation and three mischaracterized case citations, including Perrico v. Verizon.", "text_sha256": "cd3605a63255bb338850bf198f12c6239dffecff4ee5894d4f8c128bbefe54b5", "topics": [ "fabricated-citations" ], "tracker_slug": "ascent-management-inc-et-al-v-shell-oil-company-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/montgomery-oh-ccp-2026-ascent-management-v-shell-oil", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/montgomery-oh-ccp-2026-ascent-management-v-shell-oil" }, { "ai_passage": "The Supreme Court case cited by VanAlstine, Highland Park v Grifith Motors, 336 Mich 588, 592; 59 NW2d 54 (1953), does not exist—it's a hallucinated citation that is likely the product of generative artificial intelligence (AI). *6 VanAlstine contends that he “made diligent efforts to comply with local requirements, including consulting with Clinton County Building officials,” and there is “no evidence of health or safety risks caused by the structure with the zoning requirement. ” VanAlstine began construction before applying for the required building and zoning permits, and he stated that construction was “mostly complete” before he requested a zoning variance. “[E]veryone dealing with a municipality and its agents is charged with knowledge of the restrictive provisions of lawfully adopted ordinances.", "ai_tool_named": null, "archive_url": null, "case_name": "Eagle Township v. Shaun VanAlstine", "citation": "2026 WL 1194667", "cited_authorities": [], "court": "Michigan Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "michctapp-2026-eagle-township-v-shaun-vanalstine", "disposition": "The court affirmed summary disposition for the township and noted the appellant’s cited Michigan Supreme Court case was hallucinated.", "docket_number": "375687", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a submission with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2114/EAGLE_TOWNSHIP_v_SHAUN_VANALSTINE_USA_30_April_2026.pdf", "state": "MI", "summary": "The Michigan Court of Appeals on 2026-04-30 affirmed summary disposition for the township and noted the appellant’s cited Michigan Supreme Court case was hallucinated in Eagle Township v. Shaun VanAlstine. The self-represented party filed a submission with one fabricated case citation.", "text_sha256": "08d0e3d3ba3ccfce9a9ff2c01f86cfdc7a01b3dd1e142336baf512639c093bc5", "topics": [ "fabricated-citations" ], "tracker_slug": "eagle-township-v-shaun-vanalstine", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/michctapp-2026-eagle-township-v-shaun-vanalstine", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/michctapp-2026-eagle-township-v-shaun-vanalstine" }, { "ai_passage": "“[I]n exercising that discretion to impose sanctions for a pleading or paper’s lack of legal support, the court must apply an objective standard, inquiring whether ‘a reasonable attorney in like circumstances could not have believed his actions to be legally justified. ’” Lokhova, 30 F. 4th at 354 (quoting Hunter v. Earthgrains Co. Bakery, 281 F. 3d 144, 153 (4th Cir. 2022)). To be sanctionable, a legal argument 3 “Fake or nonexistent legal citations typically are the result of AI ‘hallucinations. ’” Mezu v. Mezu, 267 Md. App. 354, 368 (2025), reconsideration denied (Nov. 24, 2025), cert. dismissed, 493 Md. 184 (2026) (quoting Noland v. Land of the Free, L.", "ai_tool_named": null, "archive_url": null, "case_name": "Darrin L. Johnson, Jr. v. Nationstar Mortgage, LLC, et al.", "citation": null, "cited_authorities": [ "Hunter v. Earthgrains Co. Bakery, 281 F", "Mezu v. Mezu, 267 Md", "Noland v. Land of the Free" ], "court": "United States District Court for the District of Maryland", "court_code": "mdd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "mdd-2026-darrin-l-johnson-jr-v-nationstar-mortgage", "disposition": "The court ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "1:25-cv-00855-JRR", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a pleading with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2072/Johnson_v._Nationstar_USA_30_APril_2026.pdf", "state": "MD", "summary": "The District of Maryland on 2026-04-30 ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities in Darrin L. Johnson, Jr. v. Nationstar Mortgage, LLC, et al. The self-represented party filed a pleading with one fabricated case citation.", "text_sha256": "082d05ef44077176e04244963c2e124ae544f84e7baaf1129f2e5c16c66de889", "topics": [ "fabricated-citations" ], "tracker_slug": "johnson-v-nationstar", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdd-2026-darrin-l-johnson-jr-v-nationstar-mortgage", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdd-2026-darrin-l-johnson-jr-v-nationstar-mortgage" }, { "ai_passage": "R. Civ. P. 11(b) (emphasis added). Rule 11 applies to pro se plaintiffs, and filing documents containing citations to nonexistent cases or arguments wholly unsupported by the record violates Rule 11. In both his complaint and his opposition to defendants’ motions to dismiss, Rahman cites cases that do not exist. See, e. g. , [38] at 4 (citing a case supposedly called Swayne that does not exist at plaintiff’s citation), [38] at 51 (citing a case supposedly from the Seventh Circuit Court of Appeals called Kitchen, that does not exist at plaintiff’s citation). Case: 1:25-cv-08489 Document #: 51 Filed: 04/30/26 Page 4 of 15 PageID #:1179 Failure to comply with Rule 11 obligations in the future will result in sanctions, including dismissal of lawsuits, monetary sanctions, and a restriction on filing any new cases with the court. Rahman must not submit any filing to the court that contains false or misrepresented citations (cases that do not exist or cases that do not say what Rahman claims they say), and Rahman cannot repeat the results of computer-assisted research without personally certifying and verifying the truthfulness and accuracy of his briefs.", "ai_tool_named": null, "archive_url": null, "case_name": "Faisal Rahman v. Michael J. Burton, et al.", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "ilnd-2026-faisal-rahman-v-michael-j-burton", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "25 CV 8489", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed an opposition with two fabricated case citations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2066/Rahman_v._Burton_USA_30_April_2026.pdf", "state": "IL", "summary": "The Northern District of Illinois on 2026-04-30 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Faisal Rahman v. Michael J. Burton, et al. The self-represented plaintiff filed an opposition with two fabricated case citations.", "text_sha256": "3db7429060718325b97bea9ca8a72be27d222174f40b0dee946c1851576eea00", "topics": [ "fabricated-citations" ], "tracker_slug": "faisal-rahman-v-michael-j-burton-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-faisal-rahman-v-michael-j-burton", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-faisal-rahman-v-michael-j-burton" }, { "ai_passage": "Genuine Parts Co. , 463 F. Supp. 2d 928, 934 (E. D. Wis. 2006). These erroneous citations suggest that artificial intelligence was used to draft the complaint, producing the phenomenon known as “hallucinations,” i. e. , fabricated cases that do not exist. Unfortunately, this has become an unwelcome fixture in court filings across the country. The Court recognizes that artificial intelligence has the potential to expand access to the courts, but it also presents very serious dangers that are “fundamentally incompatible with our justice system” predicated on “integrity and honesty from parties. ” Mills v. City of St. Louis, No. 4:25- cv-1219-MTS, 2025 WL 3470293, at *1 (E. D.", "ai_tool_named": null, "archive_url": null, "case_name": "Burnside v. Verdick, et al.", "citation": null, "cited_authorities": [ "Mills v. City of St. Louis, No. 4:25- cv-1219-MTS, 2025 WL 3470293, at *1 (E", "Plaintiffs cited 'Jones v. County of Los Angeles, 802 Fed. App’x 282 (9th Cir. 2020)'", "Plaintiffs cited 'Thompson v. Hong, 2020 IL App (2d) 190551'", "Fay v. Fifty K Corporation, No. 2-19-0551, 2020 WL 2095845 (Ill. App. Ct. Apr. 29, 2020) (alt. 2020 IL App (", "Plaintiffs cited 'Wallace v. County of Los Angeles, 479 F. Supp. 3d 1088 (C.D. Cal. 2020)'", "Curtis v. Oliver, 479 F. Supp. 3d 1039, 1088 (D.N.M. 2020) instead, indicating mismatch/nonexisten", "Plaintiffs cited 'Estate of Smith v. Shulz, 2018 WL 2192187 (N.D. Iowa)'", "Cabrera v. N.Y. Fresh Meat Inc., 2018 WL 2192187 (S.D.N.Y. May 14, 2018), not a N.D. Iowa decision", "Plaintiffs cited 'Yates v. Mansfield, 2014 WL 11535036 (S.D. Iowa)'", "Plaintiffs cited 'Doe v. United States, 463 F. Supp. 2d 934 (N.D. Iowa 2006)'" ], "court": "United States District Court for the Southern District of Iowa", "court_code": "iasd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-30", "decision_id": "iasd-2026-burnside-v-verdick", "disposition": "The court ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "3:25-cv-00134-SMR-SBJ", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a pleading with six fabricated case citations, including Jones v. County of Los Angeles and Thompson v. Hong.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2061/Burnside_v._Verdick_USA_30_April_2026.pdf", "state": "IA", "summary": "The Southern District of Iowa on 2026-04-30 ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities in Burnside v. Verdick, et al. The self-represented party filed a pleading with six fabricated case citations, including Jones v. County of Los Angeles.", "text_sha256": "d316c1a68bc142f2d156b1ff8ba93bc62f79bb58c659797d5d697576453c6c76", "topics": [ "fabricated-citations" ], "tracker_slug": "burnside-v-verdick-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/iasd-2026-burnside-v-verdick", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/iasd-2026-burnside-v-verdick" }, { "ai_passage": "” 1st OSC at 2. While most attorneys provide such an explanation, which often involves an admission of reliance on artificial intelligence (“AI”) platforms, Lindsay’s brief sworn statement in response offers only airy generalities and conclusory statements. Her response contains no coherent explanation for how the two memoranda of law came to contain the fabricated citations. The most basic questions — most obviously: what was the source of the fabricated citations? — are never answered. Thus, Lindsay states merely that she “follow[s] a structured and diligent process designed to ensure accuracy, thoroughness, and compliance with all applicable legal and ethical standards. ” Aff.", "ai_tool_named": null, "archive_url": null, "case_name": "Sai Malena Jimenez-Fogarty v. Thomas Fogarty et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-29", "decision_id": "nysd-2026-sai-malena-jimenez-fogarty-v-thomas-fogarty", "disposition": "The court fined counsel $2,500 and ordered counsel to notify the client about the AI-related citation errors.", "docket_number": "1:24-cv-08705-JLR-GWG", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with seven fabricated case citations after using LexisNexis.", "currency": "USD", "monetary_penalty": 2500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2045/Fogarty_v._Fogarty_USA_29_April_2026.pdf", "state": "NY", "summary": "The Southern District of New York on 2026-04-29 fined counsel $2,500 and ordered counsel to notify the client about the AI-related citation errors in Sai Malena Jimenez-Fogarty v. Thomas Fogarty et al. Counsel filed a brief with seven fabricated case citations.", "text_sha256": "5a0ce14b154659a03dc7c57f61a16a38a880b338667c27ebb2d80260d7a9737b", "topics": [ "fabricated-citations" ], "tracker_slug": "sai-malena-jimenez-fogarty-v-thomas-fogarty-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-sai-malena-jimenez-fogarty-v-thomas-fogarty", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-sai-malena-jimenez-fogarty-v-thomas-fogarty" }, { "ai_passage": "(2) November 8, 2021 – Plaintiff asserts that, during her meeting with , he “stated her accommodations were being violated by ‘repeatedly giving her work with deadline demands,’” but told her that the accommodations were “‘guiding principles’to be followed only ‘tothe extent possible,’” and that she “needed to be ‘more flexible’ratherthan insisting on adherence to approved This “quote” and “citation” were one of a number of issues previously raised to Plaintiff’s counsel in this Court’s March 12, 2026 Letter Order. ECF 75. In light of the fabricated citation, this Court has sufficient cause, in its discretion, to decline to consider the proposition purportedly drawn from “Nita H. ,” for which Plaintiff cites no other case in either its cross-motion or its reply. However, the point is moot because, as discussed infra, even if this Court were to accept Plaintiff’s argument based on the fabricated citation, Plaintiff still has not adequately shown causation. Under the “intervening period” theory of causation, where “temporal proximity between protected activity and allegedly retaliatory conduct is missing, courts may look to the intervening period for other evidence of retaliatory animus.", "ai_tool_named": null, "archive_url": null, "case_name": "Jane Doe v. Baltimore City Board of School Commissioners", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Maryland", "court_code": "mdd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-29", "decision_id": "mdd-2026-jane-doe-v-baltimore-city-board-of-school-commissioners", "disposition": "The court granted defendants’ summary-judgment motion in part, denied plaintiff’s summary-judgment motion, and refused to rely on a fabricated case.", "docket_number": "1:23-cv-02899-SAG", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a reply brief with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2117/Doe_v_Baltimore_City_Board_of_School_USA_6_May_2026.pdf", "state": "MD", "summary": "The District of Maryland on 2026-04-29 granted defendants’ summary-judgment motion in part, denied plaintiff’s summary-judgment motion, and refused to rely on a fabricated case in Jane Doe v. Baltimore City Board of School Commissioners. Counsel filed a reply brief with one fabricated case citation.", "text_sha256": "42814bd6f19d5896a4d85ca21e9ca87a132a91009251d767793e9d7d13898ec3", "topics": [ "fabricated-citations" ], "tracker_slug": "jane-doe-v-baltimore-city-board-of-school-commissioners", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdd-2026-jane-doe-v-baltimore-city-board-of-school-commissioners", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdd-2026-jane-doe-v-baltimore-city-board-of-school-commissioners" }, { "ai_passage": "For example, the “Standard of Review” section does not contain a single citation. 4 We strike the portions of Appellant's brief as it pertains to this argument because the three cases cited as support do not exist. 5 While not binding on this Court, this case was acknowledged as persuasive support in the following cases: Doser v. Doser, 106 Md. App. 329, 346-47 (1995); Short, 136 Md. App. at 579; In re Timothy C. , 376 Md. at fn. 10. AMPARO TREJO v. MIGUEL ANGEL AMAYA... , Not Reported in Atl.... 6 As previously noted, this case does not exist.", "ai_tool_named": null, "archive_url": null, "case_name": "Amparo Trejo v. Miguel Angel Amaya Hernandez", "citation": "2026 WL 1162579", "cited_authorities": [ "Doser v. Doser, 106 Md", "AMPARO TREJO v. MIGUEL ANGEL AMAYA..." ], "court": "Appellate Court of Maryland", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-29", "decision_id": "mdapp-2026-amparo-trejo-v-miguel-angel-amaya-hernandez", "disposition": "The court struck the portions of the appellant’s brief that relied on three nonexistent nunc pro tunc cases.", "docket_number": "C-16- FM-24-008161 Reed, Zic, Harrell, Glenn T, Jr", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with three fabricated case citations.", "currency": null, "monetary_penalty": null, "outcome": "strike-off" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2056/AMPARO_TREJO_v_MIGUEL_ANGEL_AMAYA_HERNANDEZ_et_al_USa_27_April_2026.pdf", "state": "MD", "summary": "The Appellate Court of Maryland on 2026-04-29 struck the portions of the appellant’s brief that relied on three nonexistent nunc pro tunc cases in Amparo Trejo v. Miguel Angel Amaya Hernandez. Counsel filed a brief with three fabricated case citations.", "text_sha256": "b46211681ae73e87e72ef5e65b404366c4c3a0b9c4da5e581f607fc36edc4d46", "topics": [ "fabricated-citations" ], "tracker_slug": "amparo-trejo-v-miguel-angel-amaya-hernandez", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdapp-2026-amparo-trejo-v-miguel-angel-amaya-hernandez", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdapp-2026-amparo-trejo-v-miguel-angel-amaya-hernandez" }, { "ai_passage": "Second, the court will allow Plaintiff’s excessive force complaint against Defendants Byttner and Manker to move forward as he alleges that they unnecessarily kneed him and struck Defendants point out to the court that three cases cited and quoted by Plaintiff in support of this proposition are defective as the quotes used in Plaintiff’s brief are not present in the cited cases. (Doc. 39 at 6. ) The court has confirmed this contention. The court strongly suspects this is a product of the use of artificial intelligence, given that a Westlaw search for these precise quotes turned up no exact results. While the court declines to enter a show cause order at this time, Plaintiff’s counsel is strongly warned that the any further incorrect quotations could result in sanctions under Fed. R. Civ. P. 11 and D.", "ai_tool_named": null, "archive_url": null, "case_name": "Justin Spiehs v. Erik Smith", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11" ], "court": "United States District Court for the District of Kansas", "court_code": "ksd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-29", "decision_id": "ksd-2026-justin-spiehs-v-erik-smith", "disposition": "The court warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "5:25-cv-04067-JWB-BGS", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with one false case quotation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2060/Spiehs_v._Smith_USA_29_April_2026.pdf", "state": "KS", "summary": "The United States District Court for the District of Kansas on 2026-04-29 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Justin Spiehs v. Erik Smith. Counsel filed a brief with one false case quotation.", "text_sha256": "5cb0135a31992517beeea2a36c1c4fe69266133774aa07eeb7cf0ccad5cdb0b0", "topics": [ "fabricated-citations" ], "tracker_slug": "justin-spiehs-v-erik-smith", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ksd-2026-justin-spiehs-v-erik-smith", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ksd-2026-justin-spiehs-v-erik-smith" }, { "ai_passage": "903(2)(a) (8) (requiring for each issue “[a]n argument containing the appellant's contentions and the reasons for them with citations to the authorities relied on” and warning that “[f ]ailure to cite authority in support of an issue may be deemed waiver of that issue”). To the contrary, Gericke repeatedly cited two cases that do not exist. And she cited a third case that does exist but has nothing to do with the proposition for which she cites it or any issue in this case. It thus appears likely that she misused an artificial intelligence tool when preparing her brief. We recognize that Gericke is representing herself. “But we do not have a double standard for those represented by counsel and those who are unrepresented—we expect all to follow our procedures. ” Locher & Davis, PLC v. Ruth F.", "ai_tool_named": null, "archive_url": null, "case_name": "Nisland Asset Investment, LLC v. Carissa Ann Gericke", "citation": "2026 WL 1162553", "cited_authorities": [ "PLC v. Ruth F." ], "court": "Iowa Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-29", "decision_id": "iactapp-2026-nisland-asset-investment-v-carissa-ann-gericke", "disposition": "The court deemed issues waived where the appellant relied on nonexistent or irrelevant authorities instead of valid supporting law.", "docket_number": "25-0659", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented appellant filed a brief with two fabricated case citations and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2054/Nisland_v._Gericke_USA_29_April_2026.pdf", "state": "IA", "summary": "The Iowa Court of Appeals on 2026-04-29 deemed issues waived where the appellant relied on nonexistent or irrelevant authorities instead of valid supporting law in Nisland Asset Investment, LLC v. Carissa Ann Gericke. The self-represented appellant filed a brief with two fabricated case citations and one mischaracterized case citation.", "text_sha256": "bd525d9c9843df2c42ddd2f8ca296d0ef2e8abd93f44424adf65f06a6a38c1ae", "topics": [ "fabricated-citations" ], "tracker_slug": "nisland-asset-investment-llc-v-carissa-ann-gericke", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/iactapp-2026-nisland-asset-investment-v-carissa-ann-gericke", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/iactapp-2026-nisland-asset-investment-v-carissa-ann-gericke" }, { "ai_passage": "DISCUSSION As a preliminary matter, we address mother’s statement in her opening brief that she used “something…on [her] phone” to draft her brief. Given the context of mother’s statement, and the content and style of the brief itself, we infer that mother may be referring to a generative Artificial Intelligence (AI) system. We accept that generative AI is a powerful tool, but advise that using it comes with risks, including that it could provide incorrect information and/or “hallucinated” citations. It appears to us that a substantial portion of mother’s brief may be made up of direct output from an AI system. 8.", "ai_tool_named": null, "archive_url": null, "case_name": "In re W.B.", "citation": null, "cited_authorities": [], "court": "California Court of Appeal, Fifth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-29", "decision_id": "calctapp5-2026-in-re-w-b", "disposition": "The court warned the self-represented mother to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "JD145421-00", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented mother filed an opening brief with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2065/In_re_WB_USA_30_April_2026.pdf", "state": "CA", "summary": "The California Court of Appeal, Fifth District on 2026-04-29 warned the self-represented mother to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in In re W.B. The self-represented mother filed an opening brief with one fabricated case citation.", "text_sha256": "51c41b070913471bba184cc6de1cf0aae5f9fb09e3e53f460acf762c22999212", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-w-b", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp5-2026-in-re-w-b", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp5-2026-in-re-w-b" }, { "ai_passage": "see Cult Awareness Network, Inc. v. Martino (In re Cult Awareness Network, Inc. ), 151 F. 3d 605, 607 (7th Cir. 1998) (“Debtors, particularly Chapter 7 debtors, rarely have [] a pecuniary interest [in a bankruptcyorder]becausenomatterhowtheestate’sassetsaredisbursedby the trustee, no assets will revert to the debtor. ” (citing In re Schultz Mfg. Fabricating Co. , 956 F. 2d 686, 692 (7th Cir. 1992))). Our court has generally recognized two exceptions under which a Chapter 7 debtor may have bankruptcy standing: (1) if the debtor can “show[] that a successful appeal willmaketheestatesolvent,creatingasurplusforthedebtorunder11U. S. C. § 726(a)(6),” In re Foster, 644 F. App’x at 330; or (2) if the debtor can show that the challenged order affects the terms of the debtor’s bankruptcy discharge, In re Dean, 18 F.", "ai_tool_named": null, "archive_url": null, "case_name": "In the Matter of Ikechukwu H. Okorie", "citation": null, "cited_authorities": [ "Inc. v. Martino" ], "court": "United States Court of Appeals for the Fifth Circuit", "court_code": "ca5", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-29", "decision_id": "ca5-2026-in-matter-of-ikechukwu-h-okorie", "disposition": "The court affirmed the bankruptcy orders denying motions to void property sales and rejected arguments supported by nonexistent or inapposite authority.", "docket_number": "25-60490", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a submission with one fabricated case citation and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2068/Okorie_v._Wells_Fargo_USA_29_April_2026.pdf", "state": null, "summary": "The Fifth Circuit on 2026-04-29 affirmed the bankruptcy orders denying motions to void property sales and rejected arguments supported by nonexistent or inapposite authority in In the Matter of Ikechukwu H. Okorie. The self-represented party filed a submission with one fabricated case citation and one mischaracterized case citation.", "text_sha256": "422438cdb17341fe7f88c04c727424aeae76773913d65f19488cf5af8854d929", "topics": [ "fabricated-citations" ], "tracker_slug": "in-the-matter-of-ikechukwu-h-okorie", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca5-2026-in-matter-of-ikechukwu-h-okorie", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca5-2026-in-matter-of-ikechukwu-h-okorie" }, { "ai_passage": "38-1 at 17–18); see Lary v. Trinity Phys. Fin. & Ins. Services, 780 F. 3d 1101 (11th Cir. 2015). These hallucinations allow the Court to infer that Plaintiff prepared her filing with the use of generativeartificialintelligence(“AI”). Whiletheuseofsuch a tool is not necessarily problematic, the failure to confirm the accuracy of the filing is. Rule 11 requires either a party or an attorney to sign every pleading, motion, or other paper and provides that this signature constitutes a certificate that thesignerhasreadthedocumentandverifieditsaccuracy. See Fed. R. Civ. P. 11. Thisdutyincludesensuringthatallcitations are accurate as well as any quoted portions or descriptions of the referenced case. Plaintiff's pro se status does not relieve her of this requirement.", "ai_tool_named": null, "archive_url": null, "case_name": "Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al.", "citation": "2026 WL 1162306", "cited_authorities": [ "Lary v. Trinity Phys. Fin. & Ins. Services, 780 F", "Fed. R. Civ. P. 11", "Ellsworth v. Am. Arbitration Ass'n, 148 Ariz. 17, 19 (App. 1985), which the Court found does not exist", "Ellsworth v. Am. Arb. Ass'n, 148 P.3d 983 (Utah 2006) (arbitration issue)", "Aguilar v. ASARCO", "Lary v. Trinity Phys. Fin. & Ins. Services" ], "court": "United States District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-29", "decision_id": "azd-2026-bathsheba-nichole-adams-v-kiewit-infrastructure-west", "disposition": "The court struck the defective motion and warned the self-represented plaintiff that future fabricated citations may result in sanctions.", "docket_number": "CV-25-01823-PHX-DJH", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a pleading with two fabricated case citations, including Ellsworth v. Am. Arbitration Ass'n and Ellsworth v. Am. Arb. Ass'n.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2055/Bathsheba_Nichole_Adams_v_Kiewit_Infrastructure_West_Company_USA_29_April_2026.pdf", "state": "AZ", "summary": "The District of Arizona on 2026-04-29 struck the defective motion and warned the self-represented plaintiff that future fabricated citations may result in sanctions in Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al. The self-represented plaintiff filed a pleading with two fabricated case citations, including Ellsworth v. Am. Arbitration Ass'n.", "text_sha256": "dcf29c1c7a3b7f47fdc783354e9ee404e5d7d6a9ce365cd1ef0a0bed4b4763d6", "topics": [ "fabricated-citations" ], "tracker_slug": "bathsheba-nichole-adams-v-kiewit-infrastructure-west-company-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azd-2026-bathsheba-nichole-adams-v-kiewit-infrastructure-west", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-bathsheba-nichole-adams-v-kiewit-infrastructure-west" }, { "ai_passage": "Brooks Farms, LLC, 624 S. W. 3d 601 (Tenn. Ct. App. 2020). ” (See Doc. 31, at 3 n. 1; Doc. 35, at 4. ) Plaintiffs have filed a notice of errata acknowledging some of these errors. (Doc. 36. ) The Court does not find it necessary to address sanctions at this time, but Plaintiffs are reminded that Federal Rule of Civil Procedure 11 applies to pro se litigants and that citation to non-existent authority undermines the credibility of otherwise legitimate arguments. The Court encourages Plaintiffs, should they seek legal counsel in any future proceedings, to ensure that any legal citations are carefully verified. PageID #: 330", "ai_tool_named": null, "archive_url": null, "case_name": "Pate v. CMG Mortgage, Inc., et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Eastern District of Tennessee", "court_code": "tned", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-28", "decision_id": "tned-2026-pate-v-cmg-mortgage", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:25-cv-00349-TRM-MJD", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a submission with two fabricated case citations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2043/Pete_v._CMG_Mortgage_USA_28_April_2026.pdf", "state": "TN", "summary": "The Eastern District of Tennessee on 2026-04-28 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Pate v. CMG Mortgage, Inc., et al. The self-represented plaintiff filed a submission with two fabricated case citations.", "text_sha256": "7150c9b0752737cc557ab86a241a6cbde06ff2f1eaf59c3d7fc8f6e1bfaf098a", "topics": [ "fabricated-citations" ], "tracker_slug": "pate-v-cmg-mortgage-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/tned-2026-pate-v-cmg-mortgage", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tned-2026-pate-v-cmg-mortgage" }, { "ai_passage": "Scharf, No. 3:25cv1015, 2026 WL 642917, at *2 (W. D. N. C. Feb. 25, 2026); see also id. (“Even a cursory Google search would [have] reveal[ed] that these cases do not exist [as cited]. ”). More pointedly, Plaintiff’s submissions foreground an issue that “[c]ourts across the country are grappling with,” In re Nwaubani, No. 25-9517, 2026 WL 687194, at *3 (4th Cir. Mar. 11, 2026), in that citations such as Plaintiff’s to “nonexistent cases . . . are the frequent posterchild” for “the use of generative [artificial intelligence] in materials submitted to the court,” id.; see also Kruglyak v. Home Depot U.", "ai_tool_named": null, "archive_url": null, "case_name": "Brandon Rulund Akins v. Tashi Latwon Ratliff, et al.", "citation": null, "cited_authorities": [ "Kruglyak v. Home Depot U." ], "court": "United States District Court for the Middle District of North Carolina", "court_code": "ncmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-28", "decision_id": "ncmd-2026-brandon-rulund-akins-v-tashi-latwon-ratliff", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:25-cv-00712-DAB-LPA", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a submission with nine fabricated case citations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2040/Akins_v._Ratliff_USA_28_April_2026.pdf", "state": "NC", "summary": "The Middle District of North Carolina on 2026-04-28 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Brandon Rulund Akins v. Tashi Latwon Ratliff, et al. The self-represented plaintiff filed a submission with nine fabricated case citations.", "text_sha256": "e2e7da851155c83c8157baf4bd3269f3f51fea7dadfd397b5e6739f521ca80ac", "topics": [ "fabricated-citations" ], "tracker_slug": "brandon-rulund-akins-v-tashi-latwon-ratliff-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ncmd-2026-brandon-rulund-akins-v-tashi-latwon-ratliff", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ncmd-2026-brandon-rulund-akins-v-tashi-latwon-ratliff" }, { "ai_passage": "Kumar Magistrate Judge Curtis Ivy, Jr. ORDER TO SHOW CAUSE Counsel for plaintiff, Ronnie E. Cromer, Jr. (“Cromer”) filed a response brief containing multiple citations that were entirely fictitious, had different citations, and/or did not contain the quote or content attributed to them. See ECF No. 50. Cromer admitted at a hearing before the Court on March 12, 2025, that he used a generative artificial intelligence engine (AI) to draft that brief, that AI supplied the bogus case law cited, and that he did not review or cite check that case law before filing his brief. Due to Cromer’s negligent conduct in this case, the Court ordered him to attend the ethics seminar offered by the State Bar of Michigan on April 8, 2025, Case 4:21-cv-12589-SDK-CI ECF No. 73, PageID.", "ai_tool_named": null, "archive_url": null, "case_name": "Loyer v. Wayne County Michigan et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-28", "decision_id": "mied-2026-loyer-v-wayne-county-michigan", "disposition": "The court ordered counsel to attend an ethics seminar and file proof of attendance after finding AI-supplied bogus case law.", "docket_number": "21-12589 Honorable Shalina D. Kumar Magistrate", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2936/Loyer_v._Michan_USA_28_APril_2026.pdf", "state": "MI", "summary": "The Eastern District of Michigan on 2026-04-28 ordered counsel to attend an ethics seminar and file proof of attendance after finding AI-supplied bogus case law in Loyer v. Wayne County Michigan et al. Counsel filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation.", "text_sha256": "2418db262229927c843834ff15034777b2cf4ff1ffa94de4f16f3432cd22439e", "topics": [ "fabricated-citations" ], "tracker_slug": "loyer-v-wayne-county-michigan-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-loyer-v-wayne-county-michigan", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-loyer-v-wayne-county-michigan" }, { "ai_passage": "(FAC ¶ 8. ) Plaintiff received a verification code on May 8 for additional vetting. (FAC ¶ 9. ) On May 9, he created six political ads for his Defendant argues in its reply that Plaintiff’s response should be given little weight because he improperly used artificial intelligence (“AI”) to draft his filing, leading to many misstatements of law. (Def. ’s Reply 2, Dkt. 54. ) The court agrees that the vast majority of Plaintiff’s case citations are cited for legal propositions that the cases themselves do not support, and this impacts how the court weighs his arguments—however, the court declines to independently factor in Plaintiff’s use of AI software when weighing his response, as it does not contain any hallucinated or fabricated citations and there is no need to separately account for his use of AI in considering his arguments. Plaintiff is cautioned, however, that it is his responsibility to ensure that any filings drafted with AI assistance are properly reviewed for accuracy before they are submitted to this court.", "ai_tool_named": null, "archive_url": null, "case_name": "Louis L. Ligon III v. Meta Platforms, Inc.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-28", "decision_id": "cand-2026-louis-l-ligon-iii-v-meta-platforms", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "25-cv-03959-RMI", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a reply brief with one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2081/Ligon_III_v._Meta_USA_28_April_2026.pdf", "state": "CA", "summary": "The Northern District of California on 2026-04-28 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Louis L. Ligon III v. Meta Platforms, Inc. The self-represented plaintiff filed a reply brief with one mischaracterized case citation.", "text_sha256": "ee9be4dfa3cf821ebb31af69d93cf62663483d07d17dbd6fce75abf580b64ccd", "topics": [ "fabricated-citations" ], "tracker_slug": "louis-l-ligon-iii-v-meta-platforms-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cand-2026-louis-l-ligon-iii-v-meta-platforms", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-louis-l-ligon-iii-v-meta-platforms" }, { "ai_passage": "Long before the public launch of various AI or large language models such as ChatGPT, the Fifth Circuit affirmed an award of sanctions by noting that “[f]iling mountainous piles of unorganized documents and citing to nonexistent rules of law are precisely the sort of conduct that, under the objective test of Rule 11, could lead a district court to conclude that the attorney had not made reasonable inquiry into the law or was seeking to harass or delay. ” Willy, 855 F. 2d at 1172. Sanctioning a party for citing to nonexistent law is, unfortunately, not merely a product of AIhallucinated citations. See, e. g. , Dobson v. U.", "ai_tool_named": "CoCounsel", "archive_url": null, "case_name": "Anthony C. Hill v. Workday, Inc.", "citation": null, "cited_authorities": [ "Dobson v. U.", "Fed. R. Civ. P. 11" ], "court": "United States District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-28", "decision_id": "cand-2026-anthony-c-hill-v-workday", "disposition": "The court admonished counsel, fined counsel $1,001, required four hours of live CLE, and ordered circulation of the sanction order.", "docket_number": "3:23-cv-06558-PHK", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": "CoCounsel", "conduct": "Counsel filed a submission with one fabricated case citation and one mischaracterized case citation after using CoCounsel.", "currency": "USD", "monetary_penalty": 1001, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2039/Hill_v._Workday_USA_28_April_2026.pdf", "state": "CA", "summary": "The Northern District of California on 2026-04-28 admonished counsel, fined counsel $1,001, required four hours of live CLE, and ordered circulation of the sanction order in Anthony C. Hill v. Workday, Inc. Counsel filed a submission with one fabricated case citation and one mischaracterized case citation.", "text_sha256": "6c54c6093e768296591840664a2625cb752ecc08f7c53cb5f40a612c6ab6295b", "topics": [ "fabricated-citations" ], "tracker_slug": "anthony-c-hill-v-workday-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cand-2026-anthony-c-hill-v-workday", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-anthony-c-hill-v-workday" }, { "ai_passage": "2d 1391, 1393 (1980) (quoting Roadway Express, 447 U. S. at 767). Two overarching factors drive the Court’s sanctions order. First, the imposition of sanctions for submitting generative-AI hallucinations is so well-documented at this point that the Court finds the failure to verify citations after using generative-AI rises to the level of bad faith. According to one source, in the United States alone, there have been 915 legal opinions addressing the improper use of generative-AI in the last three years. See Damien Carlotin, AI Hallucination Cases, https://www. damiencharlotin. com/hallucinations/ (last visited Apr. 26, 2026). Courts in this District have begun ordering heavy sanctions against attorneys caught using fabricated cases generated by AI.", "ai_tool_named": "LexisNexis+ (Protégé)", "archive_url": null, "case_name": "Tekoma Chaney v. Transdev Services Inc. et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-28", "decision_id": "cacd-2026-tekoma-chaney-v-transdev-services", "disposition": "The court fined counsel $2,500 and required reporting the sanction order to other courts where counsel had appeared.", "docket_number": "2:24-cv-10761-ODW-AJR", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": "LexisNexis+ (Protégé)", "conduct": "Counsel filed a submission with three fabricated case citations, including In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015) after using LexisNexis+ (Protégé).", "currency": "USD", "monetary_penalty": 2500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2041/Chaney_v._Transdev_Services_USA_28_April_2026.pdf", "state": "CA", "summary": "The Central District of California on 2026-04-28 fined counsel $2,500 and required reporting the sanction order to other courts where counsel had appeared in Tekoma Chaney v. Transdev Services Inc. et al. Counsel filed a submission with three fabricated case citations, including In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015).", "text_sha256": "9678cabb0520ae74734f87a1c8ee3ffc4f4c20ad48f47259d82eb8bf94c53119", "topics": [ "fabricated-citations" ], "tracker_slug": "tekoma-chaney-v-transdev-services-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-tekoma-chaney-v-transdev-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-tekoma-chaney-v-transdev-services" }, { "ai_passage": "3d 1432, 1433-34 (11th Cir. 1997), and attributes to it the following quotation: “‘Resign or be fired’ scenarios are classic jury questions. ” (Doc. # 48 at 15-16). The court’s own review of Thomas reveals that no such language appears anywhere in that opinion. The court declines to speculate as to how this misattribution occurred, but counsel is cautioned that submitting fabricated quotations to the court implicates her obligations under Federal Rule of Civil Procedure 11 and that such conduct will not be tolerated in future filings. See, e. g. , Johnson v. Dunn, 792 F. Supp. 3d 1241 (N. D.", "ai_tool_named": null, "archive_url": null, "case_name": "Tunstall v. Alabama Department of Corrections", "citation": null, "cited_authorities": [ "Johnson v. Dunn, 792 F", "Thomas v. Dillard" ], "court": "United States District Court for the Northern District of Alabama", "court_code": "alnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-28", "decision_id": "alnd-2026-tunstall-v-alabama-department-of-corrections", "disposition": "The court admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct.", "docket_number": "2:24-cv-01504-RDP", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a submission with one false case quotation, including Thomas v. Dillard.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2067/Tuntstall_v._Alabama_DOC_USA_28_April_2026.pdf", "state": "AL", "summary": "The Northern District of Alabama on 2026-04-28 admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct in Tunstall v. Alabama Department of Corrections. Counsel filed a submission with one false case quotation, including Thomas v. Dillard.", "text_sha256": "f50b17210bfffa59b5fd020297e99d013066a6bfdd33ac7c79717a200ca0eb81", "topics": [ "fabricated-citations" ], "tracker_slug": "tunstall-v-alabama-department-of-corrections", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/alnd-2026-tunstall-v-alabama-department-of-corrections", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alnd-2026-tunstall-v-alabama-department-of-corrections" }, { "ai_passage": "14, 2020). private cause of action; that claim is dismissed, with prejudice, because amendment would be futile. Moore has one final opportunity to amend and must do so no later than May 15, 2026. 8 SIGNED on April 27, 2026, at Houston, Texas. ________________________________ Lee H. Rosenthal Senior United States District Judge Wireless also asserts that Moore’s pleadings indicate the use of generative AI and point out cases she cites that do not exist. (Docket Entry No. 10 at 20). The court has checked those citations (see, e. g. , Docket Entry No. 7 at 2 (citing “Thomas v. City of San Marcos (W. D.", "ai_tool_named": null, "archive_url": null, "case_name": "Moore v. Wireless CCTV LLC", "citation": null, "cited_authorities": [ "Thomas v. City of San Marcos", "Pleading cited 'Thomas v. City of San Marcos", "Pleading cited 'Cole v. Sandler, 2014 WL 266501 (E.D. La.)'", "Cole v. Hunter" ], "court": "United States District Court for the Southern District of Texas", "court_code": "txsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-27", "decision_id": "txsd-2026-moore-v-wireless-cctv", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "4:25-cv-05476", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a pleading with two fabricated case citations, including Thomas v. City of San Marcos and Cole v. Sandler.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2071/Moore_v._Wireless_USA_27_April_2026.pdf", "state": "TX", "summary": "The Southern District of Texas on 2026-04-27 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Moore v. Wireless CCTV LLC. The self-represented party filed a pleading with two fabricated case citations, including Thomas v. City of San Marcos.", "text_sha256": "41d522006133625d4e3e7b7d00c396e16f16ecfcb65395858169df05bd7b860b", "topics": [ "fabricated-citations" ], "tracker_slug": "moore-v-wireless-cctv-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txsd-2026-moore-v-wireless-cctv", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txsd-2026-moore-v-wireless-cctv" }, { "ai_passage": "See Kay v. Ehrler, 499 U. S. 432, 438 (1991). In this variety of hallucination, the Almodel appears to have provided the plaintiff with a legal doctrine that he wanted to exist without it actually existing. also filed an accompanying Al-aided motion for a temporary restraining order (“TRO”) along with an Al-aided brief in support. 2 Per the motion, Marble “is currently subject to criminal prosecution predicated on alleged criminal trespass and/or burglary. ” (Doc. 3 at 1). The motion references Marble’s ostensible preliminary hearing testimony, presented as an “Excerpt of an Official Court Transcript,” where plaintiff’s former landlord testified that he evicted the plaintiff and that plaintiff kept returning to the properties. 3 (Doc.", "ai_tool_named": null, "archive_url": null, "case_name": "Marble v. O'Malley", "citation": null, "cited_authorities": [ "See Kay v. Ehrler, 499 U", "Plaintiff's TRO brief attributes a holding to Manuel v. City of Joliet that it references Younger doctrine" ], "court": "United States District Court for the Middle District of Pennsylvania", "court_code": "pamd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-27", "decision_id": "pamd-2026-marble-v-o-malley", "disposition": "The court admonished the self-represented plaintiff for unverified or fabricated authorities and cautioned against repeating the citation misconduct.", "docket_number": "3:26-cv-00040-JKM", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a brief with one fabricated case citation, one fabricated or AI-like submission item, and one invented legal doctrine.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2070/Marble_v._OMalley_USA_27_April_2026.pdf", "state": "PA", "summary": "The Middle District of Pennsylvania on 2026-04-27 admonished the self-represented plaintiff for unverified or fabricated authorities and cautioned against repeating the citation misconduct. The self-represented plaintiff filed a brief with one fabricated case citation, one fabricated or AI-like submission item, and one invented legal doctrine, including TRO brief attributes a holding to Manuel v. City of Joliet that it….", "text_sha256": "9fb89ba7044c4dd56c10005d323e9afadb35e0aa3f4afbb2d999305e962c1745", "topics": [ "fabricated-citations" ], "tracker_slug": "marble-v-omalley", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pamd-2026-marble-v-o-malley", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pamd-2026-marble-v-o-malley" }, { "ai_passage": "This Court notes that upon review of the petition, petitioner's citations were either for New York cases that were general election law matters and inapplicable to the facts in this case, or to nonexistent case law. Respondent's argument that the case law petitioner presented was AI hallucinations and fabricated has some merit, but since respondent did not seek sanctions, there is no reason for this Court to render a ruling on this argument. Finally,petitionerarguesrespondent,anincumbentAssembly Member, should be fully familiar with the election law and should have checked to see if his party affiliation had been changed prior to filing the certificate of authorization. He further argues challenging candidates, such as himself, are routinely removed from the electoral process due to ministerial errors that render petitions facially deficient.", "ai_tool_named": null, "archive_url": null, "case_name": "In the Matter of the Application of Jonathan David Rinaldi", "citation": "2026 WL 1279715", "cited_authorities": [], "court": "Supreme Court of the State of New York", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-27", "decision_id": "nysupct-2026-in-matter-of-application-of-jonathan-david-rinaldi", "disposition": "The court granted the motion to dismiss the election petition and noted that sanctions were unavailable because the respondent did not request them.", "docket_number": "711266/2026", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a submission with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2144/Rinaldi_v._Evesi_USA_27_April_2026.pdf", "state": "NY", "summary": "The New York Supreme Court on 2026-04-27 granted the motion to dismiss the election petition and noted that sanctions were unavailable because the respondent did not request them in In the Matter of the Application of Jonathan David Rinaldi. The self-represented party filed a submission with one fabricated case citation.", "text_sha256": "bbbef92bdbba7488c55d725e96fc7ee1073709ed4fecc83cd9ef2859a3ea7aa2", "topics": [ "fabricated-citations" ], "tracker_slug": "in-the-matter-of-the-application-of-jonathan-david-rinaldi", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-in-matter-of-application-of-jonathan-david-rinaldi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-in-matter-of-application-of-jonathan-david-rinaldi" }, { "ai_passage": "and • a 179-page \"Memorandum of Law in Opposition to Defendant's Motion to Dismiss and in Support of Emergency Relief, Mandamus, and Judicial Enforcement. \" (Dkt. 40 at 3. ) As discussed in more detail below, portions of plaintiff's papers appear to constitute the unedited output of a generative artificial intelligence (AI) tool. Plaintiff's Motions to Vacate and Strike are Denied Plaintiff's letter-motion to vacate the March 24, 2026 deadline for the Commissioner to file the CAR (Dkt. 19) is DENIED AS MOOT in light of the filing of the Commissioner's Rule 12(b)(1) motion on March 9, 2026. See Supp. Soc.", "ai_tool_named": null, "archive_url": null, "case_name": "Rhonda L. H.-B. v. Commissioner of Social Security", "citation": null, "cited_authorities": [], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-27", "decision_id": "nysd-2026-rhonda-l-h-b-v-commissioner-of-social-security", "disposition": "The court allowed refiling but warned the self-represented plaintiff after AI-like placeholders and repeated nonsensical text appeared.", "docket_number": "1:26-cv-00425-PAE-BCM", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed an opposition with two fabricated or AI-like submission items.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2076/Rhonda_v._CSS_USA_27_April_2026.pdf", "state": "NY", "summary": "The Southern District of New York on 2026-04-27 allowed refiling but warned the self-represented plaintiff after AI-like placeholders and repeated nonsensical text appeared in Rhonda L. H.-B. v. Commissioner of Social Security. The self-represented plaintiff filed an opposition with two fabricated or AI-like submission items.", "text_sha256": "6bc19a7e509329b53b38efc0d863dd67e2f13cdbca5bdd2d2d29a1ac58e63f2a", "topics": [ "fabricated-citations" ], "tracker_slug": "rhonda-l-h-b-v-commissioner-of-social-security", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-rhonda-l-h-b-v-commissioner-of-social-security", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-rhonda-l-h-b-v-commissioner-of-social-security" }, { "ai_passage": "53–55, 56–58) comprising over 40 pages of coherent legal analysis all on April 10, 2026, the day after the Court’s prior order, ECF No. 52. The latest flurry worsens a pattern of repeated filings: the Court’s previous order denied four of Plaintiffs’ motions that were filed within the space of a few weeks. ECF No. 52. The likeliest explanation is that Plaintiffs are using an artificial intelligence (AI) tool. This inference is further corroborated by numerous hallucinated cases and citations: for example, in ECF No. 59 at 8, Plaintiffs’ quote a previous case of this Court (“United States v. $17,900 in U. S. Currency”) that does not appear to exist. Although the use of AI tools for legal research or drafting is not inherently improper, Plaintiffs’ avalanche of filings here, whether AI-generated or not, have burdened the Court, advanced frivolous arguments, misstated the record, and fabricated legal authorities.", "ai_tool_named": null, "archive_url": null, "case_name": "Ali Behroz Aziz, et al. v. United States of America, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Maryland", "court_code": "mdd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-27", "decision_id": "mdd-2026-ali-behroz-aziz-v-united-states-of-america", "disposition": "The court imposed page limits and warned the self-represented plaintiffs after identifying a nonexistent forfeiture case citation.", "docket_number": "1:26-cv-00243-ABA", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a motion with one fabricated case citation, including United States v. $17,900 in U.S. Currency.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2044/Aziz_v._USA_USA_27_April_2026.pdf", "state": "MD", "summary": "The District of Maryland on 2026-04-27 imposed page limits and warned the self-represented plaintiffs after identifying a nonexistent forfeiture case citation in Ali Behroz Aziz, et al. v. United States of America, et al. The self-represented plaintiff filed a motion with one fabricated case citation, including United States v. $17,900 in U.S. Currency.", "text_sha256": "b4944dda60f0a2f8ee3909728c7e45ed661879430af48411720e3b63c37e2e96", "topics": [ "fabricated-citations" ], "tracker_slug": "ali-behroz-aziz-et-al-v-united-states-of-america-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdd-2026-ali-behroz-aziz-v-united-states-of-america", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdd-2026-ali-behroz-aziz-v-united-states-of-america" }, { "ai_passage": "BMakin Film Ltd, 2026 WL 1164759 (2026) sanctions or both shall be entered as a judgment of the court. In no event shall the amount of sanctions imposed exceed $10,000 for any single occurrence of frivolous conduct. ” *3 Submissions that rely on non-existent cases generated by artificial intelligence, resulting in AI “hallucinations” and cases that do not stand for the propositions alleged, are considered “frivolous conduct” under 22 NYCRR § 130-1. 1 and are sanctionable. See Will of Samuel, 82 Misc 3d 616, 621 (Sur Ct 2024). A party's pro se status does not excuse such conduct. **5 It is clear and undisputed that Makinen used Artificial Intelligence to create the documents relied upon in his motions.", "ai_tool_named": null, "archive_url": null, "case_name": "Keefe v. BMakin Film Ltd", "citation": "2026 N.Y. Slip Op. 31794(U)", "cited_authorities": [ "Cited 'Klapper v. Graziano, 41 Misc 3d 401, 410 (Sup Ct 2013)' and attributed the statement that releases 'a", "Cited 'Clark v. Velsiplast Corp., 88 A.D.2d 859 (1st Dep't 1982)' and quoted from it, but the citation is incorrec", "Cited 'Shah v. Levy, 56 A.D.3d 574 (2d Dep't 2008)' for a proposition unrelated to that action" ], "court": "Supreme Court of the State of New York", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-24", "decision_id": "nysupct-2026-keefe-v-bmakin-film", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "525621/2025. April 24, 2026", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a motion with one fabricated case citation, two false case quotations, and one mischaracterized case citation, including Klapper v. Graziano and Clark v. Velsiplast Corp.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2326/2_-_Keefe_v_BMakin_Film_Ltd.pdf", "state": "NY", "summary": "The New York Supreme Court on 2026-04-24 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Keefe v. BMakin Film Ltd. The self-represented party filed a motion with one fabricated case citation, two false case quotations, and one mischaracterized case citation, including Klapper v. Graziano.", "text_sha256": "4783df36eff92f2f4dc1b200cb06f1f0069b4c501554a1fa7ea68337ad08d462", "topics": [ "fabricated-citations" ], "tracker_slug": "keefe-v-bmakin-film-ltd", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-keefe-v-bmakin-film", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-keefe-v-bmakin-film" }, { "ai_passage": "2023). Before concluding, we note that Marquez’s deceptive briefing practices deserve special mention and admonition. After an exhaustive reviewofMarquez’sbrief,weconcludethatsomeofthecasesMarquezcites do not exist and nearly every quotation from the caselaw that he cites from existing caselaw is either misquoted or fabricated. Further, most of the legal propositions that Marquez posits are supported by our caselaw are either inappositetothecaseshecitesor,worse,contradictedbyourcaselaw. While we afford pro se plaintiffs some leeway, we will not ignore Marquez’s use of non-existentcaselawandfabricatedquotations,whichfloutstherequirement in Federal Rule of Appellate Procedure 28(a)(8)(A) that all briefs contain arguments supported by cited authority. SeeFed.", "ai_tool_named": null, "archive_url": null, "case_name": "United States v. Jose Marquez", "citation": null, "cited_authorities": [], "court": "United States Court of Appeals for the Fifth Circuit", "court_code": "ca5", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-24", "decision_id": "ca5-2026-united-states-v-jose-marquez", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "25-50866 Summary Calendar", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2077/USA_v._MArquez_USA_24_April_2026.pdf", "state": null, "summary": "The Fifth Circuit on 2026-04-24 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in United States v. Jose Marquez. The self-represented plaintiff filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation.", "text_sha256": "c0e77bf3607be06b1f7c64167135fb04325df5645071ebf916e01d863f36a732", "topics": [ "fabricated-citations" ], "tracker_slug": "united-states-v-jose-marquez", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca5-2026-united-states-v-jose-marquez", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca5-2026-united-states-v-jose-marquez" }, { "ai_passage": "S. 213 (1983): “The mere assertion of a complaint ... without corroboration or personal knowledge of a crime, fails to establish probable cause. ” Aplt. Opening Br. at 21 (alteration in original) (internal quotation marks omitted). But we cannot find this quote (or any similar proposition) in Spinelli. Nor does the quotation appear in any other federal or state case. We therefore suspect that Mr. Jarvis's quotation is a fabrication generated by his use of a generative artificial intelligence (AI) tool. Cf. Wadsworth v. Walmart Inc. , 348 F. R. D. 489, 497 (D. Wyo. 2025) (“It is ... well-known in the legal community that AI resources generate fake cases. ”).", "ai_tool_named": null, "archive_url": null, "case_name": "Ryan-Michael Jarvis v. County of Teton Wyoming", "citation": "2026 WL 1122106", "cited_authorities": [ "Cf. Wadsworth v. Walmart Inc. , 348 F", "Appellant attributed a quotation to Spinelli v. United States that does not appear in the opinion", "Appellant cited Meechaicum v. Fountain for a holding about Eighth Amendment claims that the cour" ], "court": "United States Court of Appeals for the Tenth Circuit", "court_code": "ca10", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-24", "decision_id": "ca10-2026-ryan-michael-jarvis-v-county-of-teton-wyoming", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "25-8034", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a pleading with one false case quotation and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2051/Jarvis_v._County_USA_24_April_2026.pdf", "state": null, "summary": "The Tenth Circuit on 2026-04-24 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Ryan-Michael Jarvis v. County of Teton Wyoming. The self-represented party filed a pleading with one false case quotation and one mischaracterized case citation, including Spinelli v. United States that does not appear in the opinion.", "text_sha256": "8381321f97f2d0a3f28a7d450c7d821996edfafae99968ca9fef62e1c5a6dc00", "topics": [ "fabricated-citations" ], "tracker_slug": "ryan-michael-jarvis-v-county-of-teton-wyoming", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca10-2026-ryan-michael-jarvis-v-county-of-teton-wyoming", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca10-2026-ryan-michael-jarvis-v-county-of-teton-wyoming" }, { "ai_passage": ", concurring) (\"offer[ing] … preliminary thoughts about whether and how [AI-powered large language models] might aid lawyers and judges in the interpretive enterprise\"). Rather, the problem of fake citations in court filings is the result of attorneys failing to properly research and verify the results of AI-generated citations -- in short, attorney negligence in checking his or her work. And such failures often lead to problems like those in this case. In a recent case from the Northern District of Alabama, Judge Manasco set forth a few of the many harms that flow from the submission of fake legal authorities. As stated in Johnson v.", "ai_tool_named": null, "archive_url": null, "case_name": "Laurie Ibach and Mark Stewart v. Bruce Stewart", "citation": null, "cited_authorities": [ "Quoted Janowiak v. Tiesi as supporting a proposition" ], "court": "Supreme Court of Alabama", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-24", "decision_id": "ala-2026-laurie-ibach-and-mark-stewart-v-bruce-stewart", "disposition": "The court doubled appellate costs, awarded $17,200, prohibited further filings without counsel, and referred counsel to the Alabama State Bar.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a submission with five fabricated case citations and three false case quotations, including Quoted Janowiak v. Tiesi as supporting a proposition.", "currency": "USD", "monetary_penalty": 17200, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2035/Ibach__Stewart_v._Steward_USA_24_April_2026.pdf", "state": "AL", "summary": "The Supreme Court of Alabama on 2026-04-24 doubled appellate costs, awarded $17,200, prohibited further filings without counsel, and referred counsel to the Alabama State Bar in Laurie Ibach and Mark Stewart v. Bruce Stewart. Counsel filed a submission with five fabricated case citations and three false case quotations, including Quoted Janowiak v. Tiesi as supporting a proposition.", "text_sha256": "12e02c057e43bbe7ce2da04e36d94995f5d23360a8dde19733e9f4150958b038", "topics": [ "fabricated-citations" ], "tracker_slug": "ibach-v-stewart", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ala-2026-laurie-ibach-and-mark-stewart-v-bruce-stewart", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ala-2026-laurie-ibach-and-mark-stewart-v-bruce-stewart" }, { "ai_passage": "She does not specify in her brief what amendment she refused to accept. She cites cases that she purports support the proposition that any amendments to the Contract had to be in writing. However, Crawford's cited cases are either “hallucinated” cases or do not support the proposition that the mere proposal of an amendment nullified the Contract. 5 Regardless of what amendment Crawford disputes, Buffalo Creek sought specific performance of the original Contract, and the court awarded that relief. There is no showing that the court ordered specific performance of any amendment Buffalo Creek proposed. The Contract called for any liens or binding agreements to be “satisfied out of the sales price. ” The court “reformed” the Contract to adjust Buffalo Creek's payment due for the expenses of effectuating the Contract such as courts costs, attorney's fees, property-tax payments, and payment to the life-estate holder.", "ai_tool_named": null, "archive_url": null, "case_name": "Joann Crawford v. Buffalo Creek Properties, LLC", "citation": "2026 WL 1097101", "cited_authorities": [ "Appellant referenced 'Hercenberger v. Proctor' without a reporter citation" ], "court": "Texas Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-23", "decision_id": "texapp-2026-joann-crawford-v-buffalo-creek-properties", "disposition": "The court affirmed the judgment for Buffalo Creek after finding no reversible error and noting unsupported or nonexistent authorities in the brief.", "docket_number": "03-24-00260-CV", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a brief with two fabricated case citations and one invented legal doctrine, including Hercenberger v. Proctor' without a reporter citation and Hercenberger v. Proctor.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2027/Joann_Crawford_Appellant_v_Buffalo_Creek_Properties_LLC_Appellee.pdf", "state": "TX", "summary": "The Texas Court of Appeals on 2026-04-23 affirmed the judgment for Buffalo Creek after finding no reversible error and noting unsupported or nonexistent authorities in the brief in Joann Crawford v. Buffalo Creek Properties, LLC. The self-represented party filed a brief with two fabricated case citations and one invented legal doctrine, including Hercenberger v. Proctor' without a reporter citation.", "text_sha256": "4e846d22b7bf8eb83c2703de515e9738461f1983fa350b5ffaaa596c83837450", "topics": [ "fabricated-citations" ], "tracker_slug": "joann-crawford-v-buffalo-creek-properties-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp-2026-joann-crawford-v-buffalo-creek-properties", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp-2026-joann-crawford-v-buffalo-creek-properties" }, { "ai_passage": "IN RE PAULA M. MILLER, Relator NO. 01-26-00319-CV | Opinion issued April 23, 2026 Original Proceeding on Petition for Writ of Mandamus Panel consists of Chief Justice Adams and Justices Caughey and Morgan. Adams, C. J. , concurring. CONCURRING OPINION Terry Adams Chief Justice *1 I write separately to note that the mandamus petition herehasattributionsandquotationstocaselawwhichstrongly appear to be AI-fabricated hallucinations. Filing a document in our Court with fictitious or misleading citations—whether generated by AI and not checked by a human, or otherwise— is a serious breach of candor that this Court cannot tolerate. See TEX. R. APP. P. 38. 1, 38.", "ai_tool_named": null, "archive_url": null, "case_name": "IN RE PAULA M. MILLER, Relator", "citation": "2026 WL 1137938", "cited_authorities": [], "court": "Texas Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-23", "decision_id": "texapp-2026-in-re-paula-m-miller", "disposition": "The court warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "01-26-00319-CV", "document_type": "concurrence", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a submission with one fabricated case citation and one false case quotation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2050/IN_re_Paula_Miller_USA.pdf", "state": "TX", "summary": "The Texas Court of Appeals on 2026-04-23 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in IN RE PAULA M. MILLER, Relator. Counsel filed a submission with one fabricated case citation and one false case quotation.", "text_sha256": "fd7d2cd8a4f1d6ba60d6c60191366951028b7b11b2088c0f7569dc647e9f8fc3", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-paula-m-miller-relator", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp-2026-in-re-paula-m-miller", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp-2026-in-re-paula-m-miller" }, { "ai_passage": "” In support, she cites In re Yves S. , 373 Md. 551, 586–87 (2003) and Karanikas v. Cartwright, 209 Md. App. 571, 589–90 (2013). Neither of these cases support the stated proposition. To be sure, citations of inapposite authority is not uncommon in pro se filings, and, alone, it does not necessarily indicate the use of AI, but Mother's principal brief also contains two apparently fictitious citations: • Hurd v. Hurd, 223 Md. App. 654, 667–68 (2015), see Appellant's Br. at 13, does not exist. There is no Maryland case bearing this caption, and the principal cite leads to Assateague Coastal Tr. , Inc. v. Schwalbach, 223 Md.", "ai_tool_named": null, "archive_url": null, "case_name": "Fatima Meziane v. Abdelouahab Aitouche", "citation": "2026 WL 1101776", "cited_authorities": [ "Karanikas v. Cartwright, 209 Md", "Hurd v. Hurd, 223 Md", "Inc. v. Schwalbach, 223 Md", "Maryland case 'Hurd v. Hurd, 223 Md. App. 654, 667–68 (2015)'", "Maryland case 'Bradley v. Bradley, 174 Md. App. 234, 248–50 (2007)'" ], "court": "Appellate Court of Maryland", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-23", "decision_id": "mdapp-2026-fatima-meziane-v-abdelouahab-aitouche", "disposition": "The court affirmed the custody judgment, assessed costs to the appellant, and exercised discretion not to strike a brief with fictitious citations.", "docket_number": "C-15- FM-23-003513 Berger, Friedman, Sharer, J. Frederick", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented appellant filed a brief with two fabricated case citations, including Hurd v. Hurd and Bradley v. Bradley.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2057/FATIMA_MEZIANE_v_ABDELOUAHAB_AITOUCHE_23_April_2026.pdf", "state": "MD", "summary": "The Appellate Court of Maryland on 2026-04-23 affirmed the custody judgment, assessed costs to the appellant, and exercised discretion not to strike a brief with fictitious citations in Fatima Meziane v. Abdelouahab Aitouche. The self-represented appellant filed a brief with two fabricated case citations, including Hurd v. Hurd.", "text_sha256": "d072a1682c00947107420040972e1dca57b15f69d174649c3cc9a79dd69249e1", "topics": [ "fabricated-citations" ], "tracker_slug": "fatima-meziane-v-abdelouahab-aitouche", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mdapp-2026-fatima-meziane-v-abdelouahab-aitouche", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mdapp-2026-fatima-meziane-v-abdelouahab-aitouche" }, { "ai_passage": "However, Dennison is accordingly warned of the possibility of sanctions if any future filings violate Rule 11(b). The Court notes that when Dennison filed his complaint, he did not know which judge would preside over the matter. However, this Court entered a supplemental notice to pro se litigants regarding the use of artificial intelligence on April 13, 2026. Dkt. 8. This notice and the Practices and Procedures of this Court require all litigants to tell the Court if they used artificial intelligence (“AI”) to help write their complaint, a motion, or any other documents they file into the case. If Dennison uses AI to write a document, he must include a signed statement at the end of the document that says: This document was generated with the assistance of [identify AI tool name].", "ai_tool_named": null, "archive_url": null, "case_name": "Philip D. Dennison v. June Caudill et al.", "citation": null, "cited_authorities": [ "Fed. R. Civ. P. 11", "Plaintiff cited 'Coleman v. Hudson, 682 F3d 775 (7th Cir. 2012)'" ], "court": "United States District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-23", "decision_id": "insd-2026-philip-d-dennison-v-june-caudill", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "2:26-cv-00255-JRO-MKK", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a pleading with one fabricated case citation, including Coleman v. Hudson.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2049/Dennisson_v._Caudill_USA_23_April_2026.pdf", "state": "IN", "summary": "The Southern District of Indiana on 2026-04-23 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Philip D. Dennison v. June Caudill et al. The self-represented party filed a pleading with one fabricated case citation, including Coleman v. Hudson.", "text_sha256": "64410bea2a26c76ba948d54d1b6fb00efdf651e0c382e10d5e2b64f864fc776b", "topics": [ "fabricated-citations" ], "tracker_slug": "philip-d-dennison-v-june-caudill-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/insd-2026-philip-d-dennison-v-june-caudill", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-philip-d-dennison-v-june-caudill" }, { "ai_passage": "’s respondent’s brief highlights the deficits in the appellate record and asks this court to affirm on that basis. The respondent’s brief also complains that several of the cases cited by Melka in her opening brief either do not exist or do not support the claimed proposition for which they were cited— hallmarks, in respondent’s view, of use of an artificial intelligence tool to generate legal citations. The respondent’s brief also endeavors to rebut Melka’s arguments on the merits, insofar as permitted by the state of the record. Melka responded by filing a reply brief and a motion to augment the appellate record. Her motion seeks to augment the record with two items: O.", "ai_tool_named": null, "archive_url": null, "case_name": "O.K., LLC v. Melka", "citation": null, "cited_authorities": [], "court": "California Court of Appeal, Second District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-23", "decision_id": "calctapp2-2026-o-k-v-melka", "disposition": "The court affirmed the judgment, awarded appellate costs to O.K., and rejected record-augmentation arguments tied to alleged fabricated citations.", "docket_number": "LC103261", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a reply brief with one fabricated case citation and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2080/OK_v._Melka_USA_23_April_2026.pdf", "state": "CA", "summary": "The California Court of Appeal, Second District on 2026-04-23 affirmed the judgment, awarded appellate costs to O.K., and rejected record-augmentation arguments tied to alleged fabricated citations in O.K., LLC v. Melka. The self-represented party filed a reply brief with one fabricated case citation and one mischaracterized case citation.", "text_sha256": "9b8c5b9ed15f383ca88cf7f11e8e09456a9ce28dc67425c1e34022a81a3ec21b", "topics": [ "fabricated-citations" ], "tracker_slug": "o-k-llc-v-melka", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp2-2026-o-k-v-melka", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp2-2026-o-k-v-melka" }, { "ai_passage": "The Court recognizes the difficulty of making this showing and thus does not reach this conclusion lightly. However, Gunter is not advancing a debatable interpretation of an ambiguous law, which would clearly give rise to federal jurisdiction. He is relying on a phantom provision ofANCSAthat does not exist. Beyond that, Gunter offers no explanation for how ANCSA directly imposes a voting requirement on native corporation land sales. And because Gunter’s claim has no foundation in the text of ANCSA or any other tool of statutory interpretation, it is “completely devoid of merit as not to involve a federal controversy. ”62 Akiachak Native Comm.", "ai_tool_named": null, "archive_url": null, "case_name": "Gunter v. Contango ORE, Inc., et al.", "citation": null, "cited_authorities": [ "Plaintiff cited Jimerson v. Tetlin Native Corp. as holding that transactions affecting ANCSA l", "Inc. v. Doyon, Ltd. to argue the 1996 deed was improper" ], "court": "United States District Court for the District of Alaska", "court_code": "akd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-23", "decision_id": "akd-2026-gunter-v-contango-ore", "disposition": "The court admonished the self-represented party for unverified or fabricated authorities and cautioned against repeating the citation misconduct.", "docket_number": null, "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a submission with three mischaracterized case citations, one fabricated legal rule, and one fabricated or AI-like submission item.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2059/Gunter_v._Contango_USA_23_April_2026.pdf", "state": "AK", "summary": "The District of Alaska on 2026-04-23 admonished the self-represented party for unverified or fabricated authorities and cautioned against repeating the citation misconduct. The self-represented party filed a submission with three mischaracterized case citations, one fabricated legal rule, and one fabricated or AI-like submission item, including Jimerson v. Tetlin Native Corp. as holding that transactions affecting ANCSA l.", "text_sha256": "5e97564e2e8855d85f9155c767a4de1fea140531f311448488d3c81baa81b5e8", "topics": [ "fabricated-citations" ], "tracker_slug": "gunter-v-contango-ore-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/akd-2026-gunter-v-contango-ore", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/akd-2026-gunter-v-contango-ore" }, { "ai_passage": "46 Significantly, here, Ms. Johnson’s request is not premised on the need to respond to newly-raised issues or to proffer newly-discovered evidence. As Mr. Finlayson has suggested, it appears that the initial Opposition may have resulted from the improper use of artificial intelligence (“AI”). Ms. Johnson’s initial Opposition was riddled with case citations and quotations that the Court was unable to locate on Westlaw. 47 Ms. Johnson’s counsel was unable to provide copies of the cases at issue upon the Court’s request and sought instead to file more than six months after filing the initial Opposition an amended Opposition supported by different case law—case law that was available at the time of the initial Opposition’s filing. The amended Opposition is also supported by evidence that had not before been proffered, yet there is no argument provided that this evidence was not available when the initial Opposition was filed.", "ai_tool_named": null, "archive_url": null, "case_name": "Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Utah", "court_code": "utd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-22", "decision_id": "utd-2026-primerica-life-insurance-v-daniel-vett-finlayson-michelle-johnson", "disposition": "The court warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "2:24-cv-00779-AMA-DBP", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an opposition with one fabricated case citation and one false case quotation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2021/Primerica_USA_22_April_2026.pdf", "state": "UT", "summary": "The District of Utah on 2026-04-22 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson. Counsel filed an opposition with one fabricated case citation and one false case quotation.", "text_sha256": "aff21b58c5298226a02d7181d10ab315060000eb05145a3710b67a1b94b5c460", "topics": [ "fabricated-citations" ], "tracker_slug": "primerica-life-insurance-company-v-daniel-vett-finlayson-michelle-johnson", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/utd-2026-primerica-life-insurance-v-daniel-vett-finlayson-michelle-johnson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/utd-2026-primerica-life-insurance-v-daniel-vett-finlayson-michelle-johnson" }, { "ai_passage": "at 124 (“In accord with the substance and sense of our decisions in Lassiter and Santosky, [citation omitted], we place decrees forever terminating parental rights in the category of cases in which the State may not ‘bolt the door to equal justice[. ]’”). We overrule the Meyers’s second issue. D. Nonexistent Authority Before concluding, we would be remiss without acknowledging the Meyers’s reference to two non-existent cases. “Courts across the country have issued sanctions against attorneys and pro se parties for submitting fictitious case citations, fictitious quotations, and related misrepresentations to the court, including” dismissing or denying the appeal. United States v. Hayes, 763 F. Supp. 3d 1054, 1071–72 (E. D. Cal.", "ai_tool_named": null, "archive_url": null, "case_name": "Meyer v. Castroville State Bank", "citation": null, "cited_authorities": [ "United States v. Hayes, 763 F" ], "court": "Texas Court of Appeals, Fourth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-22", "decision_id": "texapp4-2026-meyer-v-castroville-state-bank", "disposition": "The court affirmed the summary judgment for the bank and declined to initiate sanctions proceedings over two non-existent cases.", "docket_number": "04-25-00278-CV Lance J. MEYER and Kerry L. Meyer, A", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a submission with two fabricated case citations.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2016/Meyer_v._Castrovill_USA_22_April_2026.pdf", "state": "TX", "summary": "The Texas Court of Appeals, Fourth District on 2026-04-22 affirmed the summary judgment for the bank and declined to initiate sanctions proceedings over two non-existent cases in Meyer v. Castroville State Bank. The self-represented party filed a submission with two fabricated case citations.", "text_sha256": "d336c23adc7eb2861ab171b7218ece624eaa8f074daf666a652a893d5fba95d6", "topics": [ "fabricated-citations" ], "tracker_slug": "meyer-v-castroville-state-bank", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp4-2026-meyer-v-castroville-state-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp4-2026-meyer-v-castroville-state-bank" }, { "ai_passage": "” On receipt of the parties’ responses, the court, through the Chief Judge, referred the matter to the Motions Department for resolution by way of precedential opinion issued by a three-judge panel because of the important and concerningly recurrent nature of the issue. As an initial matter, the professional choice for appellant's attorney to have made upon receiving the respondent's brief would have been to disclose to the court immediately that the opening brief contained fabricated law resulting from the use of generative artificial intelligence, and to have requested leave to file a rewritten brief. The motion that appellant's attorney filed lacked the candor that we expect from lawyers. See RPC 3.", "ai_tool_named": null, "archive_url": null, "case_name": "Carol L. Williams v. Tracy Honl", "citation": null, "cited_authorities": [ "Brief cited 'Tubra v. Cooke, 233 Or App 339, 225 P3d 862 (2010)' for an anti‑SLAPP proposition", "Neumann v. Liles", "Brief quoted Staten v. Steel as supporting a broad rule that private employment disputes", "Brief relied on Davoodian v. Rivera and similar citations for propositions or quotations the co", "Brief invoked Handy v. Lane for a proposition about government transparency and accountab" ], "court": "Oregon Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-22", "decision_id": "orctapp-2026-carol-l-williams-v-tracy-honl", "disposition": "The court struck the brief, awarded $8,044 in costs, and allowed appellant to file a replacement brief by a fixed deadline.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an opening brief with one fabricated case citation, one false case quotation, and three mischaracterized case citations, including Tubra v. Cooke and Neumann v. Liles.", "currency": "USD", "monetary_penalty": 8044, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2017/Williams_v._Honl_USA_22_April_2026.pdf", "state": "OR", "summary": "The Oregon Court of Appeals on 2026-04-22 struck the brief, awarded $8,044 in costs, and allowed appellant to file a replacement brief by a fixed deadline in Carol L. Williams v. Tracy Honl. Counsel filed an opening brief with one fabricated case citation, one false case quotation, and three mischaracterized case citations, including Tubra v. Cooke.", "text_sha256": "767cd4fb953e52973142589a1e5ddf6fbef89835cd2fc3fe7893f6bb0f166e8f", "topics": [ "fabricated-citations" ], "tracker_slug": "carol-l-williams-v-tracy-honl", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/orctapp-2026-carol-l-williams-v-tracy-honl", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/orctapp-2026-carol-l-williams-v-tracy-honl" }, { "ai_passage": "BROWN EME COURT IN THE SUPREME COURT OF THE STATE OF NEVADA YANLING ZHANG, Appellant, vs. YANHUI ZHANG, Respondent. ORDER IMPOSING SANCTIONS, REFERRING COUNSEL TO THE STATE BAR FOR INVESTIGATION, AND DENYING REQUEST TO CORRECT OPENING BRIEF On March 23, 2026, we entered an order toshow cause why this court should not impose sanctions or refer attorney Michael Lin to the State Bar of Nevada for investigation for potential violations of the Nevada Rules ofAppellate Procedure and Rulesof Professional Responsibility, specifically his inclusion of fictional or misleading citations in his opening brief. In response to this order, Mr. Lin acknowledges the seriousness of the circumstances and requests to file a corrected opening brief. Having considered Mr.", "ai_tool_named": null, "archive_url": null, "case_name": "Yanling Zhang v. Yanhui Zhang", "citation": null, "cited_authorities": [ "Appellant cited City of Henderson v. Bldg. & Constr. Trades Council, but the Court's research indicates this citation is fictional", "Appellant cited Blakeney v. State, but the Court's research indicates this citation is fictional", "Inc. v. Precision Constr., Inc", "Appellant cited Coyote Springs Inv. v. Eighth Judicial Dist. Ct" ], "court": "Supreme Court of Nevada", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-22", "decision_id": "nev-2026-yanling-zhang-v-yanhui-zhang", "disposition": "The court fined counsel $250, referred counsel to the State Bar, and denied leave to file a corrected opening brief.", "docket_number": "90509 FILE . BROWN EME COURT IN THE SUPREME COURT O", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an opening brief with two fabricated case citations and two mischaracterized case citations, including City of Henderson v. Bldg. & Constr. Trades Council and Blakeney v. State.", "currency": "USD", "monetary_penalty": 250, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2088/Zhang_v._Zhang_USA_22_April_2026.pdf", "state": "NV", "summary": "The Supreme Court of Nevada on 2026-04-22 fined counsel $250, referred counsel to the State Bar, and denied leave to file a corrected opening brief in Yanling Zhang v. Yanhui Zhang. Counsel filed an opening brief with two fabricated case citations and two mischaracterized case citations, including City of Henderson v. Bldg. & Constr. Trades Council.", "text_sha256": "84a64b83aec3165669cad36dc2ff8c9cdaa06168c09ee24c409e702b5dda29f9", "topics": [ "fabricated-citations" ], "tracker_slug": "yanling-zhang-v-yanhui-zhang", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nev-2026-yanling-zhang-v-yanhui-zhang", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nev-2026-yanling-zhang-v-yanhui-zhang" }, { "ai_passage": "Cf. id. at 625. Jones’s citation to Tokio Marine&FireInsuranceCompanyv. Flota Mercante Grancolombiana, S. A. , 35 F. 3d 1134 (6th Cir. 1994) is not to a real case, which suggests that Jones might be using artificial intelligence (AI) software prone to creating fake cases. And citing to cases that do not exist is a sanctionable offense. See Hardy v. Jones, No. 25-12718, 2026 WL 801202, at *1 (E. D. Mich. Mar. 23, 2026) (warning a pro se plaintiff that the court would recommend sanctions, including involuntary dismissal, for his repeated use of AI to generate fake cases); see also Whiting City of Athens Tennessee, No. 25-5424, 2026 WL 710568, at *4 (6th Cir.", "ai_tool_named": null, "archive_url": null, "case_name": "Alishia Monique Jones v. Ahmed Taylor, et al.", "citation": null, "cited_authorities": [ "See Hardy v. Jones, No. 25-12718, 2026 WL 801202, at *1 (E", "Tokio Marine & Fire Insurance Company v. Flota Mercante Grancolombiana, S.A., 35 F.3d 1134 (6th Cir. 1994) is not a real case and likely AI-generated", "Court noted United States v. Robinson, 305 F.3d 732 (6th Cir. 2002) appears to be a fabricated citation generated by AI" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-22", "decision_id": "mied-2026-alishia-monique-jones-v-ahmed-taylor", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "2:25-cv-10681 v. Honorable Susan K. DeClercq United", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a submission with two fabricated case citations, including Tokio Marine & Fire Insurance Company v. Flota Mercante Grancolombiana and United States v. Robinson.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2019/Jones_v._Taylor_USA_22_April_2026.pdf", "state": "MI", "summary": "The Eastern District of Michigan on 2026-04-22 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Alishia Monique Jones v. Ahmed Taylor, et al. The self-represented plaintiff filed a submission with two fabricated case citations, including Tokio Marine & Fire Insurance Company v. Flota Mercante Grancolombiana.", "text_sha256": "bd95bc5397a802787ad823d80868cfde104b5d0351720e970b5ff2ab81127679", "topics": [ "fabricated-citations" ], "tracker_slug": "alishia-monique-jones-v-ahmed-taylor-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-alishia-monique-jones-v-ahmed-taylor", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-alishia-monique-jones-v-ahmed-taylor" }, { "ai_passage": ") Appellant's brief does not engage with the applicable standards of review. It contains little if any legal argument or citations to relevant authority. Instead, the brief cites authorities that do not support the propositions for which they are cited; decisions that have been disapproved by the Supreme Court; 10 and numerous nonexistent cases. 11 Extensive reliance on nonexistent legal authority could alone justify dismissing an appeal as “frivolous because it ‘rests on negligible legal foundation’ [Citations] and is peppered with fabricatedlegalcitations[,]... [andalso]unreasonablyviolates the Rules of Court because it does not support each point with citationstoreal(asopposedtofabricated)legalauthority. (See rule8. 204(a)(1)(B). )”(Nolandv. LandoftheFree,L. P.", "ai_tool_named": null, "archive_url": null, "case_name": "In re the Marriage of Joanne Rodrigues and Nathan Craig", "citation": "2026 WL 1102361", "cited_authorities": [], "court": "California Court of Appeal, Sixth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-22", "decision_id": "calctapp6-2026-in-re-marriage-of-joanne-rodrigues-and-nathan-craig", "disposition": "The court affirmed the status-only judgment and postjudgment orders and ordered the parties to bear their own appellate costs.", "docket_number": "20FL000750", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented appellant filed a brief with nine fabricated case citations.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2048/Rodrigues_v._Craig_USA_22_April_2022.pdf", "state": "CA", "summary": "The California Court of Appeal, Sixth District on 2026-04-22 affirmed the status-only judgment and postjudgment orders and ordered the parties to bear their own appellate costs in In re the Marriage of Joanne Rodrigues and Nathan Craig. The self-represented appellant filed a brief with nine fabricated case citations.", "text_sha256": "dca0d6b7cc920932dae2c68ca3c1de3406001e9b140c7b054bc229e2c50f3fa5", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-the-marriage-of-joanne-rodrigues-and-nathan-craig", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp6-2026-in-re-marriage-of-joanne-rodrigues-and-nathan-craig", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp6-2026-in-re-marriage-of-joanne-rodrigues-and-nathan-craig" }, { "ai_passage": "However, the undersigned finds that while the scope of the violation here may be distinguishable from Tercero, the existence of an intent to gain an unfair advantage through a misrepresentation of legal citation is the same in both cases, and here warrants both a monetary sanction and reporting to the bar. Although its use is not conclusive here, this Court expresses its grave concern about the use of generative artificial intelligence without the appropriate due diligence and verificationbytheattorneysigningthefiling. Theappearance of hallucinated cases, improper citations, and distortions of opinions create consequences that fall on the attorney, as filing documents with this Court certifies that any assertions made are supported by law and signatures on the documents filed mean the attorney has performed the appropriate due diligence. If Plaintiff elects to go down the treacherous path of employing generative artificial intelligence in drafting her filings to this Court, she must realize she bears the responsibility for that election and all related consequences, and nothing about that election constitutes a substitute for attorney diligence.", "ai_tool_named": null, "archive_url": null, "case_name": "Krista C. Geddes v. LoanCare, LLC, et al.", "citation": "2026 WL 1092496", "cited_authorities": [], "court": "United States District Court for the Eastern District of California", "court_code": "caed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-22", "decision_id": "caed-2026-krista-c-geddes-v-loancare", "disposition": "The court fined counsel $1,000 and referred counsel to the State Bar after finding false quotations in the remand papers.", "docket_number": "2:25-cv-02955-DMC", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a submission with two false case quotations.", "currency": "USD", "monetary_penalty": 1000, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2018/Geddes_v._Loancare_USA_22_April_2026.pdf", "state": "CA", "summary": "The Eastern District of California on 2026-04-22 fined counsel $1,000 and referred counsel to the State Bar after finding false quotations in the remand papers in Krista C. Geddes v. LoanCare, LLC, et al. Counsel filed a submission with two false case quotations.", "text_sha256": "c52775e85c77c3f3365109b8ecca59e3eb83d8604cfbaea9fbc1a73fc913525c", "topics": [ "fabricated-citations" ], "tracker_slug": "krista-c-geddes-v-loancare-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/caed-2026-krista-c-geddes-v-loancare", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/caed-2026-krista-c-geddes-v-loancare" }, { "ai_passage": "In support of this claim, Plaintiff cites to Navient Solutions, - 18 - LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1864871, at *12 (D. Ariz. 2020). This case does not exist. As Circle K notes in its Motion to Dismiss, a search of “2020 WL 1864871” returns an Ohio Public Utilities Commission Finding and Order titled “In the Matter of the Proper Procedures and Process for the Commission’s Operations and Proceedings During the Declared State of Emergency and Related Matters. ” (Doc. 11 at 13). The Court believes that Plaintiff intended to cite to a case from the Eastern District of Virginia. See Navient Sols.", "ai_tool_named": null, "archive_url": null, "case_name": "Daniel D’Agostino v. Circle K Stores Incorporated, et al.", "citation": null, "cited_authorities": [ "LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1864871, at *12 (D", "LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1864871, at *12 (D. Ariz. 2020).' The Court found that citation does not", "LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1867939 (E.D. Va. Apr. 14, 2020), which is irrelevant to the claim" ], "court": "United States District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-22", "decision_id": "azd-2026-daniel-dagostino-v-circle-k-stores-incorporated", "disposition": "The court granted Circle K’s motion to dismiss in part, denied it in part, and identified a nonexistent Navient citation in the complaint.", "docket_number": "2:26-cv-01225-JAT", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a motion with one fabricated case citation, including LLC v. Law Offices of Jeffrey Lohman.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2073/DAgostino_v_Circle_K_Stores_Incorporated_USA_23_April_2026.pdf", "state": "AZ", "summary": "The District of Arizona on 2026-04-22 granted Circle K’s motion to dismiss in part, denied it in part, and identified a nonexistent Navient citation in the complaint in Daniel D’Agostino v. Circle K Stores Incorporated, et al. The self-represented plaintiff filed a motion with one fabricated case citation, including LLC v. Law Offices of Jeffrey Lohman.", "text_sha256": "b8c798bff5edfa8a7ec0996d922c9519a0034b4c7d486b0ed653db3fd5b7dc76", "topics": [ "fabricated-citations" ], "tracker_slug": "daniel-dagostino-v-circle-k-stores-incorporated-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azd-2026-daniel-dagostino-v-circle-k-stores-incorporated", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-daniel-dagostino-v-circle-k-stores-incorporated" }, { "ai_passage": "Supp. 3d 443 (2023), constituye el primer caso donde se analizó extensamente el uso de inteligencia artificial generativa para producir citas ficticias y donde se impusieron sanciones detalladas por el mal uso de ChatGPT en un escrito judicial. 2 En lo concerniente a la conducta sancionable específica, el Tribunal de Distrito para el Distrito Sur de Nueva York sostuvo que, bajo la Regla 11 de las Reglas de Procedimiento 2 En cuanto a los hechos de dicho caso, abogados fueron sancionados por usar ChatGPT, herramienta de inteligencia artificial que fabricó casos citados en un escrito presentado ante un foro judicial. Particularmente, el Tribunal de Distrito para el Distrito Sur de Nueva York examinó una oposición a solicitud de desestimación donde se citaron decisiones inexistentes y generadas por la inteligencia artificial.", "ai_tool_named": null, "archive_url": null, "case_name": "In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry", "citation": null, "cited_authorities": [ "Promovidas cited 'Otero-Burgos v. Inter Med. Supplies, Inc., 137 DPR 841, 848 (1995)' and attributed a direct quote which the record sh", "Promovidas attributed to 'Rosado v. ELA, 2004 TSPR 13' a textual statement on Ley 115 that the Court found was not suppor", "Promovidas cited 'Ramos Lozada v. E.L.A., 174 DPR 650 (2008)' attributing a quote on qualified immunity that the Court det" ], "court": "Supreme Court of Puerto Rico", "court_code": null, "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-21", "decision_id": "pr-2026-in-re-maria-v-irizarry-centeno-anissa-m-bonilla-irizarry", "disposition": "The court admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a submission with six fabricated case citations, including Otero-Burgos v. Inter Med. Supplies and Rosado v. ELA.", "currency": "USD", "monetary_penalty": 1000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2047/In_re_Mar%C3%ADa_V._IRIZARRY_CENTENO_USA_21_April_2026.pdf", "state": "PR", "summary": "The Supreme Court of Puerto Rico on 2026-04-21 admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct in In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry. Counsel filed a submission with six fabricated case citations, including Otero-Burgos v. Inter Med. Supplies.", "text_sha256": "75b1f5398388f0521e78f6aaa3764835fb9aa64919ab84ef19306184247f28c6", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-mar-a-v-irizarry-centeno-anissa-m-bonilla-irizarry", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pr-2026-in-re-maria-v-irizarry-centeno-anissa-m-bonilla-irizarry", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pr-2026-in-re-maria-v-irizarry-centeno-anissa-m-bonilla-irizarry" }, { "ai_passage": "4 Because the Court is granting Plaintiff an additional opportunity to move to amend the Complaint, the Court will at this time deny the pending Motions to Dismiss as moot, and without prejudice. The Defendants may renew their motions to dismiss at a later date, if the motions remain relevant. F. Use of Artificial Intelligence Multiple Defendants have suggested that Plaintiff has used artificial intelligence tools to draft her pleadings. In particular, the District Defendants assert that Plaintiff's use of artificial intelligence resulted in Plaintiff submitting nonexistent or spurious case citations to this Court. District. Def. 's Opp'n to Second Mot. Am.", "ai_tool_named": null, "archive_url": null, "case_name": "Jurkowski v. Berkowitz", "citation": "2026 WL 1345470", "cited_authorities": [], "court": "Superior Court of the District of Columbia", "court_code": null, "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-21", "decision_id": "dcsuperct-2026-jurkowski-v-berkowitz", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "2025-CAB-8255. April 21, 2026", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a pleading with one fabricated case citation and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2327/3_-_Jurkowski_v_Berkowitz.pdf", "state": "DC", "summary": "The Superior Court of the District of Columbia on 2026-04-21 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jurkowski v. Berkowitz. The self-represented plaintiff filed a pleading with one fabricated case citation and one mischaracterized case citation.", "text_sha256": "6b91075fcc368205f96a3ef5d8a16f7dd59e88c564e1544ebb54fce737222f86", "topics": [ "fabricated-citations" ], "tracker_slug": "jurkowski-v-berkowitz", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/dcsuperct-2026-jurkowski-v-berkowitz", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/dcsuperct-2026-jurkowski-v-berkowitz" }, { "ai_passage": "see also Telford, 95 Wn. App. at 162 & n. 17 (discussing 1991 Att'y Gen. Op. No. 5). This is not persuasive to the instant record. 13 Atcertainpointsinhisbriefing,Westprovidesfictitiousquotationsfromexistentcases. Werebukesuchlackof candor as detrimental and offensive to the legal process and not worthy of judicial review. Everyone, including pro se litigants, are responsible to confirm their pleadings, motions, briefs, and other filings are accurate and do not contain any citations that are invented or hallucinated by generative artificial intelligence (AI) or any other source. See RAP 10. 3(a)(6); West v. Thurston County, 168 Wn. App. 162, 187, 275 P. 3d 1200 (2012).", "ai_tool_named": null, "archive_url": null, "case_name": "Arthur West v. Lower Duwamish Waterway Group", "citation": "2026 WL 1069752", "cited_authorities": [ "West v. Thurston County, 168 Wn" ], "court": "Washington Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-20", "decision_id": "washctapp-2026-arthur-west-v-lower-duwamish-waterway-group", "disposition": "The court admonished the self-represented party for unverified or fabricated authorities and cautioned against repeating the citation misconduct.", "docket_number": "87289-3-I", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a brief with one fabricated case citation and one false case quotation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2023/West_v._Lower_Duwamish_USA_20_April_2026.pdf", "state": "WA", "summary": "The Washington Court of Appeals on 2026-04-20 admonished the self-represented party for unverified or fabricated authorities and cautioned against repeating the citation misconduct in Arthur West v. Lower Duwamish Waterway Group. The self-represented party filed a brief with one fabricated case citation and one false case quotation.", "text_sha256": "8ec708b531b1f16afe16fec26b52121df850520d1b1b8149a9855d7fe193938b", "topics": [ "fabricated-citations" ], "tracker_slug": "arthur-west-v-lower-duwamish-waterway-group", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/washctapp-2026-arthur-west-v-lower-duwamish-waterway-group", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/washctapp-2026-arthur-west-v-lower-duwamish-waterway-group" }, { "ai_passage": "The court did not, however, give Plaintiffs a deadline to file that amendment because Plaintiffs must respond to this order first. While reviewing the parties’ briefs on 3M’s Rule 12(c) motion, the court noticed that Plaintiffs’ opposition (doc. 39) was riddled with misquotes, false quotes, strained case interpretations, and citations that seem to have been outright fabricated. You could call some of the errors ‘ticky-tack’ if you viewed them in isolation. But considering the volume of the errors—and the number of fabrications—the court struggles to overlook any of them. Instead, the court highlights nine errors below. A.", "ai_tool_named": null, "archive_url": null, "case_name": "Bridgett Watson Adams, et al. v. 3M Company", "citation": null, "cited_authorities": [ "Jarrod Johnson v. Water Light & Sinking Fund Comm’n", "Gonsalvez v. Celebrity Cruises", "Plaintiffs relied on Cook v. Randolph Cty., 573 F.3d 1143, 1150-51 (11th Cir. 2009) to support a Rule 15 amendment entitleme", "Plaintiffs cited Payton v. Monsanto, 801 So. 2d 829, 835-36 (Ala. 2001) claiming it supported a discovery rule for ac" ], "court": "United States District Court for the Northern District of Alabama", "court_code": "alnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-20", "decision_id": "alnd-2026-bridgett-watson-adams-v-3m", "disposition": "The court ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "4:24-cv-00832-CLM", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed an opposition with two fabricated case citations, three false case quotations, and three mischaracterized case citations.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2577/Adams_-_43.pdf", "state": "AL", "summary": "The Northern District of Alabama on 2026-04-20 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities. Counsel filed an opposition with two fabricated case citations, three false case quotations, and three mischaracterized case citations, including Jarrod Johnson v. Water Light & Sinking Fund Comm’n.", "text_sha256": "314c87609e79117fb5e5dba50f409c0855a24e998aff5c633fa7ae24026cb577", "topics": [ "fabricated-citations" ], "tracker_slug": "bridgett-watson-adams-et-al-v-3m-company", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/alnd-2026-bridgett-watson-adams-v-3m", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alnd-2026-bridgett-watson-adams-v-3m" }, { "ai_passage": "I became aware Thursday evening that the JPLs’ Emergency Motion for Entry of Orders Granting (I) Ex Parte Relief and (II) Provisional Relief, Pursuant to Section 1519 of the Bankruptcy Code filed with the Court on April 9, 2026 (the “Motion”) [D. I. 9] includes inaccurate citations and other errors, each of which is identified and corrected in Schedule A to this letter. The inaccuracies and errors in the Motion include artificial intelligence (“AI”) “hallucinations. ” “Hallucinations” are instances in which artificial intelligence tools fabricate case citations, misquote authorities, or generate non-existent legal sources. We deeply regret that this has occurred. The Firm maintains comprehensive policies and training requirements governing the use of AI tools in legal work. These safeguards are designed to prevent exactly this situation.", "ai_tool_named": null, "archive_url": null, "case_name": "In re Prince Global Holdings Limited, et al.", "citation": null, "cited_authorities": [], "court": "United States Bankruptcy Court for the Southern District of New York", "court_code": "nysb", "court_level": "federal-bankruptcy", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-18", "decision_id": "nysb-2026-in-re-prince-global-holdings-limited", "disposition": "The bankruptcy court received the firm’s corrective letter identifying AI hallucinations, accepted corrected citations, and noted the apology.", "docket_number": "26-10769 Dear Chief", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "The firm filed a bankruptcy motion with AI-hallucinated case citations, a misquoted authority, and a garbled citation, then corrected the errors by letter.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2002/In_re_Prince_USA_18_April_2026.pdf", "state": "NY", "summary": "The Bankruptcy Court for the Southern District of New York on 2026-04-18 received the firm’s corrective letter identifying AI hallucinations, accepted corrected citations, and noted the apology in In re Prince Global Holdings Limited, et al. Counsel filed a motion with two fabricated case citations, one false case quotation, and one mischaracterized case citation.", "text_sha256": "907127d4745c07606af1bc7ed442ffbc75c2daaa0e4d9a36913941a9bc02b008", "topics": [ "fabricated-citations" ], "tracker_slug": "sullivan-cromwell-prince-global", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysb-2026-in-re-prince-global-holdings-limited", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysb-2026-in-re-prince-global-holdings-limited" }, { "ai_passage": "Plaintiff argues Defendant's Motion to Dismiss was filed “without reliable legal support” and cites “multiple authority defects. ” Mot. at 11. Among other things, Plaintiff cites (and Defendant has confirmed) its use of AI resulted in several citation errors, including a completely hallucinated cite and other cites that do not support the proposition Defendant's claimed they did. See id. at 11-13. While the Court agrees with Plaintiff that Defendant's failure to verify authority it cited in its filing before a federal court is inexcusable, the Court cannot conclude Defendant “knowingly or recklessly raise[d] a frivolous argument. ”1 In re Keegan Mgmt.", "ai_tool_named": null, "archive_url": null, "case_name": "Robert Harris v. Elementis Specialties, Inc.", "citation": "2026 WL 1104324", "cited_authorities": [], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-17", "decision_id": "cacd-2026-robert-harris-v-elementis-specialties", "disposition": "The court warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "EDCV 26-00171-KK-DTBx", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a motion with one fabricated case citation and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2058/Robert_Harris_v_Elementis_Specialties_Inc_et_al_USA_17_April_2026.pdf", "state": "CA", "summary": "The Central District of California on 2026-04-17 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Robert Harris v. Elementis Specialties, Inc. Counsel filed a motion with one fabricated case citation and one mischaracterized case citation.", "text_sha256": "0c357d095f19bb88ea425afdea97a79007c39849daa7487ebfd06459e019ffe7", "topics": [ "fabricated-citations" ], "tracker_slug": "robert-harris-v-elementis-specialties-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-robert-harris-v-elementis-specialties", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-robert-harris-v-elementis-specialties" }, { "ai_passage": "LAUD ESSANDOH v. United States District Court, E. D. Texas, Sherman Division. LAUD ESSANDOH v. CAPITAL ONE BANK NA NO. ORDER ON DISCLOSURE AND CERTIFICATION REQUIREMENTS FOR USE OF GENERATIVE ARTIFICIAL INTELLIGENCE Bill Davis United States Magistrate Judge *1 Today, the court held a discovery hearing based on the parties' joint report, Dkt. 25, following the court's face-to-face order, Dkt. 24. Minute Entry for Apr. 16, 2026. At the hearing, the court questioned plaintiff Laud Essandohregardinginaccuraciesinhispartofthejointreport. Id. Essandoh admitted that the inaccuracies resulted from reliance on generative artificial intelligence (“AI”). Id. The court admonished him about the risks of that misplaced relianceandthesanctionsthatcanresultfromit. Id.", "ai_tool_named": null, "archive_url": null, "case_name": "Laud Essandoh v. Capital One Bank NA", "citation": "2026 WL 1040383", "cited_authorities": [ "Sherman Division. LAUD ESSANDOH v. CAPITAL ONE BANK NA NO. ORDER ON DISCLOSURE AND CERTIFICATION REQU" ], "court": "United States District Court for the Eastern District of Texas", "court_code": "txed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-16", "decision_id": "txed-2026-laud-essandoh-v-capital-one-bank-na", "disposition": "The court admonished the self-represented plaintiff and imposed disclosure and certification requirements for any future generative-AI use.", "docket_number": "4:25-CV-00746-ALM-BD", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff submitted an inaccurate joint discovery report after relying on generative AI without adequate verification.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2024/Essandoh_v._Capital_One_USA_16_Arpil_2026.pdf", "state": "TX", "summary": "The Eastern District of Texas on 2026-04-16 admonished the self-represented plaintiff about inaccuracies in a joint discovery report caused by generative-AI reliance. The order required future disclosures identifying any generative-AI use and certifications that the filer reviewed AI work product for accuracy and relevance.", "text_sha256": "312d927607f9364dac195076151fc2e7e6c02f2a7a1acdd9d7efbe2df726a97a", "topics": [ "fabricated-citations" ], "tracker_slug": "laud-essandoh-v-capital-one-bank-na", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txed-2026-laud-essandoh-v-capital-one-bank-na", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txed-2026-laud-essandoh-v-capital-one-bank-na" }, { "ai_passage": "72(a) (“When a pretrial matter not dispositive of a party's claim or defense is referred to a magistrate judge to hear and decide, the magistrate judge must promptly conduct the required proceedings and, when appropriate, issue a written order stating the decision. ”). 3 As a preliminary matter, in its surreply, Safeway includes an embedded motion to strike the Motion for Costs on grounds that Ms. Saunders's reply brief was not timely filed and that she relied on a fictional, AI-generated case. See ECF No. 86 at 3; see also ECF No. 77 at 3 (citing Lampe v. United States, 18 F.", "ai_tool_named": null, "archive_url": null, "case_name": "Jamie Lee Saunders v. Albertsons/Safeway, LLC", "citation": "2026 WL 1040465", "cited_authorities": [ "Lampe v. United States, 18 F" ], "court": "United States District Court for the District of Colorado", "court_code": "cod", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-16", "decision_id": "cod-2026-jamie-lee-saunders-v-albertsons-safeway", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:24-cv-00814-PAB-SBP", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a reply brief with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1995/Saunders_v._Albertsons_USA_16_April_2026.pdf", "state": "CO", "summary": "The District of Colorado on 2026-04-16 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jamie Lee Saunders v. Albertsons/Safeway, LLC. The self-represented party filed a reply brief with one fabricated case citation.", "text_sha256": "f06c5bc069ccc4004bdca25026cce7fa3de3cb757a32db91c4297c5c6cea4c6a", "topics": [ "fabricated-citations" ], "tracker_slug": "jamie-lee-saunders-v-albertsons-safeway-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cod-2026-jamie-lee-saunders-v-albertsons-safeway", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cod-2026-jamie-lee-saunders-v-albertsons-safeway" }, { "ai_passage": "After appellee filed its brief, cogently and logically demonstrating the lack of merit in appellants’ appellate argument and showing that the case citations briefed by appellants do not stand for the claimed propositions of law, appellants filed a replybrief. Thereplybriefattemptedtoaddanappellateissue,anditincludedfifteen opinion citations. Of those, one is a purported opinion from this court for which the citation is incorrect and which we were unable to locate after extensive research. It appears to be hallucinated. Four of the opinions cited in the reply brief do not stand for the asserted propositions. The remaining cases cited are for generic legal propositions, such as the standards for granting summary judgment. Considering the merits, we find no error and affirm the judgment. BACKGROUND On January 14, 2020, appellants executed a promissory note in favor of appellee, secured by a deed of trust against their property in Kaufman County.", "ai_tool_named": null, "archive_url": null, "case_name": "Fofanah v. Rockwall Rental Properties", "citation": null, "cited_authorities": [ "Appellants relied on Khan v. GBAK Properties, Inc. for a notice-of-default proposition the opinion does not support", "Appellants cited 'Jones v. American Real Estate Services, LLC' as an opinion of this court" ], "court": "Texas Court of Appeals, Fifth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-15", "decision_id": "texapp5-2026-fofanah-v-rockwall-rental-properties", "disposition": "The court affirmed summary judgment for Rockwall Rental Properties after appellants relied on unsupported and hallucinated case citations.", "docket_number": "118630-422", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented appellant filed a reply brief with one fabricated case citation and two mischaracterized case citations, including Khan v. GBAK Properties and Jones v. American Real Estate Services.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2022/Fofanah_USA_15_April_2026.pdf", "state": "TX", "summary": "The Texas Court of Appeals, Fifth District on 2026-04-15 affirmed summary judgment for Rockwall Rental Properties after appellants relied on unsupported and hallucinated case citations in Fofanah v. Rockwall Rental Properties. The self-represented appellant filed a reply brief with one fabricated case citation and two mischaracterized case citations, including Khan v. GBAK Properties.", "text_sha256": "529b81604036b27430af11972162af2271e9905ff37e644f244063926dd1f540", "topics": [ "fabricated-citations" ], "tracker_slug": "fofanah-v-rockwall-rental-properties", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/texapp5-2026-fofanah-v-rockwall-rental-properties", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp5-2026-fofanah-v-rockwall-rental-properties" }, { "ai_passage": ", 783 F. Supp. 3d 959, 960 (N. D. Tex. 2025) (“It is no secret that generative [artificial intelligence (AI)] programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs. ” (quoting Sanders v. United States, 176 Fed. Cl. 163, 168-69 (2025))). 4 The Mathews factors require us to consider: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.", "ai_tool_named": null, "archive_url": null, "case_name": "Nelson v. Derry", "citation": "2026 WL 1065922", "cited_authorities": [ "Sanders v. United States, 176 Fed", "Husband cited 'DeMars v. DeMars, 590 N.W.2d 116, 120-21 (Minn. Ct. App. 1999)', which the court was unable to loc" ], "court": "Minnesota Court of Appeals", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-15", "decision_id": "minnctapp-2026-nelson-v-derry", "disposition": "The court affirmed the district court’s order and noted that the husband cited an unlocatable DeMars decision resembling an AI hallucination.", "docket_number": "62-FA-21-428 ConsideredanddecidedbyLarson,Presiding", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a brief with one fabricated case citation, including DeMars v. DeMars.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2015/In_re_Nelson_USA_15_April_2026.pdf", "state": "MN", "summary": "The Minnesota Court of Appeals on 2026-04-15 affirmed the district court’s order and noted that the husband cited an unlocatable DeMars decision resembling an AI hallucination in Nelson v. Derry. The self-represented party filed a brief with one fabricated case citation, including DeMars v. DeMars.", "text_sha256": "c407d2ecce4d7d4daa5d87a1a35d15f9ad94c02ab80f74a4139ae998079c4866", "topics": [ "fabricated-citations" ], "tracker_slug": "nelson-v-derry", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/minnctapp-2026-nelson-v-derry", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/minnctapp-2026-nelson-v-derry" }, { "ai_passage": "” McCann v. Dart, 2015 Il App (1st) 141291, ¶ 15. “Arguments that do not comply with Rule 341(h)(7) do not merit consideration on appeal and may be rejected by this court for that reason alone. ” Wells Fargo Bank, N. A. v. Sanders, 2015 IL App (1st) 141272, ¶ 43. ¶16Plaintiffs’convolutedbriefsincludeabundantcitationsto both hallucinated cases and fictitious holdings and quotations from existent cases. Plaintiffs’ citations to fictitious authority are too numerous to relay in their entirety. For instance, in their corrected and amended opening brief, plaintiffs cite Dunn v. Old Orchard Ctr. , Ltd. , 306 Ill. App. 3d 75 (1999). STANCE STRONG and KINISHA STRONG... , Not Reported in N.", "ai_tool_named": "Centient AI", "archive_url": null, "case_name": "Stance Strong and Kinisha Strong v. Zubha Pop Foods LLC d/b/a Popeyes Chicken", "citation": "2026 IL App (1st) 242451-U", "cited_authorities": [ "McCann v. Dart, 2015 Il App (1st", "N. A. v. Sanders, 2015 IL App (1st", "Dunn v. Old Orchard Ctr.", "Plaintiffs cited Dunn v. Old Orchard Ctr., Ltd., 306 Ill. App. 3d 75 (1999) for a proposition the actual case (People v. Ma", "Plaintiffs cited Arnold v. Hoyt, 384 F. Supp. 566 (1974) and quoted language not found in the actual opinion", "Inc. v. Dussault and the quoted passage is absent", "Fausett v. Walgreen Co' with no supporting citation or record" ], "court": "Appellate Court of Illinois, First District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-15", "decision_id": "illapp1-2026-stance-strong-and-kinisha-strong-v-zubha-pop-foods-d-b-a-popeyes-chicken", "disposition": "The court struck the defective brief after finding Centient AI links, false quotations, and numerous nonexistent authorities.", "docket_number": "1-24-2451", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": "Centient AI", "conduct": "The self-represented plaintiff filed an opening brief with one fabricated case citation and two mischaracterized case citations, including Dunn v. Old Orchard Ctr and People v. Maurice Dunn after using Centient AI.", "currency": null, "monetary_penalty": null, "outcome": "strike-off" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1996/Strong_v._Zhuba_USA_16_April_2026.pdf", "state": "IL", "summary": "The Appellate Court of Illinois, First District on 2026-04-15 struck the defective brief after finding Centient AI links, false quotations, and numerous nonexistent authorities. The self-represented plaintiff filed an opening brief with one fabricated case citation and two mischaracterized case citations, including Dunn v. Old Orchard Ctr.", "text_sha256": "55cdc630a8a77c6f0ea73ff98dc90210f5efd1fcff6f32fa9dc5b4b0931722f8", "topics": [ "fabricated-citations" ], "tracker_slug": "stance-strong-and-kinisha-strong-v-zubha-pop-foods-llc-d-b-a-popeyes-chicken", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/illapp1-2026-stance-strong-and-kinisha-strong-v-zubha-pop-foods-d-b-a-popeyes-chicken", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illapp1-2026-stance-strong-and-kinisha-strong-v-zubha-pop-foods-d-b-a-popeyes-chicken" }, { "ai_passage": "While we do not specifically address all of the protester’s arguments, we have considered them and conclude that they do not provide a basis to sustain the protest. We note that in reviewing the protester’s filings, we identified several irregularities in citations provided by the protester. In this regard, the protester cited decisions of our Office for which we were unable to locate the decisions identified by the protester and misrepresented the content of several decisions. For example, the protester cites to “Innovative Test Asset Solutions, LLC, B-419132, Dec. 16, 2020, 2020 CPD ¶ 398” for the proposition that “omissions affecting the evaluation of a scored factor are material defects” requiring further action from the agency. Protest at 5.", "ai_tool_named": null, "archive_url": null, "case_name": "Matter of: LOGMET LLC, B-423066.2", "citation": "B-423066.2", "cited_authorities": [], "court": "Government Accountability Office", "court_code": "gao", "court_level": "federal-specialty", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-15", "decision_id": "gao-2026-matter-of-logmet-b-423066-2", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "FA810824RB001, issued by the Department of the Air", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a submission with one fabricated case citation and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2020/LOGMET_LLC_885266.pdf", "state": null, "summary": "The Government Accountability Office on 2026-04-15 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Matter of: LOGMET LLC, B-423066.2. The self-represented party filed a submission with one fabricated case citation and one mischaracterized case citation.", "text_sha256": "072e78c0ede96a91f67954b4ace13e1704545ab1ff42379b31294e68f21fea9b", "topics": [ "fabricated-citations" ], "tracker_slug": "matter-of-logmet-llc-b-423066-2", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gao-2026-matter-of-logmet-b-423066-2", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gao-2026-matter-of-logmet-b-423066-2" }, { "ai_passage": "Smith’s claims against the non-signatories—SBI, A & A, and B & C—must be hashed out in arbitration. The Court declines to lift the stay as to the non-signatory defendants. Artificial Intelligence Though the Court has found good reason to deny Smith’s motion, it pauses to address Smith’s use of generativeAI. In response to the motion, the non-signatory defendants directed the Court’s attention to AI-hallucinated cases in Smith’s motion. This is not the first time Smith’s filings cited fictitious legal authorities. And the Court has admonished Smith against further fictitious citations. [40] But the Court does note Smith had already filed his motion for reconsideration before the Court’s admonishment.", "ai_tool_named": null, "archive_url": null, "case_name": "Brian Smith v. TD Auto Finance LLC, et al.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Northern District of Mississippi", "court_code": "msnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-14", "decision_id": "msnd-2026-brian-smith-v-td-auto-finance", "disposition": "The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "19-12130,2020WL3832606, at", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party filed a motion with one fabricated case citation.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1988/Smith_v._Auto_Finance_USA_14_April_2026.pdf", "state": "MS", "summary": "The Northern District of Mississippi on 2026-04-14 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Brian Smith v. TD Auto Finance LLC, et al. The self-represented party filed a motion with one fabricated case citation.", "text_sha256": "a8c6199bb492de7331bac5afd1e7b89af71369372a8eab6cbb9ea9490188e124", "topics": [ "fabricated-citations" ], "tracker_slug": "brian-smith-v-td-auto-finance-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/msnd-2026-brian-smith-v-td-auto-finance", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/msnd-2026-brian-smith-v-td-auto-finance" }, { "ai_passage": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION CYNTHIAWHITE, ) ) Plaintiff, ) ) v. ) No. 1:25-cv-01120-RLY-TAB ) WALMART, INC. , ) ) Defendant. ) DISCOVERY ORDER FOLLOWING APRIL10, 2026, TELEPHONIC STATUS CONFERENCE Artificial intelligence can be a useful discovery tool. However, as discussed below,AI is not a substitute for attorneys and litigants exercising independent judgment and oversight in the discovery process. Relatedly, the Court once again reminds counsel of their obligation to meaningfully meet and confer with one another before seeking the Court's involvement in discovery disputes. Exclusive reliance onAI-generated discovery responses does not satisfy this obligation. I. Background Plaintiff Cynthia White alleges that Defendant Walmart wrongfully terminated her in retaliation for making a worker's compensation claim.", "ai_tool_named": null, "archive_url": null, "case_name": "Cynthia White v. Walmart, Inc.", "citation": null, "cited_authorities": [], "court": "United States District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-14", "decision_id": "insd-2026-cynthia-white-v-walmart", "disposition": "The court warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "1:25-cv-01120-RLY-TAB", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel relied on AI-generated discovery talking points that overstated every interrogatory response as deficient instead of conducting a real meet-and-confer.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1979/White_v._Walmart_USA_14_April_2026.pdf", "state": "IN", "summary": "The Southern District of Indiana on 2026-04-14 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Cynthia White v. Walmart, Inc. Counsel filed a submission with one fabricated or AI-like submission item and one misstated record or submission point.", "text_sha256": "dac490ca61932542e3cde9d4f2727bfcd457923f90ca89aade8ddb907b5a5975", "topics": [ "fabricated-citations" ], "tracker_slug": "cynthia-white-v-walmart-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/insd-2026-cynthia-white-v-walmart", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-cynthia-white-v-walmart" }, { "ai_passage": "4th 737, 750, for the following quotation: “a judge may not act on personal knowledge of facts not presented in evidence or conduct an independent investigation of facts not in evidence. ” However, no such quotation appears in that case, or in any other case this court was able to locate. In addition to the other such instance in his opening brief identified above, T-Alexander's reply brief contains numerous similar fabricated quotations. The record also shows that T-Alexander acknowledged having included inaccurate citations in briefing in the trial court. We caution appellant that such conduct violates the California Rules of Court and Code of Civil Procedure, notwithstandingthefactthatheisunrepresented. (See,e.", "ai_tool_named": null, "archive_url": null, "case_name": "Michael T-Alexander v. Michelle Baass et al.", "citation": "2026 WL 1004593", "cited_authorities": [ "Tennessee v. Lane that do not appear in that opinion", "Appellant cited People v. Superior Court" ], "court": "California Court of Appeal, Sixth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-14", "decision_id": "calctapp6-2026-michael-t-alexander-v-michelle-baass", "disposition": "The court admonished the self-represented appellant for unverified or fabricated authorities and cautioned against repeating the citation misconduct.", "docket_number": "23CV01552", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented appellant filed a reply brief with one fabricated case citation and two false case quotations, including Tennessee v. Lane that do not appear in that opinion and People v. Superior Court.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1985/Alexander_v._Baas_USA_14_April_2026.pdf", "state": "CA", "summary": "The California Court of Appeal, Sixth District on 2026-04-14 admonished the self-represented appellant for unverified or fabricated authorities and cautioned against repeating the citation misconduct. The self-represented appellant filed a reply brief with one fabricated case citation and two false case quotations, including Tennessee v. Lane that do not appear in that opinion.", "text_sha256": "42155c3fbb290d9cfc50988e87eec8b50446bc1161635afee71074fbf7af3cbf", "topics": [ "fabricated-citations" ], "tracker_slug": "michael-t-alexander-v-michelle-baass-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp6-2026-michael-t-alexander-v-michelle-baass", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp6-2026-michael-t-alexander-v-michelle-baass" }, { "ai_passage": "The Court not found any such case and therefore finds Plaintiff has cited a nonexistent case. 6 Plaintiff fails to address Boyd in her reply despite Defendants directing Plaintiff’s attention to the error, ECF No. 24, pg. 4. Plaintiff instead asserts that “Plaintiff has not cited fictitious cases and there is no basis to infer bad faith from correctable citation defects. ” ECF No. 26, pg. 12. The Court agrees that any correctable citation defects do not necessarily indicate bad faith nor warrant sanctions, as previously addressed herein. However, Plaintiff declined to address the fictitious citation to Boyd despite Defendants raising the issue. Plaintiff had the opportunity to make the necessary corrections to her Boyd citation or take accountability for citing a nonexistent case, but instead claimed she “has not cited fictitious cases.", "ai_tool_named": null, "archive_url": null, "case_name": "Shaw v. City of Portola, et al.", "citation": null, "cited_authorities": [ "Plaintiff used an incorrect pinpoint citation to People v. Dang, citing page 1305 though the published opinion ends at page 1300, and relied on D", "Boyd v. City of San Diego, 14 Cal.App.4th 954, 959-960 (1993)", "Plaintiff initially cited State of Nevada v. US Dept. of Energy with incorrect reporter information", "Nevada v. United States Dep't of Energy, 133 F.3d 1201 (9th Cir. 1998)", "Plaintiff relied on Larson v. Domestic & Foreign Commerce Corp., 337 U.S. 682 (1949) to support the proposition that courts void or enjoin ultra" ], "court": "United States District Court for the Eastern District of California", "court_code": "caed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-14", "decision_id": "caed-2026-shaw-v-city-of-portola", "disposition": "The court ordered the self-represented plaintiff to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "2:25-CV-02461-DJC-DMC", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a reply brief with one fabricated case citation and five mischaracterized case citations, including People v. Dang and Boyd v. City of San Diego.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1993/Shaw_v._Portola_USA_15_April_2026.pdf", "state": "CA", "summary": "The Eastern District of California on 2026-04-14 ordered the self-represented plaintiff to show cause why sanctions or corrective action should not issue for the defective authorities in Shaw v. City of Portola, et al. The self-represented plaintiff filed a reply brief with one fabricated case citation and five mischaracterized case citations, including People v. Dang.", "text_sha256": "fa1c9382dd91765a09428dd13d355ed60385554a6681d4dd04d63d1d2c809ba2", "topics": [ "fabricated-citations" ], "tracker_slug": "shaw-v-city-of-portola-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/caed-2026-shaw-v-city-of-portola", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/caed-2026-shaw-v-city-of-portola" }, { "ai_passage": "” Prof. Cond. R. 8. 4(c)-(d). “It is well established that courts possess inherent authority to manage proceedings essential to their function, to control the conduct of those who appear before them, and to sanction conduct that abuses the judicial process. ” State v. Coleman, 2026-Ohio-965, ¶ 39 (11th Dist. ). Striking a filing containing fabricated and misplaced authority is an appropriate remedy a court could employ. See, id. at ¶103-104. 2 Appellant incorrectly cites R. C. 4511. 091 as the source for this rule. While R. C. 4511. 091 addresses the arrest of an individual based on radar and other devices, it does not place such a burden on the prosecution as Alqahtani claims. 3 Moreover, Alqahtani fails to offer any support for the notion that an officer must state the reason for a traffic stop before requesting identification from a driver, nor can we find any such requirement in the law to that effect.", "ai_tool_named": null, "archive_url": null, "case_name": "State of Ohio v. Abdullah M. Alqahtani", "citation": "2026-Ohio-1335", "cited_authorities": [ "State v. Coleman, 2026-Ohio-965, ¶ 39 (11th Dist" ], "court": "Ohio Court of Appeals, Third District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-13", "decision_id": "ohctapp3-2026-state-of-ohio-v-abdullah-m-alqahtani", "disposition": "The court affirmed the traffic conviction, assessed appellate costs, and noted that some of the appellant’s cited cases did not seem to exist.", "docket_number": "2-25-11", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented appellant filed a submission with one fabricated case citation, one mischaracterized case citation, and one misstated legal rule.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1983/Ohio_v._Alqahtani_USA_10_April_2026.pdf", "state": "OH", "summary": "The Ohio Court of Appeals, Third District on 2026-04-13 affirmed the traffic conviction, assessed appellate costs, and noted that some of the appellant’s cited cases did not seem to exist in State of Ohio v. Abdullah M. Alqahtani. The self-represented appellant filed a submission with one fabricated case citation, one mischaracterized case citation, and one misstated legal rule.", "text_sha256": "609ba4a86610cb4cf678022a1735636d3a4e3c9a92f889aeb6203493bb93c9f8", "topics": [ "fabricated-citations" ], "tracker_slug": "state-of-ohio-v-abdullah-m-alqahtani", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohctapp3-2026-state-of-ohio-v-abdullah-m-alqahtani", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohctapp3-2026-state-of-ohio-v-abdullah-m-alqahtani" }, { "ai_passage": "Hunt may re-raise his statute of limitations argument in a motion for summary judgment, if this action progresses to that stage. But a motion to dismiss can only be granted on a statute of limitations argument if the plaintiff’s own complaint makes evident that her claim falls outside of the prescribed time period. Allen’s complaint does not do that. III. Motion for Sanctions Hunt asks this Court to impose sanctions on Allen for submitting a brief citing a fabricated case. In her response to Hunt’s motion to stay, Allen included a citation to “Sterigenics U. S. , LLC v. Sotera Health Co. , 2020 WL 5645683 (N.", "ai_tool_named": null, "archive_url": null, "case_name": "Allen v. Hunt", "citation": null, "cited_authorities": [ "LLC v. Sotera Health Co. , 2020 WL 5645683 (N", "LLC v. Sotera Health Co., 2020 WL 5645683 (N.D. Ill. Sep. 22, 2020)\", which the Court found does not exist" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-13", "decision_id": "ilnd-2026-allen-v-hunt", "disposition": "The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.", "docket_number": "25-cv-02275", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a brief with two fabricated case citations, including LLC v. Sotera Health Co.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1987/Allen_v._Hunt_USA_13.pdf", "state": "IL", "summary": "The Northern District of Illinois on 2026-04-13 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Allen v. Hunt. The self-represented plaintiff filed a brief with two fabricated case citations, including LLC v. Sotera Health Co.", "text_sha256": "45138676c5ba81c10ae113d8e48aa8728b762d756d453d1a3dbaf0c5044c7f40", "topics": [ "fabricated-citations" ], "tracker_slug": "allen-v-hunt", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-allen-v-hunt", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-allen-v-hunt" }, { "ai_passage": "com/watch? v=oqSYljRYDEM. PAGE 3 – ORDER it is advisable to use AI tools to conduct legal research or draft legal briefs will explain that any legal authorities or legal analysis generated by AI need to be verified. Plaintiff opposes both Alyssa Alao and Kelsey Alao’s motions on two grounds. First, Plaintiff argues, Defendants did not include a certification or representation of conferral in their motions, as is required by Local Rule 7-1(a). Although the Court may reject a motion on the ground that it fails to comply with a local rule, it declines to do so here. The record otherwise indicates that the parties have conferred throughout the litigation.", "ai_tool_named": null, "archive_url": null, "case_name": "Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao", "citation": "2021 WL 5397472", "cited_authorities": [ "Hernandez v. Cnty. of Yamhill", "U.S. Bank Nat’l Ass’n v. Taylor", "Johns v. County of Douglas", "McNeil v. United States" ], "court": "United States District Court for the District of Oregon", "court_code": "ord", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-10", "decision_id": "ord-2026-steven-nemec-v-kelsey-kanoelani-alao-and-alyssa-jade-alao", "disposition": "The court granted the motions to dismiss, denied the motions to strike, allowed amendment, and warned that AI-generated legal authorities must be verified.", "docket_number": "3:26-cv-00083-SI", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented plaintiff filed a brief with four fabricated case citations, including Hernandez v. Cnty. of Yamhill and U.S. Bank Nat’l Ass’n v. Taylor.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1994/Nemec_v._Alao_USA_10_April_2026.pdf", "state": "OR", "summary": "The District of Oregon on 2026-04-10 granted the motions to dismiss, denied the motions to strike, allowed amendment, and warned that AI-generated legal authorities must be verified in Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao. The self-represented plaintiff filed a brief with four fabricated case citations, including Hernandez v. Cnty. of Yamhill.", "text_sha256": "c4250b0d869bdbf9d5eb7ee16f65b42b99d3c6f3cbfbd28f65164196a0eeb5b2", "topics": [ "fabricated-citations" ], "tracker_slug": "steven-nemec-v-kelsey-kanoelani-alao-and-alyssa-jade-alao", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ord-2026-steven-nemec-v-kelsey-kanoelani-alao-and-alyssa-jade-alao", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ord-2026-steven-nemec-v-kelsey-kanoelani-alao-and-alyssa-jade-alao" }, { "ai_passage": "We recently addressed a similar scenario where a pro se litigant submitted a filing to this Court that cited to non-existent cases, as well as cited to actual cases which did not stand for the legal propositions asserted in the filing. See Hessert v. Hessert, No. 6D2026-0121, 2026 WL 785016 (Fla. 6th DCA Mar. 20, 2026). In Hessert, we acknowledged that “[c]ourts across the United States, including Florida’s appellate courts, are currently grappling with an influx of court filings “Generative AI[—i. e. , generative artificial intelligence—]are deep-learning models that compile data to generate statistically probable outputs when prompted. . . . Generative AI can create original images, analyze documents, and draft briefs based on written prompts. Often, these programs rely on large language models.", "ai_tool_named": null, "archive_url": null, "case_name": "Bruno Roberto Rodriguez v. Kathryn Louise Rodriguez", "citation": "2026 WL 785016", "cited_authorities": [ "See Hessert v. Hessert, No. 6D2026-0121, 2026 WL 785016 (Fla" ], "court": "Florida District Court of Appeal, Sixth District", "court_code": null, "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-04-10", "decision_id": "fladistctapp6-2026-bruno-roberto-rodriguez-v-kathryn-louise-rodriguez", "disposition": "The court ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities.", "docket_number": "6D2025-3086 Lower Tribunal No. 2025-DR-002837-O", "document_type": "order", "fetched_at": "2026-09-07T14:34:17-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel filed a brief with one fabricated case citation and one mischaracterized case citation.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1974/Rodriguez_v._Rodriguez_USA_10_April_2026.pdf", "state": "FL", "summary": "The Florida District Court of Appeal, Sixth District on 2026-04-10 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities in Bruno Roberto Rodriguez v. Kathryn Louise Rodriguez. Counsel filed a brief with one fabricated case citation and one mischaracterized case citation.", "text_sha256": "cba1c154dba28a6853284ee79aee89ee61d2e18781f7c68a4734eb4e1fae08d5", "topics": [ "fabricated-citations" ], "tracker_slug": "bruno-roberto-rodriguez-v-kathryn-louise-rodriguez", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp6-2026-bruno-roberto-rodriguez-v-kathryn-louise-rodriguez", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp6-2026-bruno-roberto-rodriguez-v-kathryn-louise-rodriguez" }, { "decision_id": "lawb-2026-in-re-troylond-malon-wise", "case_name": "In re Troylond Malon Wise", "court": "U.S. Bankruptcy Court for the Western District of Louisiana", "court_code": "lawb", "court_level": "federal-bankruptcy", "state": "LA", "date_filed": "2026-04-09", "citation": null, "docket_number": "25-51132", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court struck counsel’s objection and supplemental response, imposed a $2,750 sanction, ordered AI-focused CLE, and barred further filings until compliance.", "ai_passage": "the underlying promissory note.” 2 Regardless of what Ms. Wilson may have intended by citing to In re Garcia, the Court finds that her failure to review and verify the AI-generated Objection caused her to file a false and misleading pleading in this Court. Ms. Wilson also acknowledges that her Supplemental Response (ECF # 67) contains an AI-generated case citation to In re Buttermilk Towne LLC which does not resolve to any opinion. In her Response to the Court’s Show Cause Order, she supplies what she claims is the correct citation but notes that even the correctly cited case “is not applicable to the legal argument which is correctly noted in Veal.” 3 Similarly, she admits that her Supplemental Response cites to La. R.S. § 9:5774, a statute that does not exist, and she claims that she should have cited to La. Civ. Code art. 3357, et seq., concerning the reinscription of mortgages. 4 Notwithstanding Ms. Wilson’s explanations, her failure to review and verify the admittedly AI-generated See Response, p. 1 (ECF #79). Id., p. 2. Id. Id. 25-51132 - #84 File 04/09/26 Enter 04/09/26 14:12:22 Main Document Pg 2", "cited_authorities": [], "summary": "On 2026-04-09, U.S. Bankruptcy Court for the Western District of Louisiana struck counsel’s objection and supplemental response, imposed a $2,750 sanction, ordered AI-focused CLE, and barred further filings until compliance. Counsel submitted a filing with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities, including In re Garcia and In re Buttermilk Towne LLC.", "incident": { "conduct": "The filing used nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities, including In re Garcia and In re Buttermilk Towne LLC, which the court found nonexistent, misquoted, or unsupported.", "outcome": "sanctions", "actor": "lawyer", "monetary_penalty": 2750, "currency": "USD", "ai_tool": null }, "tracker_slug": "in-re-troylond-malon-wise", "courtlistener_url": null, "text_sha256": "686775245707d220884c4043d68913e6524ffc0b54ca91be37a5b81af6b73d37", "source_url": "https://www.damiencharlotin.com/documents/1989/In_re_Troylond_USA_9_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/lawb-2026-in-re-troylond-malon-wise", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/lawb-2026-in-re-troylond-malon-wise" }, { "decision_id": "ilnd-2026-delliane-chinedu-obi-v-cook-county-illinois", "case_name": "Ifeoma Delliane Chinedu Obi v. Cook County, Illinois, et al. (1)", "court": "U.S. District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "state": "IL", "date_filed": "2026-04-09", "citation": null, "docket_number": "25 C 3096", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court struck the motion and imposed a $4,999 sanction for repeated AI-generated fake cases, quotations, and statements of law and fact.", "ai_passage": "such possibility. Plaintiff generated each brief using AI. Plaintiff’s motion is riddled with AI hallucinations, made up cases, quotes, and statements of law and fact. (Dkt. 90); (see also Dkt. 92-1) (identifying 13 hallucinated cases, quotes, and statements of law). For example, Plaintiff quotes Marshall v. Marshall, 547 U.S. 293 (2006) for the rule that “Federal courts may exercise jurisdiction even when the case touches upon matters traditionally reserved to state law, where federal rights are at issue.” (Dkt. 90 at 3). That quoted language is not in Marshall. Plaintiff cites Andrade v. Arby Concessions, 88 F.4th 1014, 1018 (7th Cir. 2023) to dispute the Court’s Order dismissing her complaint. (Dkt. 90 at 6). “Andrade” is not a real case. Plaintiff’s reliance on AI hallucinations is not limited to made up cases either. Plaintiff conjures up new language from this Court’s prior orders as well. Plaintiff asserts that “Page 7 [of the Court’s November 18, 2025, Order] explicitly references that ‘a federal court may hear a claim alleging a state court judgment is void for lack of jurisdiction,’ which is precisely the central and repeated allegation raised by Plaintiff.” (Dkt.", "cited_authorities": [], "summary": "On 2026-04-09, U.S. District Court for the Northern District of Illinois struck the motion and imposed a $4,999 sanction for repeated AI-generated fake cases, quotations, and statements of law and fact. A self-represented party submitted a complaint with 13 false quotations and fabricated or nonexistent authorities, including Marshall v. Marshall and Andrade v. Arby Concessions.", "incident": { "conduct": "The complaint used 13 false quotations and fabricated or nonexistent authorities, including Marshall v. Marshall and Andrade v. Arby Concessions, which the court found nonexistent, misquoted, or unsupported.", "outcome": "sanctions", "actor": "litigant-in-person", "monetary_penalty": 4999, "currency": "USD", "ai_tool": null }, "tracker_slug": "ifeoma-delliane-chinedu-obi-v-cook-county-illinois-et-al-1", "courtlistener_url": null, "text_sha256": "3055cd68b8e389806de41572a2b4b90bd0b9f5a434fa63f13386b7fa3d282898", "source_url": "https://www.damiencharlotin.com/documents/1982/gov.uscourts.ilnd.475370.97.0.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-delliane-chinedu-obi-v-cook-county-illinois", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-delliane-chinedu-obi-v-cook-county-illinois" }, { "decision_id": "illappct-2026-robert-s-hulvat-v-juli-gumina-stg", "case_name": "Robert S. Hulvat v. Juli Gumina, STG Divorce Law, and Jennifer B. Hulvat", "court": "Illinois Appellate Court, Third District", "court_code": "illappct", "court_level": "state-appellate", "state": "IL", "date_filed": "2026-04-09", "citation": "2026 IL App (3d) 240628-U", "docket_number": "3-24-0628", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied dismissal and striking of the appellate brief but awarded appellees $3,178 in attorney fees for responding to the AI-produced brief.", "ai_passage": "Robert to show cause as to why he Boy, 2025 IL App (4th) 241427, ¶ 57. Our supreme should not be sanctioned based on his violations of Illinois court's policy authorizes the use of AI when compliant Supreme Court rules and AI policy by citing nonexistent with legal and ethical standards. Ill. Sup. Ct., Illinois authorities and fictitious holdings in his appellate brief. Supreme Court Policy on Artificial Intelligence (Jan. 1, Before us are defendants Gumina and STG's request to strike 2025), https://ilcourtsaudio.blob.core.windows.net/antilles- Robert's brief and their petition for attorney fees. resources/resources/ e43964ab-8874-4b7abe4e-63af019cb6f7/Illinois ¶ 29 Robert's initial brief included citations to nine %20Supreme%20Court%20AI%20Policy.pdf (AI Policy). nonexistent cases (Bjorlin v. Aluminum Co. of America, 261 To adhere to these standards, the policy forewarns that “[a]ll Ill. App. 3d 552 (1994); In re Estate of Drawve, 119 Ill. App. users must thoroughly review AI-generated content before 2d 487 (1970); In re Marriage of Lewis, 213 Ill. App. 3d submitting it in any court proceeding,” that “[u]nsubstantiated 1042 (1991); In re Marriage of Royster, 278 Ill. App. 3d *** AI-generated content that *** obscures truth-finding ROBERT S. HULVAT, Plaintiff-Appellant, v. JULI GUMINA,..., Not", "cited_authorities": [], "summary": "On 2026-04-09, Illinois Appellate Court, Third District denied dismissal and striking of the appellate brief but awarded appellees $3,178 in attorney fees for responding to the AI-produced brief. A self-represented party submitted an appellate brief with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including In re Marriage of Lehr.", "incident": { "conduct": "The appellate brief used multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including In re Marriage of Lehr, which the court found nonexistent, misquoted, or unsupported.", "outcome": "sanctions", "actor": "litigant-in-person", "monetary_penalty": 3178, "currency": "USD", "ai_tool": null }, "tracker_slug": "robert-s-hulvat-v-juli-gumina-stg-divorce-law-and-jennifer-b-hulvat", "courtlistener_url": null, "text_sha256": "7906e9f9891ab149b0e24b93f1a39f8b738331fe6da74daa64d102ea513b689a", "source_url": "https://www.damiencharlotin.com/documents/1966/Hulvat_v._Gumina_USA_9_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/illappct-2026-robert-s-hulvat-v-juli-gumina-stg", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illappct-2026-robert-s-hulvat-v-juli-gumina-stg" }, { "decision_id": "flsd-2026-joseph-c-zoghaib-v-societe-generale-de", "case_name": "Joseph C. Zoghaib v. Societe Generale De Banque Au Liban, et al.", "court": "U.S. District Court for the Southern District of Florida", "court_code": "flsd", "court_level": "federal-district", "state": "FL", "date_filed": "2026-04-08", "citation": "2026 WL 943756", "docket_number": "25-CV-20097-MOORE/Elfenbein Zoghaib alleg", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court recommended staying discovery and mediation pending two motions to dismiss and warned that the plaintiff’s FSIA discovery authorities did not support the cited propositions.", "ai_passage": "SOCIETE GENERALE DE..., Slip Copy (2026) The Court ends its analysis by noting that, in his Responses, IV. CONCLUSION Zoghaib cites to various cases for certain propositions that *7 For the reasons explained above, I respectfully do not support his arguments, leading the Court to suspect RECOMMEND that BdL's Motion to Stay, ECF No. [75] that Zoghaib used artificial intelligence (“AI”) to write them. be GRANTED; SGBL's Motion to Stay, ECF No. [78], be For example, Zoghaib repeatedly cites to Meier ex rel. Meier GRANTED; and that discovery and mediation in this matter v. Sun Int'l Hotels, Ltd., 288 F.3d 1264, 1274 (11th Cir. be stayed until resolution of BdL's Motion to Dismiss, ECF 2002) to support his argument that “FSIA immunity does not No. [72], and SGBL's Motion to Dismiss, ECF No. [81]. bar jurisdictional discovery where the commercial-activity exception is invoked or jurisdictional facts are disputed.” See The Parties will have fourteen (14) days from the date of ECF No. [97] at 1. However, the Meier decision involves being served with a copy of this Report and Recommendation a dismissal for lack of personal jurisdiction, making no within", "cited_authorities": [], "summary": "On 2026-04-08, U.S. District Court for the Southern District of Florida recommended staying discovery and mediation pending two motions to dismiss. A self-represented party submitted a response brief with The response brief cited FSIA discovery authorities, including In re Clerici, for propositions those authorities did not support.", "incident": { "conduct": "The response brief cited FSIA discovery authorities, including In re Clerici, for propositions those authorities did not support.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "joseph-c-zoghaib-v-societe-generale-de-banque-au-liban-et-al", "courtlistener_url": null, "text_sha256": "e587def47fa1516dfad08b95b8877d2f344455d3f0edd23267dfa2b2f71e6f1f", "source_url": "https://www.damiencharlotin.com/documents/1967/Zoghaib_v._Bank_Liban_USA_8_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/flsd-2026-joseph-c-zoghaib-v-societe-generale-de", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flsd-2026-joseph-c-zoghaib-v-societe-generale-de" }, { "decision_id": "bap8-2026-tahnee-r-young-v-happy-money", "case_name": "James C. Young; Tahnee R. Young v. Happy Money", "court": "U.S. Bankruptcy Appellate Panel for the Eighth Circuit", "court_code": "bap8", "court_level": "federal-bankruptcy", "state": null, "date_filed": "2026-04-08", "citation": null, "docket_number": "25-6011", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed the bankruptcy court’s order limiting one debtor’s advocacy for the other and noted that several cited bankruptcy cases did not exist or support the argument.", "ai_passage": "2012), was retrieved. The Swanson case begins on page 495 of volume 475 of the Bankruptcy Reporter and ends on page 535. The case concerns a Uniform Commercial Code issue, not the imposition of sanctions for discovery violations as argued by the Debtors in their brief. The citation for In re Cherrett, 873 F.3d 1060 (9th Cir. 2017), did retrieve the In re Cherrett case; however, the case involves the issue of whether the purchase of a second residence was a business debt or a consumer debt and does not involve sanctions against an attorney as stated by the Debtors in their brief. nonexistent cases is the type of harm rules governing the unauthorized practice of law are designed to prevent. CONCLUSION For the reasons stated above, we find the bankruptcy court did not err in denying the Debtors’ Motion to the extent that James Young was seeking to represent Tahnee Young or advocate on her behalf in a bankruptcy proceeding that relates solely to her debt and involves alleged violations of the automatic stay that relate solely to efforts to collect a debt from Tahnee Young. 5 Nor did", "cited_authorities": [], "summary": "On 2026-04-08, U.S. Bankruptcy Appellate Panel for the Eighth Circuit affirmed the bankruptcy court’s order limiting one debtor’s advocacy for the other and noted that several cited bankruptcy cases did not exist or support the argument. A self-represented party submitted a motion with fabricated or nonexistent authorities and mischaracterized authorities, including In re Cherrett and In re Pringle.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities and mischaracterized authorities, including In re Cherrett and In re Pringle, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "james-c-young-tahnee-r-young-v-happy-money", "courtlistener_url": null, "text_sha256": "b18cb0570d1840225aabba8202e9a4ea41c106710428c98064efa07f64d5309e", "source_url": "https://www.damiencharlotin.com/documents/1945/Young_v._Happy_Money_USA_8_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/bap8-2026-tahnee-r-young-v-happy-money", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/bap8-2026-tahnee-r-young-v-happy-money" }, { "decision_id": "alnd-2026-pleasant-v-burns", "case_name": "Pleasant v. Burns", "court": "U.S. District Court for the Northern District of Alabama", "court_code": "alnd", "court_level": "federal-district", "state": "AL", "date_filed": "2026-04-08", "citation": "2026 WL 948793", "docket_number": "2:25-cv-1658-ACA error in her email addre", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the case without prejudice after the plaintiff ignored orders to address Rule 11 concerns about nonexistent cases and fabricated quotations.", "ai_passage": "Defendants Laura Burns, Autumn Caudell, and the Alabama intentional or in bad faith cannot be supported by the fact State Bar alleging constitutional and state law violations. that she was unaware that Ms. Burns brought these errors to (Doc. 1). Ms. Pleasant later filed multiple documents that the court's attention. After all, Ms. Pleasant's “inaccuracies included nonexistent cases, fabricated case quotations, and or deficiencies” occurred before Ms. Burns responded and misstatements of the holdings of cases, and the court ordered existed regardless of Ms. Burns's notice of them. her to show cause why it should not impose sanctions under Federal Rule of Civil Procedure 11. Ms. Pleasant has Because of the error in her email address, the court extended repeatedly ignored the court's orders. The court therefore Ms. Pleasant's deadline to respond by an additional week. WILL DISMISS this case WITHOUT PREJUDICE. (Doc. 20). The order again instructed Ms. Pleasant that “the order to show cause requires her to specifically address each I. BACKGROUND potential Rule 11 violation that the court outlined” in its Ms. Burns moved to dismiss Ms. Pleasant's complaint. (Doc. previous order. (Id.). The order also directed Ms. Pleasant to 6). Ms. Pleasant responded to Ms. Burns's motion. (Doc. 10). file a notice with the court when she received the court's order. Ms. Pleasant's response misrepresented the law, which Ms. (Id.). In addition to electronic notification, the court mailed Burns highlighted in her reply. (Doc. 13 at 2–5). Roughly a the order to Ms. Pleasant. month later, Ms. Pleasant moved for a preliminary injunction.", "cited_authorities": [], "summary": "On 2026-04-08, U.S. District Court for the Northern District of Alabama dismissed the case without prejudice after the plaintiff ignored orders to address Rule 11 concerns about nonexistent cases and fabricated quotations. A self-represented party submitted a complaint with at least one false quotations, fabricated or nonexistent authorities and mischaracterized authorities.", "incident": { "conduct": "The complaint used at least one false quotations, fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "pending", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "pleasant-v-burns", "courtlistener_url": null, "text_sha256": "1dc6156cd442e6a3489b8ee9233bbc812ef0ce86dde1cbb8904918ad1e60a041", "source_url": "https://www.damiencharlotin.com/documents/1946/Pleasant_v._Burns_USA_8_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/alnd-2026-pleasant-v-burns", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alnd-2026-pleasant-v-burns" }, { "decision_id": "pacommwct-2026-nancy-parkinson-v-unemployment-compensation-board", "case_name": "Nancy Parkinson v. Unemployment Compensation Board of Review", "court": "Commonwealth Court of Pennsylvania", "court_code": "pacommwct", "court_level": "state-appellate", "state": "PA", "date_filed": "2026-04-07", "citation": null, "docket_number": "1776 C.D. 2024", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed the unemployment board and declined to consider the claimant’s recoupment argument because it relied on a nonexistent case and a misplaced statute.", "ai_passage": "CHRISTINE FIZZANO CANNON, Judge Beck v. Unemployment Comp. Bd. of Rev. (Pa. Cmwlth., No. 459 C.D. 2013, filed September 11, 2013). This Court declines to consider Claimant’s final argument that the “Board’s decision to deduct from [Claimant’s] Social Security benefits to recover previously approved funds violates fundamental due process principles and conflicts with 43 P.S. § 874, which prohibits unjust enrichment . . . .” Claimant’s Br. at 8. Claimant cites a non-existent case to support her position that “[t]he premature recoupment of benefits before a final determination is contrary to Pennsylvania precedent,” and her reliance on Section 874 of the UC Law, 43 P.S. § 874, is misplaced. IN THE COMMONWEALTH COURT OF PENNSYLVANIA Nancy Parkinson, : Petitioner : : v. : : Unemployment Compensation : Board of Review, : No. 1776 C.D. 2024 Respondent : ORDER AND NOW, this 7th day of April, 2026, the November 26, 2024 order of the Unemployment Compensation Board of Review is AFFIRMED. __________________________________ CHRISTINE FIZZANO CANNON, Judge", "cited_authorities": [], "summary": "On 2026-04-07, Commonwealth Court of Pennsylvania affirmed the unemployment board and declined to consider the claimant’s recoupment argument because it relied on a nonexistent case and a misplaced statute. A self-represented party submitted a petition with fabricated or nonexistent authorities, including Beck v. Unemployment Comp. Bd. of Rev.", "incident": { "conduct": "The petition used fabricated or nonexistent authorities, including Beck v. Unemployment Comp. Bd. of Rev, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "nancy-parkinson-v-unemployment-compensation-board-of-review", "courtlistener_url": null, "text_sha256": "c47e24abb37450a6afb5634da432622415be857d6db6a028ecdd19c3ed5cbe12", "source_url": "https://www.damiencharlotin.com/documents/1935/Parkison_v._Board_uSA_3_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/pacommwct-2026-nancy-parkinson-v-unemployment-compensation-board", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pacommwct-2026-nancy-parkinson-v-unemployment-compensation-board" }, { "decision_id": "okwd-2026-blackburn-v-united-states", "case_name": "Blackburn v. United States", "court": "U.S. District Court for the Western District of Oklahoma", "court_code": "okwd", "court_level": "federal-district", "state": "OK", "date_filed": "2026-04-07", "citation": null, "docket_number": "CIV-22-983-G", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the motion in limine and warned that the plaintiff’s mischaracterized treating-physician authorities implicated Rule 11.", "ai_passage": "At a minimum, Plaintiff’s cited authority fails to demonstrate an entitlement to relief on the merits of her Motion. In addition, such mischaracterizations of case law, whether or not the product of generative artificial intelligence, implicate consideration of Plaintiff’s representations for purposes of Federal Rule of Civil Procedure 11(b) and (c). See Clark v. CoreCivic, Inc., No. CIV-25-775-SLP, 2025 WL 3709023, at *2 n.2 (W.D. Okla. Dec. 22, 2025). As recently explained by the Tenth Circuit, pro se litigants have “the responsibility to ensure that citations to legal authority are not fabrications but instead point to real cases that at least arguably stand for the propositions for which they are cited.” Dodds v. Bridges, No. 25-7021, 2026 WL 380194, at *6 (10th Cir. Feb. 11, 2026). CONCLUSION For the foregoing reasons, Plaintiff’s Motion in Limine (Doc. No. 135) is DENIED. IT IS SO ORDERED this 7th day of April, 2026.", "cited_authorities": [], "summary": "On 2026-04-07, U.S. District Court for the Western District of Oklahoma denied the motion in limine and warned that the plaintiff’s mischaracterized treating-physician authorities implicated Rule 11. A self-represented party submitted a motion with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hall v. United States and Poppino v. Berryhill, an unrelated decision.", "incident": { "conduct": "The motion used false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hall v. United States and Poppino v. Berryhill, an unrelated decision, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "blackburn-v-united-states", "courtlistener_url": null, "text_sha256": "64e436665bd74d2716923fdbd0b682e9b55a4791f96c9c0622c7db7261133638", "source_url": "https://www.damiencharlotin.com/documents/1965/Blackburn_v_m5HCIWT._USA_USA_7_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/okwd-2026-blackburn-v-united-states", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/okwd-2026-blackburn-v-united-states" }, { "decision_id": "nvd-2026-sims-v-souily-lefave", "case_name": "Sims v. Souily-Lefave (1)", "court": "U.S. District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "state": "NV", "date_filed": "2026-04-07", "citation": "2026 WL 948233", "docket_number": "2:24-cv-00831-CDS-EJY that", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the discovery motions and warned the plaintiff that unchecked AI-generated or unsupported citations could expose her to Rule 11 sanctions.", "ai_passage": "is not an Motion; however, the Court finds such efforts would be futile attorney, offers arguments not germane to the issue of her and, thus, this failure is not a basis to deny Plaintiff's Motion. refusal to proceed with answering questions at her deposition, It is true that Defendants had previously filed a Motion to and contends defense counsel improperly made threats of Compel; however, Defendants offer no law supporting their sanctions (id. at 8-9), which the Court warned Plaintiff could contention that Plaintiff cannot file a motion for protective be sought if her deposition did not proceed. ECF No. 172 at order in response to a motion to compel. Plaintiff's Reply 13-14. (ECF No. 184) is off point (discussing defense counsel's pro hac vice filing, contending her Motion for Protective Plaintiff cites case law that must be AI generated. See EFC Order was “administrative,” and discussing the importance of No. 175 at 10 and compare Plaintiff's citations to (1) Cruz protective orders). ECF No. 184 at 3, 4, 6-8. To the extent v. Fox, 202 F.R.D. 419, 423 (N.D. Ill 2001) (allegedly Plaintiff contends she adequately met and conferred", "cited_authorities": [], "summary": "On 2026-04-07, U.S. District Court for the District of Nevada denied the discovery motions and warned the plaintiff that unchecked AI-generated or unsupported citations could expose her to Rule 11 sanctions. A self-represented party submitted a motion with The motion cited fabricated or mischaracterized discovery cases, including Cruz and DuPont authorities, for propositions the cases did not support.", "incident": { "conduct": "The motion cited fabricated or mischaracterized discovery cases, including Cruz and DuPont authorities, for propositions the cases did not support.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "sims-v-souily-lefave-1", "courtlistener_url": null, "text_sha256": "d97a18a7e0a0837ea43ba0b0e3d1014c79abaab2afbbdbcc398999bc560740a3", "source_url": "https://www.damiencharlotin.com/documents/1942/Sims_v._Souilly-Lefave_USA_7_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nvd-2026-sims-v-souily-lefave", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-sims-v-souily-lefave" }, { "decision_id": "cand-2026-thanh-nguy-v-jabil", "case_name": "Thanh Nguy v. Jabil Inc.", "court": "U.S. District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "state": "CA", "date_filed": "2026-04-07", "citation": null, "docket_number": "24-cv-06798-EKL (VKD)", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court declined to sanction counsel after a corrected brief was filed, but warned all parties to verify the existence and accuracy of cited authorities.", "ai_passage": "of the bar of this Court to “comply with the standards of professional conduct required of members of the State Bar of California.” Civil L.R. 11-4(a)(1). Under California Rule of Professional Conduct 3.3, lawyers have a duty of candor, which prohibits a lawyer from “knowingly mak[ing] a false statement of fact or law to a tribunal[.]” On this record, the Court is concerned that Mr. Nguy’s counsel may have relied on AI to identify legal authorities and did not exercise care in ensuring that that fictitious AI-generated legal authorities were not included in Mr. Nguy’s opposition filed with the Court. However, Ms. Masoom promptly corrected the claimed erroneous filing, and, at the motion hearing, she confirmed that she and her firm have taken steps to ensure that this situation does not occur again. The Court therefore declines to impose any sanctions. However, all parties are reminded that the failure to confirm or double-check the accuracy, veracity, or even existence of a case or legal citation (or assertion of fact), whether created by an AI tool or otherwise, is grounds for potential sanctions. United States District Court III. CONCLUSION For the", "cited_authorities": [], "summary": "On 2026-04-07, U.S. District Court for the Northern District of California declined to sanction counsel after a corrected brief was filed, but warned all parties to verify the existence and accuracy of cited authorities. Counsel submitted an opposition brief with fabricated or nonexistent authorities.", "incident": { "conduct": "The opposition brief used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "warning", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "thanh-nguy-v-jabil-inc", "courtlistener_url": null, "text_sha256": "39458b7193ef04bfbe87e4071d63452b4f6e88297fda9c1e6e27c80d405f4a11", "source_url": "https://www.damiencharlotin.com/documents/1943/Nguy_v_Jabil_Inc_USA_7_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/cand-2026-thanh-nguy-v-jabil", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-thanh-nguy-v-jabil" }, { "decision_id": "orctapp-2026-kelly-bartholomew-v-public-utility-commission", "case_name": "Kelly Bartholomew v. Public Utility Commission of Oregon", "court": "Oregon Court of Appeals", "court_code": "orctapp", "court_level": "state-appellate", "state": "OR", "date_filed": "2026-04-06", "citation": null, "docket_number": "Order No. 25-125", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the judicial-review petition after the petitioner failed to explain fabricated AI-sourced citations in her opening brief and show-cause response.", "ai_passage": "still failed to acknowledge the egregiousness of her conduct and, instead, continued to minimize it. Nothing in petitioner’s response to the show cause order demonstrates, even an attempt at, transparency. Petitioner continued to avoid explaining how any of the fabricated case citations came to be, despite the fact that they are clearly the type of fake legal authority fabricated by artificial intelligence (AI) that the court has recently sanctioned. See Ringo, 345 Or App 301; Powell, 347 Or App 55. Petitioner attached to her response to the show cause order a copy of an email correspondence between herself and an assistant at the Law Library of Clackamas County, which demonstrate that petitioner had informed the library assistant that the case citations came from petitioner’s use of AI. Despite the emails, in her response to the show cause order petitioner maintained her vague argument that she used “secondary sources” to draft the brief. The court agrees with PGE that “to the extent that Petitioner’s non-existent citations resulted from the use of artificial intelligence (AI), she did not rely on a secondary source” and that petitioner’s “lack of transparency and candor should", "cited_authorities": [], "summary": "On 2026-04-06, Oregon Court of Appeals dismissed the judicial-review petition after the petitioner failed to explain fabricated AI-sourced citations in her opening brief and show-cause response. A self-represented party submitted a petition with 10 fabricated or nonexistent authorities, including Ass’n v. Washington County, 309 Or App 112, 124-25, 482 P3d 827.", "incident": { "conduct": "The petition used 10 fabricated or nonexistent authorities, including Ass’n v. Washington County, 309 Or App 112, 124-25, 482 P3d 827, which the court found nonexistent, misquoted, or unsupported.", "outcome": "dismissal", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "kelly-bartholomew-v-public-utility-commission-of-oregon", "courtlistener_url": null, "text_sha256": "caf9e90965dabaca4f7c9e1c8393a49c6963b63783a867ca026dd895ed1fe14f", "source_url": "https://www.damiencharlotin.com/documents/1934/Kelly_Bartholomew_v_Public_Utility_Commission_of_Oregon_USA_6_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/orctapp-2026-kelly-bartholomew-v-public-utility-commission", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/orctapp-2026-kelly-bartholomew-v-public-utility-commission" }, { "decision_id": "nysd-2026-viral-bhagat-v-anuja-sharad-shah", "case_name": "Viral Bhagat v. Anuja Sharad Shah", "court": "U.S. District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "state": "NY", "date_filed": "2026-04-06", "citation": null, "docket_number": "P. 16(b)(4)(E)(i). (ECF 639", "document_type": "report-and-recommendation", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court admonished the self-represented defendant to verify that cited cases exist and support the propositions asserted in future AI-assisted filings.", "ai_passage": "motion to dismiss for failure to state a claim. Nor was I able to locate the quoted text in any case available on Westlaw. I therefore conclude that the citation is an AI-generated hallucination. I understand the difficulties of litigating pro se and the reasons why a pro se litigant might choose to use AI- generated filings. However, Defendant is admonished that pro se litigants are obligated to review the cases cited in their filings to confirm that they exist and stand for the proposition for which they are cited. 7. I issued an order (ECF 656) directing Plaintiff to refile his Exhibit 1 attached to ECF 652, which was to be a redacted version of the document at ECF 644-2. However, upon further examination of the voluminous docket, it appears that an unredacted version of the document is already on the docket and has been on the docket at ECF 572-32 since November 14, 2025. Nor did Plaintiff ever make an application to have ECF 572-32 sealed in the nearly five months it has been on the docket. Accordingly, the document at ECF 644-2 shall be unsealed. See Gambale", "cited_authorities": [], "summary": "On 2026-04-06, U.S. District Court for the Southern District of New York admonished the self-represented defendant to verify that cited cases exist and support the propositions asserted in future AI-assisted filings. A self-represented party submitted a motion with false quotations and fabricated or nonexistent authorities, including In re SunEdison, Inc. Sec. Litig.", "incident": { "conduct": "The motion used false quotations and fabricated or nonexistent authorities, including In re SunEdison, Inc. Sec. Litig, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "viral-bhagat-v-anuja-sharad-shah", "courtlistener_url": null, "text_sha256": "65ef63db0cfdc02e9fcf95ba5dc21bb9277c6f211343bd3425efc96eb0c6e80d", "source_url": "https://www.damiencharlotin.com/documents/1959/Bhagat_v._Shah_USA_6_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nysd-2026-viral-bhagat-v-anuja-sharad-shah", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-viral-bhagat-v-anuja-sharad-shah" }, { "decision_id": "nvd-2026-and-rebecca-knepp-v-dan-heinrich-and", "case_name": "Wendy Wolkenstein and Rebecca Knepp v. Dan Heinrich and Samual Tillery", "court": "U.S. District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "state": "NV", "date_filed": "2026-04-06", "citation": null, "docket_number": "2:25-cv-01138-APG-NJK", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted default judgment in part, denied paralegal costs, and warned the plaintiffs that fake AI-drafted cases may lead to sanctions.", "ai_passage": "in briefs, usually as the result of using generative AI software, like ChatGPT, to draft court filings. Johnson v. MINI of Las Vegas, No. 2:25-cv-00725-APG-EJY, 2025 WL 2718525, at *3 (D. Nev. Sept. 24, 2025). Generative AI often invents fake cases and legal precedent, and using it is no excuse to not verify the veracity of citations. Having to research fake authority and spend time chasing down what is not a real case wastes the court’s time and resources. Going forward, the plaintiffs are warned of their duty under Rule 11(b)(2) and that citing fake cases drafted by generative AI may violate this rule. Failure to comply in the future may result in sanctions, such as an order to pay a penalty into the court, or nonmonetary directives. Fed. R. Civ. P. 11(c)(4). Despite these shortcomings, the plaintiffs’ motion satisfies the factors set forth in Eitel v. McCool, 782 F.2d 1470, 1471-72 (9th Cir. 1986). Default has been entered against the defendants. ECF No. 12. I thus find good cause to grant the motion in part. I decline to award the plaintiffs their paralegal costs because those are ordinarily not", "cited_authorities": [ "Fed. R. Civ. P. 11(c)(4)" ], "summary": "On 2026-04-06, U.S. District Court for the District of Nevada granted default judgment in part, denied paralegal costs, and warned the plaintiffs that fake AI-drafted cases may lead to sanctions. A self-represented party submitted a motion with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities.", "incident": { "conduct": "The motion used nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities, including Stanley v. University of Southern California and Shum v. Intel Corp, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "wendy-wolkenstein-and-rebecca-knepp-v-dan-heinrich-and-samual-tillery", "courtlistener_url": null, "text_sha256": "ae87947088851eb29cce9000950cfa577252ae8241f7f5c9d13930b9f9dad085", "source_url": "https://www.damiencharlotin.com/documents/1940/Wolkenstein_et_al_v_Heinrich_et_al_USA_6_APril_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nvd-2026-and-rebecca-knepp-v-dan-heinrich-and", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-and-rebecca-knepp-v-dan-heinrich-and" }, { "decision_id": "mied-2026-hardy-v-genesee-county-community", "case_name": "Hardy v. Genesee County Community Action Resource Department, et al. (2)", "court": "U.S. District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "state": "MI", "date_filed": "2026-04-06", "citation": null, "docket_number": "24-11190", "document_type": "report-and-recommendation", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court struck the motion to consolidate and gave the plaintiff a final warning after he repeated fake quotations following an earlier AI-citation sanction order.", "ai_passage": "R&R explained, “Courts and opposing counsel are [ ] burdened by the careless use of AI by pro se filers.” Hardy v. Whitaker, ___ F.R.D. ___ 2026 WL 575225, at *10. Hardy apologized for his “inclusion of inaccurate citations generated by an AI tool” in his objections to the R&R. Case No. 24-cv-11270, ECF No. 213, PageID.2430. But he repeated the same offense in his motion to consolidate. More recently, the Sixth Circuit emphasized that the “even a single fake case can be sanctionable” and that “citing fake cases can harm the reputation of judges and courts whose names are falsely invoked as authors of the bogus opinions and the reputation of a party attributed with fictional conduct.” Whiting City of Athens Tennessee, ___ F. 4th ___, 2026 WL 710568, at *4 (6th Cir. Mar. 13, 2026) (cleaned up). Thus, district courts may sanction the misuse of AI under Federal Rule of Civil Procedure and their inherent authority. Id. at *5. Hardy’s misuse of AI in his motion to consolidate is not his only repeat transgression. The R&R in Hardy v. Whitaker also discussed how he had filed umpteen frivolous motions. Hardy v. Whitaker, ___ F.R.D. ___ 2026 WL 575225, at *4-*7, *12-*13. Because Hardy’s motion to consolidate falsely claims that this Court has a duty to address his mental capacity, the motion is frivolous. Thus, the Court STRIKES Hardy’s motion to consolidate (ECF No. 77). B. Hardy moved before to compel discovery and to determine the", "cited_authorities": [], "summary": "On 2026-04-06, U.S. District Court for the Eastern District of Michigan struck the motion to consolidate and gave the plaintiff a final warning after he repeated fake quotations following an earlier AI-citation sanction order. A self-represented party submitted a motion with false quotations, including Berndt v. Tennessee does not appear in and United States v. Frazier does not appear in.", "incident": { "conduct": "The motion used false quotations, including Berndt v. Tennessee does not appear in and United States v. Frazier does not appear in, which the court found nonexistent, misquoted, or unsupported.", "outcome": "strike-off", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "hardy-v-genesee-county-community-action-resource-department-et-al-2", "courtlistener_url": null, "text_sha256": "4508764e2f938d151ecf4ae184f15e0ab8d7909b153e0e2a6e5cc774f91e6647", "source_url": "https://www.damiencharlotin.com/documents/1954/Hardy_v._Genesse_USA_3_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/mied-2026-hardy-v-genesee-county-community", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-hardy-v-genesee-county-community" }, { "decision_id": "jpml-2026-in-re-philips-recalled-cpap-bi-level", "case_name": "In re: Philips Recalled CPAP, Bi-Level PAP, and Mechanical Ventilator Products Liability Litigation (Gravelyn)", "court": "U.S. Judicial Panel on Multidistrict Litigation", "court_code": "jpml", "court_level": "federal-specialty", "state": null, "date_filed": "2026-04-06", "citation": null, "docket_number": "MDL No. 3014", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The Panel transferred the listed action to MDL No. 3014 and warned that unverified AI-generated fictional citations undermine truthful court filings.", "ai_passage": "Nathaniel M. Gorton Matthew F. Kennelly Roger T. Benitez Dale A. Kimball Madeline Cox Arleo See Reilly v. Connecticut Interlocal Risk Mgmt. Agency, No. 3:25-00640, 2025 WL 1726366, at *2 (D. Conn. June 20, 2025) (“Artificial intelligence is known to result in . . . fictional or hallucinatory citations . . . . [B]ecause artificial intelligence synthesizes many sources with varying degrees of trustworthiness, reliance on artificial intelligence without independent verification renders litigants unable to represent to the Court that the information in their filings is truthful.”) (internal quotation marks and citation omitted). IN RE: PHILIPS RECALLED CPAP, BI-LEVEL PAP, AND MECHANICAL VENTILATOR PRODUCTS LIABILITY LITIGATION MDL No. 3014 SCHEDULE A Northern District of California GRAVELYN v. KONINKLIJKE PHILIPS N.V., ET AL., C.A. No. 3:25−10908", "cited_authorities": [], "summary": "On 2026-04-06, U.S. Judicial Panel on Multidistrict Litigation the Panel transferred the listed action to MDL No. 3014 and warned that unverified AI-generated fictional citations undermine truthful court filings. Counsel submitted a filing with mischaracterized authorities, including In re Xarelto and In re Bard IVC Filters.", "incident": { "conduct": "The filing used mischaracterized authorities, including In re Xarelto and In re Bard IVC Filters, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "in-re-philips-recalled-cpap-bi-level-pap-and-mechanical-ventilator-products-liab", "courtlistener_url": null, "text_sha256": "0f2a7b0d3ce6398bcae8e11d80a332168ce498d4afe75d23bd6c2464223cc958", "source_url": "https://www.damiencharlotin.com/documents/1961/PHILIPS_RECALLED_CPAP_BI-LEVEL_USA_6_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/jpml-2026-in-re-philips-recalled-cpap-bi-level", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/jpml-2026-in-re-philips-recalled-cpap-bi-level" }, { "decision_id": "caed-2026-gamez-v-county-of-fresno", "case_name": "Gamez v. County of Fresno", "court": "U.S. District Court for the Eastern District of California", "court_code": "caed", "court_level": "federal-district", "state": "CA", "date_filed": "2026-04-06", "citation": null, "docket_number": "1:26-cv-00297-KES-EPG", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court ordered counsel to show cause why sanctions should not issue for an opposition brief with nonexistent authority, fabricated quotations, and unsupported legal assertions.", "ai_passage": "Defendant County of Fresno’s Motion for a More Definite Statement. (ECF No. 12). It appears to the Court that Plaintiff’s brief (1) cited authority that does not exist; (2) fabricated quotes from authority that does exist; and (3) made material legal representations without supporting authority. Such issues suggest that Attorney Little relied on generative artificial intelligence (AI) to draft the opposition brief without ensuring that the generated content was accurate or otherwise supported. Accordingly, the Court issues this order directing Attorney Little to show cause why he should not be sanctioned. Dockets.Justia.com II. LEGAL STANDARDS Recently, “many courts have confronted briefs populated with fraudulent legal citations resulting from attorneys’ reliance on generative AI.” Noland v. Land of the Free, L.P., 114 Cal. App. 5th 426, 433, 446 (2025). Courts, including those in this District, have sanctioned “attorneys and pro se parties for submitting fictitious case citations, fictitious quotations, and related misrepresentations to the court.” United States v. Hayes, 763 F. Supp. 3d 1054, 1071 (E.D. Cal. 2025), reconsideration denied, No. 2:24-CR-0280-DJC, 2025 WL 1067323 (E.D. Cal. Apr. 9, 2025) (collecting cases). Sanctions have included (1) monetary sanctions; (2) the striking", "cited_authorities": [], "summary": "On 2026-04-06, U.S. District Court for the Eastern District of California ordered counsel to show cause why sanctions should not issue for an opposition brief with nonexistent authority, fabricated quotations, and unsupported legal assertions. Counsel submitted an opposition brief with nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities.", "incident": { "conduct": "The opposition brief used nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Noland v. Land of the Free, L.P and United States v. Hayes, which the court found nonexistent, misquoted, or unsupported.", "outcome": "pending", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "gamez-v-county-of-fresno", "courtlistener_url": null, "text_sha256": "2e1760c367922f410a90e78ffa193499d895b9347dce8e8a0f6c700264f56b96", "source_url": "https://www.damiencharlotin.com/documents/1938/Gamez_v._County_of_Fresno_USA_6_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/caed-2026-gamez-v-county-of-fresno", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/caed-2026-gamez-v-county-of-fresno" }, { "decision_id": "cacd-2026-james-jordan-v-usa-clinicas-del", "case_name": "James Jordan v. USA, Clinicas Del Camino Real, Inc., et al.", "court": "U.S. District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "state": "CA", "date_filed": "2026-04-06", "citation": null, "docket_number": "P. 78", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the action for lack of subject-matter jurisdiction and admonished the plaintiff for false quotations and an apparently fake Ninth Circuit citation.", "ai_passage": "provides direct quotations to several cases. (Reply 6–7, Dkt. No. 14.) For example, Jordan provides this quote from City of Chicago v. International College of Surgeons, 522 U.S. 156, 172–73 (1997): “When the federal claim is eliminated early in the litigation, the district court must decline jurisdiction over the remaining state-law claims.”4 (Opp’n 6.) However, this quote does not exist in Chicago. Moreover, the legal proposition for which Jordan cites it is also plainly incorrect. See 28 U.S.C. § 1367(c) (providing that district courts have discretion to decline jurisdiction over remaining state-law claims after dismissing “claims over which they have original jurisdiction”). More concerning is Jordan’s apparently fake citation. Jordan cites to Nevada Power Co. v. Monsanto Co., 151 F.3d 1201, 1205 (9th Cir. 1998). (Opp’n 2.) However, the reporter and pincite leads to McKeon v. United States, 151 F.3d 1201 (9th Cir. 1998), not Nevada Power, which is found at 955 F.2d 1304 (9th Cir. 1992). The scourge of AI-hallucinated case law is well-documented and the Court need not beat a dead horse. The Court takes this opportunity only to note that, as other courts around this country have", "cited_authorities": [], "summary": "On 2026-04-06, U.S. District Court for the Central District of California dismissed the action for lack of subject-matter jurisdiction and admonished the plaintiff for false quotations and an apparently fake Ninth Circuit citation. A self-represented party submitted a filing with several false quotations and fabricated or nonexistent authorities, including Chicago v. International College of Surgeons and Co. v. Monsanto Co.", "incident": { "conduct": "The filing used several false quotations and fabricated or nonexistent authorities, including Chicago v. International College of Surgeons and Co. v. Monsanto Co, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "james-jordan-v-usa-clinicas-del-camino-real-inc-et-al", "courtlistener_url": null, "text_sha256": "9fb6463f5c45ff4c10509d5068f465cb529f4b2c7d8bba63dfa257b71962f21d", "source_url": "https://www.damiencharlotin.com/documents/1939/James_Jordan_v._Clinicas_Del_Camino_Real_Inc._USA_6_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/cacd-2026-james-jordan-v-usa-clinicas-del", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-james-jordan-v-usa-clinicas-del" }, { "decision_id": "wawd-2026-ward-v-amazon-com-services", "case_name": "Ward v. Amazon.com Services LLC", "court": "U.S. District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "state": "WA", "date_filed": "2026-04-03", "citation": null, "docket_number": "C25-1671-KKE", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted the arbitration-related relief and warned the plaintiff that further fictitious legal authority could produce an order to show cause for sanctions.", "ai_passage": "was able to locate Gile v. Dolgen Cal., LLC, 2022 WL 17248087 (9th Cir. 2022)—but that case does not support Ward’s waiver claim. There, the Ninth Circuit found that a “motion to compel arbitration over eleven months after [Defendant] removed [the] case to federal court” amounted to waiver. 2022 WL 17248087, at *1. Such a timeline does not exist in this case. The court in Gile observed that the defendant “signed onto a joint Rule 26(f) report before filing its motion to compel,” rather than “without” moving to compel as Ward asserts. Id. (emphasis added). In any case, Gile is inapposite because here, Amazon filed its motion to compel arbitration prior to filing the joint status report. See Dkt. Nos. 30, 33. Next, and more troubling to the Court, Ward cited “Britton v. Co-op Banking Grp., 4 F.4th 742 (9th Cir. 2021)” as “finding waiver based on 77-day delay with discovery participation.” Dkt. No. 35 at 18. The Court was again unable to locate a case with that citation. The Court identified, instead, Britton v. Co-op Banking Grp. (“Briton I”), 916 F.2d 1405 (9th Cir. 1990), which supports a contrary", "cited_authorities": [], "summary": "On 2026-04-03, U.S. District Court for the Western District of Washington granted the arbitration-related relief and warned the plaintiff that further fictitious legal authority could produce an order to show cause for sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities and mischaracterized authorities.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities and mischaracterized authorities, including Gile v. Dolgen Cal., LLC and Britton v. Co-op Banking Grp., 4 F.4th 742, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "ward-v-amazon-com-services-llc", "courtlistener_url": null, "text_sha256": "9584b5c633b052bcebee2a995800cf3a3e6ff32ab21dd247328ada647ba91295", "source_url": "https://www.damiencharlotin.com/documents/1936/Ward_v._Amazon_USA_3_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/wawd-2026-ward-v-amazon-com-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-ward-v-amazon-com-services" }, { "decision_id": "nysupct-2026-group-p-c-v-james-kaloidis", "case_name": "Kleyman Law Group, P.C. v. James Kaloidis", "court": "Supreme Court of the State of New York", "court_code": "nysupct", "court_level": "state-trial", "state": "NY", "date_filed": "2026-04-03", "citation": null, "docket_number": "D: KINGS COUNTY CLERK 04/14/2026 11: 19 A", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court held the plaintiff’s papers sanctionable as frivolous because they were riddled with fictitious cases and authorities that did not support the propositions asserted.", "ai_passage": "st Dept 2007]) ( on page 10). The memorandum again cites the fictitious case Matter of Winston & Strawn LLP (on page 11) and cites the fictitious case Edgeworth Food Corp. v Stephenson (53 NY2d 962 [1981]). 12 The memorandum again misrepresents the holdings in Fontanetta and David (on page 11 ), again cites the fictitious case Credit Agricole Indosuez (twice on page 12) and again misrepresents the holding in VisionChina Media Inc. (twice on page 12). The memorandum again misrepresents the holdings in JSC VTB Bank and Societe Generate Alsacienne De Banque (on page 13) and cites the fictitious case of Tash v Perlmutter ( 453 NYS2d 61 [2 nd Dept 1982]) (on page 13). The memorandum cites the fictitious case of Matter of Witham v Witham (122 AD3d 781 [2d Dept 2014]) (on page 13), again cites the fictitious case of Edgeworth Food Corp. and again misrepresents the holding in JSC VTB Bank (both on page 13 ). The memorandum again cites the fictitious case of Credit Agricole There is a case entitled Ma v Lien (198 AD2d 186 [1 st Department 19931). There is a case entitled", "cited_authorities": [ "Matter of Winston & Strawn LLP (on page 11)", "Matter of Witham v Witham (122 AD3d 781 [2d Dept 2014]) (on page 13)" ], "summary": "On 2026-04-03, Supreme Court of the State of New York held the plaintiff’s papers sanctionable as frivolous because they were riddled with fictitious cases and authorities that did not support the propositions asserted. Counsel submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Winston & Strawn LLP and Matter of Witham v Witham.", "incident": { "conduct": "The filing used fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Winston & Strawn LLP and Matter of Witham v Witham, which the court found nonexistent, misquoted, or unsupported.", "outcome": "sanctions", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "kleyman-law-group-p-c-v-james-kaloidis", "courtlistener_url": null, "text_sha256": "143d353bd945c46cb2e0254fd2c3f40d00a16a0afa8b0be2e6b3d2e1f4bb48ad", "source_url": "https://www.damiencharlotin.com/documents/2026/Kleyman_L__Grp__P_C__v__Kaloidis.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-group-p-c-v-james-kaloidis", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-group-p-c-v-james-kaloidis" }, { "decision_id": "nysupct-2026-ellen-michaelis-v-wilmington-savings-fund-society", "case_name": "Ellen Michaelis v. Wilmington Savings Fund Society", "court": "Supreme Court of the State of New York", "court_code": "nysupct", "court_level": "state-trial", "state": "NY", "date_filed": "2026-04-03", "citation": "2026 WL 959797", "docket_number": "2023-50982", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the renewed post-judgment request and enforced its generative-AI certification rule after finding hallucinated citations throughout the self-represented filing.", "ai_passage": "she AD3d 1285, 1287 [3d Dept. 2013], does not exist. Rather, the provides no reasonable justification for not presenting citation is for Matter of Blocker v. Fischer, 107 AD3d 1285 this \"newly discovered\" evidence on her prior motions. [3d Dept. 2013], which involves an Article 78 proceeding. First, Plaintiff's only explanation for not presenting the These type hallucinations affect virtually every legal citation Selene correspondence is because she \"obtained\" it after that appears in Plaintiff's affirmation. dismissal. This falls short of a reasonable justification. Plaintiff previously submitted mortgage statements from This Court's Part Rules require litigants, including the Selene dated November 7, 2023 and December 7, 2023 self-represented, to submit an certification or affirmation (NYSCEF Doc. #s 72-74). Notably, the \"newly discovered\" that either (1) no generative artificial intelligence program correspondence, dated December 23, 2024 and January 21, was used in the drafting of any affidavit, affirmation, or 2025, was in existence well-before before Plaintiff filed her memorandum of law contained within the submission, or (2) prior motion. Given her access to the 2023 correspondence, that a generative artificial intelligence program was used but it is improbable that Plaintiff did", "cited_authorities": [ "Blocker v. Fischer, 107 AD3d 1285" ], "summary": "On 2026-04-03, Supreme Court of the State of New York denied the renewed post-judgment request and enforced its generative-AI certification rule after finding hallucinated citations throughout the self-represented filing. A self-represented party submitted a motion with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Sakow and Kruger v. Kruger, 107 AD3d 1285, 1287.", "incident": { "conduct": "The motion used false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Sakow and Kruger v. Kruger, 107 AD3d 1285, 1287, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "ellen-michaelis-v-wilmington-savings-fund-society", "courtlistener_url": null, "text_sha256": "e3cdfa8dc77aacde32db2beb9655570edbb4794cee7fb31e3a5809cff5a7e299", "source_url": "https://www.damiencharlotin.com/documents/1957/Ellen_Michaelis_Plaintiff_v_Wilmington_Savings_Fund_Society_USA_3_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-ellen-michaelis-v-wilmington-savings-fund-society", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-ellen-michaelis-v-wilmington-savings-fund-society" }, { "decision_id": "ctb-2026-in-re-kathleen-a-rabon", "case_name": "In re: Kathleen A Rabon", "court": "U.S. Bankruptcy Court for the District of Connecticut", "court_code": "ctb", "court_level": "federal-bankruptcy", "state": "CT", "date_filed": "2026-04-03", "citation": null, "docket_number": "25-21127 (JJT)", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the debtor’s contract arguments and ordered counsel to show cause separately under Bankruptcy Rule 9011 for apparently false citations.", "ai_passage": "rejected any proposal that did not recognize him as the sole buyer of the Note. St.Germain blamed Daniel Malchman’s “eleventh hour tactic to get his wife and Russ named as co-assignees[,]” which St.Germain stated “kind of pissed me off[.]” 10 St.Germain, having initiated the Berkshire Bank transaction, unilaterally believed that he should own and control the Note. Attorney Liberty, however, testified that St.Germain’s loan approach was improvident and unacceptable, as it would render his clients unsecured creditors vulnerable to loss. Understandably, the risks of loss in St.Germain’s approach were too significant. As a consequence, no agreement was ever reached by St.Germain and Malchman and Russ. 11 Meanwhile, in Mark Rabon’s Chapter 7 case, the Movants moved for relief from stay under 11 U.S.C. § 362(d)(1), so as to continue the foreclosure process in the Superior Court. That motion went unopposed by the Debtor, Mark Rabon, and St.Germain and was subsequently granted. The Debtor then filed the instant case on October 24, 2025. By operation of law, the stay against the Debtor expired after 30 days because the Debtor’s prior Chapter 13 case had been dismissed within one year of the", "cited_authorities": [], "summary": "On 2026-04-03, U.S. Bankruptcy Court for the District of Connecticut denied the debtor’s contract arguments and ordered counsel to show cause separately under Bankruptcy Rule 9011 for apparently false citations. Counsel submitted a motion with 7 false quotations. The response requirement preceded any sanction decision.", "incident": { "conduct": "The motion used 7 false quotations that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "pending", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "in-re-kathleen-a-rabon", "courtlistener_url": null, "text_sha256": "9053abc0a18fab417b558e0a959d2b7f4d37cedf985b96802814d5a2e54830d8", "source_url": "https://www.damiencharlotin.com/documents/1955/R_Rabon_USA_3_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ctb-2026-in-re-kathleen-a-rabon", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ctb-2026-in-re-kathleen-a-rabon" }, { "decision_id": "cand-2026-najafpir-v-wells-fargo-bank-n-a", "case_name": "Najafpir v. Wells Fargo Bank, N.A.", "court": "U.S. District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "state": "CA", "date_filed": "2026-04-03", "citation": null, "docket_number": "4:24-cv-03372-YGR", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the ECOA claim with prejudice and prohibited the plaintiff from using artificial intelligence to assert legal arguments in future filings.", "ai_passage": "his complaint, plaintiff cites case law that supposedly states that Wells Fargo’s “shifting Northern District of California explanations” for its actions support an inference of discriminatory intent and “contradictory underwriting determinations create a plausible inference of pretext.” (TAC ¶ 41.) Plaintiff—for the third time—cites to “cases” that do not exist. Plaintiff presumably used artificial intelligence that hallucinated those cases. Non-existent cases cannot, by definition, stand for the proposition asserted. 2 Accordingly, plaintiff once again fails to allege an ECOA claim based on disparate treatment. 3. Disparate Impact To state a claim under a disparate treatment theory, a plaintiff must plead: (1) the existence of an outwardly neutral practice or policy; (2) a significantly adverse or disproportionate impact Because plaintiff has shown that he cannot responsibly use artificial intelligence tools, the Court hereby PROHIBITS plaintiff from using artificial intelligence in asserting legal arguments filed with the Court. Should plaintiff again cite to a hallucinated case, the Court will consider appropriate sanctions. on applicants of a particular type produced by the defendant’s facially neutral practice or policy; and (3) facts demonstrating a causal connection between the specific challenged practice or policy and", "cited_authorities": [], "summary": "On 2026-04-03, U.S. District Court for the Northern District of California dismissed the ECOA claim with prejudice and prohibited the plaintiff from using artificial intelligence to assert legal arguments in future filings. A self-represented party submitted a complaint with multiple fabricated or nonexistent authorities and mischaracterized authorities.", "incident": { "conduct": "The complaint used multiple fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "dismissal", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "najafpir-v-wells-fargo-bank-n-a", "courtlistener_url": null, "text_sha256": "1a39b71d5919ce836f4a3a5b5715c59837636fff3de02e5c3a429ca0f8ebb13f", "source_url": "https://www.damiencharlotin.com/documents/1937/Najafpir_v._Wells_Fargo_Bank_N.A._USA_3_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/cand-2026-najafpir-v-wells-fargo-bank-n-a", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-najafpir-v-wells-fargo-bank-n-a" }, { "decision_id": "cacd-2026-modern-floor-specialists-v-city-of-los", "case_name": "Modern Floor Specialists, Inc. et al. v. City of Los Angeles et al.", "court": "U.S. District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "state": "CA", "date_filed": "2026-04-03", "citation": null, "docket_number": "d for Chapter 11 bankruptcy. (FAC", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted the city defendants’ motion to dismiss and ordered counsel to file a declaration or show cause regarding the potentially hallucinated Mabee citation.", "ai_passage": "v. Anderson, 50 Cal. 3d 205, 212 (1990). The privilege even extends to “any publication required or permitted by law in the course of a judicial proceeding to achieve the objects of the litigation, even though the publication is made outside the courtroom and no function of the court or its officers is involved.” Id. Even taking Plaintiffs’ allegations as true, all of City Defendants’ protected activities fall under California’s litigation privilege. City Defendants’ alleged fraudulent filings and abusive discovery, while perhaps uncouth, were still designed “to achieve the objects of” and are connected to the Modern Floor Action. Plaintiffs argue that the litigation privilege does not apply because City Defendants protected activities were “outside the legitimate scope of judicial proceedings” and were “undertaken for improper purposes.” (Opp’n MTD 15, Dkt. No. 31.) However, “the litigation privilege applies even when statements are made for improper purposes.” Weiser Law Firm, P.C. v. Hartleib, No. 8:23-cv-00171-CJC (JDEx), 2023 WL 4291982, at *8 (C.D. Cal. May 8, 2023). Thus, even if City Defendants acted improperly or out of malice, their litigation conduct is protected by California’s litigation privilege. For these reasons, the Court", "cited_authorities": [], "summary": "On 2026-04-03, U.S. District Court for the Central District of California granted the city defendants’ motion to dismiss and ordered counsel to file a declaration or show cause regarding the potentially hallucinated Mabee citation. Counsel submitted a filing with fabricated or nonexistent authorities, including Mabee v. County of Orange and Cochran v. City of Wichita.", "incident": { "conduct": "The filing used fabricated or nonexistent authorities, including Mabee v. County of Orange and Cochran v. City of Wichita, which the court found nonexistent, misquoted, or unsupported.", "outcome": "pending", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "modern-floor-specialists-inc-et-al-v-city-of-los-angeles-et-al", "courtlistener_url": null, "text_sha256": "db21e0b9dcdf2b125f3d2634a49dae16f14e935bff6ea9a6ce5f88ee929f0b7f", "source_url": "https://www.damiencharlotin.com/documents/1960/Modern_Floor_Specialists_v._LA_USA_3_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/cacd-2026-modern-floor-specialists-v-city-of-los", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-modern-floor-specialists-v-city-of-los" }, { "decision_id": "ca6-2026-united-states-v-farris", "case_name": "United States v. Farris", "court": "U.S. Court of Appeals for the Sixth Circuit", "court_code": "ca6", "court_level": "federal-appellate", "state": null, "date_filed": "2026-04-03", "citation": null, "docket_number": "Name: 26a0105p.06", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": "Westlaw CoCounsel", "disposition": "The court disqualified counsel, denied compensation for time served, locked the briefs, directed notice of the opinion, and referred counsel for discipline.", "ai_passage": "even when new tools are sponsored by trusted legal technology providers. See Varun Magesh et al., Hallucination-Free? Assessing the Reliability of Leading AI Legal Research Tools, J. of Empirical Legal Stud. 9–16 (2025). No. 25-5623 United States v. Farris Page 5 Further, attorneys who choose to use artificial-intelligence tools must do so in a manner consistent with their ethical obligations. See A.B.A. Task Force on L. & A.I., Addressing the Legal Challenges of AI: Year 2 Report on the Impact of AI on the Practice of Law, 47–48 (2025), https://perma.cc/4JES-DGMU (compiling state bar ethics rules and guidance on generative artificial intelligence). We do not purport to exhaust the full scope of ethical considerations here. But relevant steps may include reviewing and validating content produced by artificial intelligence; considering whether to disclose the use of artificial intelligence to clients or obtain informed consent; safeguarding confidential client information and preserving attorney-client privilege; implementing firm-wide policies governing the use of artificial intelligence; adhering to ethical billing practices when using artificial-intelligence tools; and keeping current with jurisdiction-specific guidelines. New technologies, moreover, are no substitute for tried-and-true safeguards managed by practicing attorneys. Attorneys have an", "cited_authorities": [], "summary": "On 2026-04-03, U.S. Court of Appeals for the Sixth Circuit disqualified counsel, denied compensation for time served, locked the briefs, directed notice of the opinion, and referred counsel for discipline. Counsel submitted a brief with nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including United States v. Washington and United States v. Anthony.", "incident": { "conduct": "The brief used nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including United States v. Washington and United States v. Anthony, which the court found nonexistent, misquoted, or unsupported.", "outcome": "referral", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": "Westlaw CoCounsel" }, "tracker_slug": "united-states-v-farris", "courtlistener_url": null, "text_sha256": "ff64a90d81b40c574bbf111b70d73d66bda9c53b15c4bc144a54dc5195b0dd6f", "source_url": "https://www.damiencharlotin.com/documents/1903/USA_v._Farris_USA_3_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ca6-2026-united-states-v-farris", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca6-2026-united-states-v-farris" }, { "decision_id": "texapp-2026-stanford-v-leinart", "case_name": "Stanford v. Leinart", "court": "Texas Court of Appeals", "court_code": "texapp", "court_level": "state-appellate", "state": "TX", "date_filed": "2026-04-02", "citation": null, "docket_number": "02-25-00529-CV", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed the judgment, denied costs, and admonished the self-represented appellant that the fabricated Anderson v. Hood authority was unacceptable.", "ai_passage": "his gross misrepresentations of the record and misstatements of the law are unacceptable,12 but On page eighteen of his appellate brief, Stanford cites to Anderson v. Hood, 472 S.W.3d 524, 529 (Tex. App.—Dallas 2015, no pet.). “Anderson v. Hood” is a fabricated case and appears to be a “hallucinated” authority generated from the use of artificial intelligence. Our review of the citation leads to King v. Commonwealth, 472 S.W.3d 523 (Ky. Ct. App. 2015), and the only case with a comparable name is Anderson v. Hood Cnty., 958 S.W.2d 448 (Tex. App.—Fort Worth 1997, no pet.)—a workers’ compensation case. “[C]itation of nonexistent cases that appear to have been generated by [artificial intelligence] is unacceptable.” Albelbaisi v. Mustang Materials, LLC, No. 05-24-00617-CV, 2025 WL 1384772, at *2 (Tex. App.—Dallas May 13, 2025, no pet.) (mem. op.). The federal magistrate’s July 23, 2024 order warned Stanford against such conduct. The order provides: The Court ADMONISHES Mr. Stanford for filing a false and misleading document with this Court. Attempting to deceive the Court is an abuse of the judicial process and the very opposite of the good faith participation on which the justice", "cited_authorities": [], "summary": "On 2026-04-02, Texas Court of Appeals affirmed the judgment, denied costs, and admonished the self-represented appellant that the fabricated Anderson v. Hood authority was unacceptable. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities, including Anderson v. Hood.", "incident": { "conduct": "The appellate brief used fabricated or nonexistent authorities, including Anderson v. Hood, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "stanford-v-leinart", "courtlistener_url": null, "text_sha256": "211e07006d089c17bbde0abbf8c2e00855a5f30a7e45803fee9c99a75076a707", "source_url": "https://www.damiencharlotin.com/documents/1929/Stanford_v._Leinart_USA_2_APril_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/texapp-2026-stanford-v-leinart", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/texapp-2026-stanford-v-leinart" }, { "decision_id": "azd-2026-kevin-d-turnage-v-robert-f-kennedy", "case_name": "Kevin D. Turnage v. Robert F. Kennedy, Jr., et al.", "court": "U.S. District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "state": "AZ", "date_filed": "2026-04-02", "citation": null, "docket_number": "CV-25-03367-PHX-SMB", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the plaintiff’s pending motions and warned that further false citations, including AI hallucinations, may warrant sanctions.", "ai_passage": "Wash. Oct. 22, 2025). Second, courts have dismissed cases based on litigants filing “frivolous and duplicative motions [which] needlessly disrupted the litigation and burdened the court and opposing counsel.” See, e.g., Scott v. Cunningham, 516 F. App’x 672, 673 (9th Cir. 2013). Third, the Court will not tolerate any further “presentation of false citations, including AI ‘hallucinations.’” See Stafford, 2026 WL 799409, at *2. The Court notes that Plaintiff cited more hallucinated cases than highlighted herein. Any further abuses of AI may warrant sanctions. VII. CONCLUSIONS Accordingly, IT IS HEREBY ORDERED granting Plaintiff’s Motion for Leave to File Fourth Amended Complaint (Doc. 60). IT IS FURTHER ORDERED denying the following motions: Plaintiff’s Motion to Stay Administrative Inquiry (Doc. 13); Plaintiff’s First Motion to Amend (Doc. 36); Plaintiff’s Motion to for a Protective Order and to Compel Meet and Confer (Doc. 44); Plaintiff’s Second Motion to Amend (Doc. 50); Plaintiff’s Motion for Leave to Serve Third-Party Subpoena (Doc. 51); Plaintiff’s Third Motion to Amend (Doc. 55); Plaintiff’s Motion to Compel Final Agency Decision (Doc. 57); Plaintiff’s Motion to Compel Filing of Responsive Pleading (Doc. 58); Plaintiff’s Motion to Deem Unopposed and Grant Motion to Compel Final Agency Decision (Doc. 59); and Plaintiff’s Motion to Submit Pending Motions for Decision (Doc. 64). Dated this 2nd day of April, 2026.", "cited_authorities": [], "summary": "On 2026-04-02, U.S. District Court for the District of Arizona denied the plaintiff’s pending motions and warned that further false citations, including AI hallucinations, may warrant sanctions. A self-represented party submitted a complaint with nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Gao v. United States and Miller v. United States.", "incident": { "conduct": "The complaint used nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Gao v. United States and Miller v. United States, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "kevin-d-turnage-v-robert-f-kennedy-jr-et-al", "courtlistener_url": null, "text_sha256": "9dfe4b2ba6154e2803576052f0d5ac5f10e5df923ca6529a82d534d626c404cf", "source_url": "https://www.damiencharlotin.com/documents/1910/Turnage_v._Kennedy_USA_2_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/azd-2026-kevin-d-turnage-v-robert-f-kennedy", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-kevin-d-turnage-v-robert-f-kennedy" }, { "decision_id": "iowactapp-2026-in-the-interest-of-w-g-minor", "case_name": "In the Interest of W.G., Minor Child", "court": "Iowa Court of Appeals", "court_code": "iowactapp", "court_level": "state-appellate", "state": "IA", "date_filed": "2026-04-01", "citation": "2026 WL 892837", "docket_number": "25-1916 to intervene", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": "Perplexity", "disposition": "The court struck the fabricated-citation portions of the petition on appeal, declined to dismiss the appeal, and considered only arguments untainted by the false authorities.", "ai_passage": "admitted that the case we believed to be our discretion, we elect a lesser sanction here. We strike hallucinated was in fact “non-existent” and her citation “d[id] the problematic portions of K.M.’s petition on appeal and not correspond to any Iowa appellate decision.” She also consider only the arguments we can discern without the taint admitted that AI led her to “attribut[e] specific propositions” of the fabricated and false citations. We thus assume without of law to a case in which those propositions “do not appear.” deciding we can reach the merits, in part to provide finality And she disclosed that she prepared the petition using the on this issue to the child affected by this juvenile proceeding. paid version of the AI tool Perplexity. See generally What Is Perplexity Pro?, Perplexity: Perplexity Help Center (Mar. 12, 2026), https://perma.cc/5DAL-2LXN. MERITS K.M. went on to apologize to the court and opposing party, Having finished our detour to address the briefing and she said that she believed she had verified the AI's legal misconduct, we review the juvenile court's ruling for citations but now understood she “made mistakes.” She wrote “correction of", "cited_authorities": [], "summary": "On 2026-04-01, Iowa Court of Appeals struck the fabricated-citation portions of the petition on appeal, declined to dismiss the appeal, and considered only arguments untainted by the false authorities. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities and mischaracterized authorities.", "incident": { "conduct": "The appellate brief used fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": "Perplexity" }, "tracker_slug": "in-the-interest-of-w-g-minor-child", "courtlistener_url": null, "text_sha256": "ac233d72490d7811763a812180d5150ba41fd8fca847ec7d8564a4e0fdca8ae1", "source_url": "https://www.damiencharlotin.com/documents/1895/Interest_of_WG_USA_1_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/iowactapp-2026-in-the-interest-of-w-g-minor", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/iowactapp-2026-in-the-interest-of-w-g-minor" }, { "decision_id": "innd-2026-joseph-maldonado-v-professional-animal-retirement-center", "case_name": "Joseph Maldonado v. Professional Animal Retirement Center", "court": "U.S. District Court for the Northern District of Indiana", "court_code": "innd", "court_level": "federal-district", "state": "IN", "date_filed": "2026-04-01", "citation": null, "docket_number": "1:25-cv-00454-HAB-ALT", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court imposed a $1,500 sanction on counsel and directed the clerk to send the sanction orders to the Rhode Island disciplinary authority.", "ai_passage": "Jackson v. Auto-Owners Ins. Co., No. 7-24-cv-136, 2025 WL 1932274, at *5 (M.D. Ga. July 14, 2025) (imposing a $1,000 fine for the submission of filings with hallucinated cases), and Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281, 2024 WL 4882651, at *3 (E.D. Tex. Nov. 25, 2024) (imposing $2,000 sanction on attorney who submitted a response “without reading the cases cited, or even confirming the existence or validity of the cases included therein”), with Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023) (sanctioning attorneys $5,000 for producing a filing with citation to an opinion which did not exist) and HoosierVac LLC, 2025 WL 1511211, at *2 (imposing sanction of $6,000 for filing briefs containing non-existent AI-generated legal citations). Second, the Court directs the clerk’s office to transmit a copy of this Opinion and Order— as well as a copy of the Show Cause Order (ECF No. 23) which more explicitly details counsel’s misconduct—to the appropriate attorney-disciplinary authority of the State of Rhode Island where Roots is licensed. See, e.g., Amarsingh v. Frontier Airlines, Inc., No. 24-1391, 2026 WL 352016, at *8 (10th Cir. Feb. 9,", "cited_authorities": [], "summary": "On 2026-04-01, U.S. District Court for the Northern District of Indiana imposed a $1,500 sanction on counsel and directed the clerk to send the sanction orders to the Rhode Island disciplinary authority. Counsel submitted a brief with mischaracterized authorities, including Animals v. NIH and FEC v. Akins.", "incident": { "conduct": "The brief used mischaracterized authorities, including Animals v. NIH and FEC v. Akins, which the court found nonexistent, misquoted, or unsupported.", "outcome": "referral", "actor": "lawyer", "monetary_penalty": 1500, "currency": "USD", "ai_tool": null }, "tracker_slug": "joseph-maldonado-v-professional-animal-retirement-center", "courtlistener_url": null, "text_sha256": "3da39cdfbb6a94e241ceff8ec9d904ca42c2507979491d3db3707dc9231ad15c", "source_url": "https://www.damiencharlotin.com/documents/1963/Maldonado_Tiger_King_USA_1_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/innd-2026-joseph-maldonado-v-professional-animal-retirement-center", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/innd-2026-joseph-maldonado-v-professional-animal-retirement-center" }, { "decision_id": "cand-2026-saqib-kafeel-v-apple", "case_name": "Saqib Kafeel v. Apple Inc., et al.", "court": "U.S. District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "state": "CA", "date_filed": "2026-04-01", "citation": null, "docket_number": "26-cv-00330-RFL", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the preliminary-injunction motion and warned that future filings containing nonexistent cases may be stricken from the docket.", "ai_passage": "(Dkt. No. 29-2 at 13; Dkt. No. 31 at 9.) However, Apple confirmed that it is complying with its preservation duties in this lawsuit “notwithstanding any contractual right to delete materials.” (See Dkt. No. 29 at 15; Dkt. No. 29-5 at 7.) Apple’s preservation duties in this lawsuit would clearly prohibit deletion of Kafeel’s e-books, so there is no reason to believe they are subject to imminent deletion. For the foregoing reasons, Kafeel’s motion is DENIED. Additionally, Apple raised that Kafeel’s motion may contain hallucinations created by generative artificial intelligence tools. (Dkt. No. 29 at 7, 18–19.) Kafeel’s reply did not address this point, but purports to have links to each citation. Nevertheless, some of the reply’s citations do not exist. (See, e.g., Dkt. No. 31 at (citing “In re Grand Jury Subpoena, 972 F.2d 1474 (9th Cir. 1992),” which does not exist).) Use of generative artificial intelligence tools is permitted, but an individual must personally confirm for themselves the accuracy of any research regardless of the source. Kafeel is warned that if his future filings contain nonexistent cases, they may be stricken from the docket. IT IS SO ORDERED. Dated: April 1, 2026 RITA F. LIN United States District Judge", "cited_authorities": [], "summary": "On 2026-04-01, U.S. District Court for the Northern District of California denied the preliminary-injunction motion and warned that future filings containing nonexistent cases may be stricken from the docket. A self-represented party submitted a motion with fabricated or nonexistent authorities, including In re Grand Jury Subpoena.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities, including In re Grand Jury Subpoena, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "saqib-kafeel-v-apple-inc-et-al", "courtlistener_url": null, "text_sha256": "adcd28ddd97542441a06dd241b10d08874e9ca9f47a2bd94929f82573462e7da", "source_url": "https://www.damiencharlotin.com/documents/1893/Kafeel_v._Apple_USA_1_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/cand-2026-saqib-kafeel-v-apple", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-saqib-kafeel-v-apple" }, { "decision_id": "arkctapp-2026-patrick-hrdlichka-v-samantha-bengston", "case_name": "Patrick Hrdlichka v. Samantha Bengston", "court": "Arkansas Court of Appeals", "court_code": "arkctapp", "court_level": "state-appellate", "state": "AR", "date_filed": "2026-04-01", "citation": "2026 Ark. App. 205", "docket_number": "CV-25-106 damages plus interest at t", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the appeal because the self-represented appellant’s brief was noncompliant and relied on fictitious authorities that prevented meaningful review.", "ai_passage": "mischaracterized. Fabricated citations—whether cites multiple cases that, upon review, do not exist. The created intentionally or through unverified use of artificial authorities relied on in support of his arguments are not found intelligence—waste judicial resources, delay resolution of in the Arkansas Reports, the South Western Reporter, or cases, and erode confidence in the judicial system. any recognized legal database. In short, they are fictitious. We cannot evaluate arguments predicated on nonexistent Second, all litigants, including pro se appellants, bear precedent. The appellate process depends on accurate citation responsibility for the contents of their filings. The use to existing authority so that we may assess the legal of artificial intelligence does not relieve a litigant of the foundation of a party's claims. When a party cites fabricated duty to verify the accuracy of citations. A brief containing cases, we are deprived of any meaningful ability to conduct nonexistent cases is no different, in effect, from a brief review. Fictitious citations fail to comply with Rule 4-2 of containing invented precedent. the Rules of the Arkansas Supreme Court and Appellate Court. Rule 4-2(a)(7) requires that arguments contain citation Third, the court emphasizes", "cited_authorities": [], "summary": "On 2026-04-01, Arkansas Court of Appeals dismissed the appeal because the self-represented appellant’s brief was noncompliant and relied on fictitious authorities that prevented meaningful review. A self-represented party submitted an appellate brief with multiple fabricated or nonexistent authorities. The court resolved the merits while identifying the defective legal research.", "incident": { "conduct": "The appellate brief used multiple fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "patrick-hrdlichka-v-samantha-bengston", "courtlistener_url": null, "text_sha256": "49195c99b94fc2f3d881a909e67be7086c688d2e4089ae808d9bab126ffaebd5", "source_url": "https://www.damiencharlotin.com/documents/1894/Hrdlishcka_v._Bengston_USA_1_April_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/arkctapp-2026-patrick-hrdlichka-v-samantha-bengston", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arkctapp-2026-patrick-hrdlichka-v-samantha-bengston" }, { "decision_id": "wawd-2026-maria-cabrera-thompson-v-seattle-public-schools", "case_name": "Rosa Maria Cabrera Thompson v. Seattle Public Schools", "court": "U.S. District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "state": "WA", "date_filed": "2026-03-31", "citation": null, "docket_number": "2:25-cv-00468-TL", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted leave to amend only in part and ordered the plaintiff to show cause within seven days for continued citation of nonexistent authority.", "ai_passage": "SAC are the same as the claims brought in her FAC, except that Plaintiff appears to seek to add an additional Defendant (WSRMP) to Counts Three and Five. Dkt. No. 96-3 at 36–46. Further, Plaintiff seeks to add 11 new claims (Counts Seven through Seventeen). Id. at 47–64. Plaintiff does not specify which claims are brought against which Defendants. It appears, however, that Plaintiff intends to plead all 11 new claims against Defendant SPS, and some of them against Defendant WSRMP. As the Court has now granted Plaintiff additional time to join parties (see Dkt. No. 155; see also supra n.1.), in evaluating Plaintiff’s motion here, the Court will consider claims to have been pleaded against WSRMP where the language of the proposed SAC lends itself to such an interpretation. These appear to be Counts Three, Five, Seven, Ten, Eleven, and Sixteen. Defendant variously asserts Although the Court issued a case scheduling order (Dkt. No. 83) before Plaintiff filed the instant motion (Dkt. No. 96), Rule 15’s liberal amendment standard applies here. Ninth Circuit authority indicates that the “good cause” standard of Rule 16 applies when a Party seeks to", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "pending", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "rosa-maria-cabrera-thompson-v-seattle-public-schools", "courtlistener_url": null, "text_sha256": "b507cac412a950919578e463068d858ba7651d6ae31398a95c9f555c1538b26b", "source_url": "https://www.damiencharlotin.com/documents/1888/Thompson_v_Seattle_Public_Schools_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/wawd-2026-maria-cabrera-thompson-v-seattle-public-schools", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-maria-cabrera-thompson-v-seattle-public-schools" }, { "decision_id": "ohsd-2026-quandel-construction-group-v-hunt-construction-group", "case_name": "Quandel Construction Group, Inc. v. Hunt Construction Group, Inc.", "court": "U.S. District Court for the Southern District of Ohio", "court_code": "ohsd", "court_level": "federal-district", "state": "OH", "date_filed": "2026-03-31", "citation": null, "docket_number": "2-24-cv-2362", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court ordered counsel to explain how nonexistent citations and nonexistent quoted language entered Hunt’s briefing despite counsel’s denial that AI caused the errors.", "ai_passage": "_ F.4th __, 2026 WL 710568, at *3 (6th Cir. Mar. 13, 2026) (citation omitted). Hunt’s briefing provided this Court with nonexistent case citations and purported to quote nonexistent case language; Hunt’s representation that artificial intelligence was not the cause of these errors is not an explanation sufficient to address how these errors actually happened. Though the Court takes counsel for Hunt at their word if they say that artificial intelligence was not involved in their legal research, that does not end the inquiry. The topical worry that artificial intelligence will lure attorneys with the false siren song of easy shortcuts to legal authority is part of a much larger concern that attorneys will fail to cite their sources properly and—either intentionally or unintentionally—mislead the Court. Whether artificial intelligence was used, false citations damage judicial proceedings: “[t]he opposing party expends resources identifying and exposing the fabrications; the court spends time reviewing materials, holding hearings, deliberating about sanctions, and explaining its ruling; the substance of the case is delayed; and public confidence about the trustworthiness of legal proceedings may be diminished.” Johnson v. Dunn, 792 F. Supp. 3d 1241, 1257 (N.D.", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief cited nonexistent cases and quoted language that the court could not find in any actual decision.", "outcome": "pending", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "quandel-construction-group-inc-v-hunt-construction-group-inc", "courtlistener_url": null, "text_sha256": "2fe17602bcb1560c1708396f6189769ec5ab764e7226ac5f1a15d6b076ff2525", "source_url": "https://www.damiencharlotin.com/documents/1892/Quandel_v._Hunt_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ohsd-2026-quandel-construction-group-v-hunt-construction-group", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohsd-2026-quandel-construction-group-v-hunt-construction-group" }, { "decision_id": "nyed-2026-evgeny-yaroshevsky-v-karlin", "case_name": "Evgeny Yaroshevsky v. Karlin et al.", "court": "U.S. District Court for the Eastern District of New York", "court_code": "nyed", "court_level": "federal-district", "state": "NY", "date_filed": "2026-03-31", "citation": "2026 WL 522624", "docket_number": "d 02/23/2026 cottages on the North Shore", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": "Gemini", "disposition": "The court recommended an adverse fee award after finding Rule 11 safe-harbor compliance and repeated nonexistent or misrepresented AI-generated authorities.", "ai_passage": "claims with prejudice. nonexistent legal authority or misrepresenting the import of legal authority resulting from a lack of effort to verify the content of AI-generated drafts is sanctionable. See, 1. Defendants Met Rule 11’s Procedural Requirements e.g., Ramirez v. Humala, 24-CV-242, 2025 WL 1384161, at *1 (E.D.N.Y. May 13, 2025) (listing cases addressing The undersigned first considers whether Defendants met the AI-generated citations and finding “the Second Circuit, as safe harbor notice requirement of Rule 11 and concludes well as district courts across the country, have found the that they have. As previously discussed, Defendants served submission of nonexistent case citations in filings to the a copy of their motion on Plaintiff 21 days before moving court to constitute sanctionable conduct under Rule 11(b) for sanctions. 4 See supra pp. 7–8. The undersigned finds (2).”); Ferris v. Amazon.com Services, LLC, 24-CV-304, 2025 this provided Plaintiff with the requisite notice to correct the WL 1122235, at *2 (N.D. Miss. Apr. 16, 2025) (imposing alleged misconduct prior to Defendants seeking sanctions. sanctions against pro se plaintiff who continued to submit EVGENY YAROSHEVSKY, Plaintiff, v. BENJAMIN W. KARLIN,..., Slip Copy (2026) false citations", "cited_authorities": [ "Ramirez v. Humala, 24-CV-242, 2025 WL 1384161" ], "summary": "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.", "incident": { "conduct": "The complaint used multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Ramirez v. Humala, 24-CV-242, which the court found nonexistent, misquoted, or unsupported.", "outcome": "costs-order", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": "Gemini" }, "tracker_slug": "evgeny-yaroshevsky-v-karlin-et-al", "courtlistener_url": null, "text_sha256": "bb04040bf719e6f88febb85d8a4a623c9f597aa1c999724a78bc22c3aef952c3", "source_url": "https://www.damiencharlotin.com/documents/1592/Yaroshevsky_v._Karlin_USA_23_February_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nyed-2026-evgeny-yaroshevsky-v-karlin", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nyed-2026-evgeny-yaroshevsky-v-karlin" }, { "decision_id": "nvd-2026-edward-c-allen-v-western-governors-university", "case_name": "Edward C. Allen v. Western Governors University, et al.", "court": "U.S. District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "state": "NV", "date_filed": "2026-03-31", "citation": null, "docket_number": "2:25-cv-00325-RFB-NJK", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the case with prejudice and imposed nominal monetary sanctions after finding fabricated authorities, factual misrepresentations, and bad faith.", "ai_passage": "were accurate or the result of benign typographical errors while simultaneously citing to additional misrepresented or fabricated authorities. The Court is left to assume that Mr. Allen either himself fabricated authorities and lied to the Court by claiming the inaccuracies were the result of typos or clerical errors, or enlisted the assistance of AI, which misrepresented and fabricated cases to support his assertions, failed to check their validity (even after being specifically instructed to do so), and then lied to the Court about their origins. Further, while Mr. Allen’s Response to the Court’s OSC asserted that he should be afforded lenience due to his status as a pro se litigant, the Court finds Mr. Allen is neither unsophisticated nor inexperienced in litigation even though he is proceeding pro se. Indeed, he purportedly has a juris doctorate degree, and claims he has “been in this business for eighteen years.” See Hr’g Tr. 3:8, Mar. 17, 2026, ECF No. 53. And even if that were not the case, “although courts make some allowances for a pro se [p]laintiff's failure to cite to proper legal authority, courts do not make allowances for a", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used false quotations and nonexistent or mischaracterized authorities, including Christian and Warren cases the court found did not contain the quoted language.", "outcome": "costs-order", "actor": "litigant-in-person", "monetary_penalty": 1, "currency": "USD", "ai_tool": null }, "tracker_slug": "edward-c-allen-v-western-governors-university-et-al", "courtlistener_url": null, "text_sha256": "9dae470f96e0a62c251782915a076f74a79e88f8bd4fdeed7ae4ce4e589f3c3f", "source_url": "https://www.damiencharlotin.com/documents/1886/Allen_v._Western_Governors_University_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nvd-2026-edward-c-allen-v-western-governors-university", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-edward-c-allen-v-western-governors-university" }, { "decision_id": "moed-2026-jaii-leshawn-quinones-v-unknown-love", "case_name": "Jaii LeShawn Quinones v. Unknown Love, et al.", "court": "U.S. District Court for the Eastern District of Missouri", "court_code": "moed", "court_level": "federal-district", "state": "MO", "date_filed": "2026-03-31", "citation": null, "docket_number": "d this action on August 8", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court ordered the plaintiff to show cause by April 17, 2026 why Rule 11 sanctions should not issue for nonexistent cases and mischaracterized authorities.", "ai_passage": "P. 11(b). “Every filing in a federal court that contains citations to phony case law amounts to a violation of Rule 11(b) of the Federal Rules of Civil Procedure.” Turnage, 2025 WL 3052638, at *3; see also Mills v. City of St. Louis, 2025 WL 3470293, at *1 (E.D. Mo. Dec. 3, 2025) (“Providing the Court with fake cases and forged quotations cannot be squared with Rule 11(b).”). Plaintiff is ordered to show cause by April 17, 2026, why he should not be sanctioned under Rule 11(b) for citing non-existent cases and mischaracterizing existing ones. Though the Court will not decide whether or how to sanction Plaintiff until it reviews his response to this Order, it notes that it has “broad discretion in the choice of sanctions.” Vallejo v. Amgen, Inc., These are not the only examples. See also, e.g., Doc. [1-1] at 13 (citing case called U.S. v. Bigelow with case reporter cite 620 F.2d 911 for the proposition that “states must recognize the constitutional rulings of other jurisdictions when determining enforceability.” That reporter cite is to real case Precious Metals Assocs., Inc. v. Commodity Futures Trading Comm’n, 620", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used fabricated or nonexistent authorities and mischaracterized authorities, including Egelhoff v. Egelhoff and Wilkerson v. Wilkerson, which the court found nonexistent, misquoted, or unsupported.", "outcome": "pending", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "jaii-leshawn-quinones-v-unknown-love-et-al", "courtlistener_url": null, "text_sha256": "26da6cf27a2896fbe5ddd59b7e6a4afe863eee81ccddbf5086f7afd5f746686a", "source_url": "https://www.damiencharlotin.com/documents/1913/Quinones_v._Love_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/moed-2026-jaii-leshawn-quinones-v-unknown-love", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/moed-2026-jaii-leshawn-quinones-v-unknown-love" }, { "decision_id": "minnctapp-2026-rushing-v-rushing-and-christ", "case_name": "Rushing v. Rushing et al. and Christ Temple Apostolic Church-Fridley", "court": "Minnesota Court of Appeals", "court_code": "minnctapp", "court_level": "state-appellate", "state": "MN", "date_filed": "2026-03-31", "citation": "2026 WL 905119", "docket_number": "APP. with Minn. R. Civ. P. 11.02(b)", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court allowed the dismissal of the appellant’s action without prejudice to stand after rejecting his challenge to the AI-citation sanction.", "ai_passage": "SPECIAL TERM ORDER1 409 (Minn. App. 1989), rev. denied (Minn. July 12, 1989). Jennifer L. Frisch Chief Judge Appellant contends that the March 5, 2026 order dismissing *1 BASED ON THE FILE, RECORD, AND appellant's action without prejudice affected appellant's PROCEEDINGS, AND FOR THE FOLLOWING substantial rights. Appellant notes that the dismissal was REASONS: “based on [an] alleged citation to nonexistent legal authority” and asserts that the district court “rendered the alleged defect This appeal was filed on March 10, 2026. According to the uncurable” by refusing to accept an amended complaint fixing notice of appeal, appellant Marcus Rushing seeks review the citation issue it identified. of a March 9, 2026 order denying appellant's motion to vacate a March 5, 2026 dismissal order. In a March 11, In the March 5, 2026 dismissal order, the district court did 2026 order, we questioned (a) whether the March 5, 2026 not decide the merits of any of appellant's claims. Because order dismissing appellant's action without prejudice affected the district court's dismissal of appellant's action without appellant's substantial rights; (b) if not, whether the March 9, prejudice does not prevent appellant from serving", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "dismissal", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "rushing-v-rushing-et-al-and-christ-temple-apostolic-church-fridley", "courtlistener_url": null, "text_sha256": "571f168bcf3a7c50fd484b308e4c94e6242330f5e7c0c46eb0640a76e18d44e6", "source_url": "https://www.damiencharlotin.com/documents/1889/Rushing_v._Rushing_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/minnctapp-2026-rushing-v-rushing-and-christ", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/minnctapp-2026-rushing-v-rushing-and-christ" }, { "decision_id": "ksd-2026-ford-v-sherwin-williams", "case_name": "Ford v. Sherwin-Williams", "court": "U.S. District Court for the District of Kansas", "court_code": "ksd", "court_level": "federal-district", "state": "KS", "date_filed": "2026-03-31", "citation": null, "docket_number": "25-1022-DDC-GEB", "document_type": "report-and-recommendation", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the plaintiff’s review and default motions and warned that future fabricated or incorrect legal authority could bring sanctions or dismissal.", "ai_passage": "from projects, derogatory questions and comments about plaintiff’s country of origin and hygiene, and disparaging comments about Martin Luther King, Jr. holiday weren’t severe or pervasive); Morris v. City of Colorado Springs, 666 F.3d 654, 665–69 (10th Cir. 2012) (affirming summary judgment because doctor flicking plaintiff on the head, throwing bloody heart tissue, and yelling at plaintiff weren’t severe or pervasive). Even the most severe of plaintiff’s accusations—that Ross made unwanted physical advances on him—aren’t sufficient. See Chytka v. Wright Tree Serv., Inc., 925 F. Supp. 2d 1147, 1169 (D. Colo. 2013) (compiling cases and observing that other courts have found that limited instances of sexual advances are insufficient to create a hostile work environment). Plaintiff simply hasn’t alleged the sort of “outrageous conduct that may render a work environment hostile[.]” Iweha, 121 F.4th at 1223. The court thus dismisses this claim without prejudice. See Gee, 627 F.3d at 1186.7 Recall also that plaintiff’s claims based on events occurring before December 2023 aren’t timely. Plaintiff alleges that at least some harassment—including the incident where Ross assaulted him— occurred in August 2023. Doc. 1 at 2 (Compl. ¶ 15). As the", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used false quotations and fabricated or nonexistent authorities, including Clark v. City of Shawnee, Kansas, No. 21-2223-EFM, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "ford-v-sherwin-williams", "courtlistener_url": null, "text_sha256": "d4f904183f311e5af7c52beee99392e10bedae57c036684a3ece152b7210463a", "source_url": "https://www.damiencharlotin.com/documents/1907/Ford_v_Sherwin-Williams_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ksd-2026-ford-v-sherwin-williams", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ksd-2026-ford-v-sherwin-williams" }, { "decision_id": "insd-2026-elbert-coleman-iv-v-nexo-capital", "case_name": "Elbert Coleman, III; Elbert Coleman, IV v. Nexo Capital Inc.", "court": "U.S. District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "state": "IN", "date_filed": "2026-03-31", "citation": "2026 WL 994492", "docket_number": "106 at", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted summary judgment to the defendant and warned the self-represented plaintiffs that their contract-voiding authorities were inaccurate.", "ai_passage": "opposing Defendant's summary judgment motion, so the Court need not address it. In support of their argument that the contract is void, Plaintiffs cite “Indiana Code § 23-2-1-2” and “Kramer v. Trans-Lux Corp., 24 F.3d 1001 (7th Cir. 1994)” for the proposition that transactions involving unregistered securities are void. (Docket No. 107 at ECF p. 3). These citations are inaccurate. A search of the Indiana Code statute reveals that it has been repealed, and no such case exists at the Seventh Circuit, though there is one with the same name from the District of Connecticut. Kramer v. Trans-Lux Corp., No. 3:11- cv-1424, 2012 WL 4444820 (D. Conn. Sept. 25, 2012). It is unclear whether Plaintiffs’ citations are fabricated or erroneously cited. Regardless, all parties, including those proceeding pro se, must conduct a reasonable inquiry to determine that all factual and legal allegations contained in court filings are supported as required by Federal Rule of Civil Procedure 11. A party's failure to adhere to this rule authorizes sanctions, including the dismissal of the case. See Fed. R. Civ. P. 11(c). Although sanctions are not imposed here in light of the present Motion's disposition, the Court cautions all parties to adhere to this rule, especially where artificial intelligence (“AI”) may have been used to assist parties in preparing filings. See Jones v. Kankakee Cnty. Sheriff's Dep't, No. 25-1251, 2026 WL 157661, at *3 (7th Cir. Jan. 21, 2026) (“As pro se litigants employ AI to assist with court filings, a basic reminder seems wise. Accuracy and honesty matter.”).", "cited_authorities": [ "Fed. R. Civ. P. 11(c)" ], "summary": "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.", "incident": { "conduct": "The motion used 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, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "elbert-coleman-iii-elbert-coleman-iv-v-nexo-capital-inc", "courtlistener_url": null, "text_sha256": "21eeeee5bb368428b3e262cfab5fb8185cb29ee8ba3304b004d47eaa7fa0fdd7", "source_url": "https://www.damiencharlotin.com/documents/1986/Coleman_v._Nexo_Capital_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/insd-2026-elbert-coleman-iv-v-nexo-capital", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-elbert-coleman-iv-v-nexo-capital" }, { "decision_id": "ilnd-2026-ella-and-ramin-v-travelers-insurance", "case_name": "Ella and Ramin LLC v. Travelers Insurance Company", "court": "U.S. District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "state": "IL", "date_filed": "2026-03-31", "citation": "2026 WL 891866", "docket_number": "24-cv-07870 as Defendants. Now befor", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the sanctions motion and dismissed nonparty Travelers-related defendants while noting the movant’s admitted AI use and repeated legal misstatements.", "ai_passage": "the argument that Travelers claims, alleged failure to investigate, and reliance on allegedly Insurance Company does not exist as a legal entity. In fact, to false information does not meaningfully depart from a basic some extent, he appears to concede that it might not. 1 breach of contract claim. In the Court's view, such alleged conduct does not even reach the level of “mere insults, Whether Travelers Insurance Company is or is not a separate indignities, threats, annoyances, petty oppressions, or other legal entity is ultimately of no consequence. It is clear trivialities.” Id. And if it did, that still is not enough to support from the attachments to Ghayoori's Amended Complaint that a claim for IIED. Id. TravCo was the insurer that issued the policy in question. (Evid. of Prop. Ins., Dkt. No. 14 (listing “Travco Insurance Ghayoori also asserts that TravCo terminated his policy to Company” as the company that issued the policy); Letter retaliate against him for seeking compensation. Setting aside dated Feb. 24, 2023, Dkt. No. 14 (naming “Travco Insurance the conclusory nature of this allegation, retaliation (even Company” as the insurance company).) Thus, Ghayoori's own", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint and sanctions papers cited nonexistent or irrelevant Illinois insurance authorities while relying on admitted AI-drafted legal research.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "ella-and-ramin-llc-v-travelers-insurance-company", "courtlistener_url": null, "text_sha256": "589aa3e763cda1e1765ca03af0efcf3815dad58f7a14293138dd46c0bc1faae3", "source_url": "https://www.damiencharlotin.com/documents/1928/ELLA_AND_RAMIN_LLC_Plaintiff_v_TRAVELERS_INSURANCE_COMPANY_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-ella-and-ramin-v-travelers-insurance", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-ella-and-ramin-v-travelers-insurance" }, { "decision_id": "ilcd-2026-feldman-and-trost-v-district-6-board", "case_name": "Feldman & Trost v. District 6 Board of Education", "court": "U.S. District Court for the Central District of Illinois", "court_code": "ilcd", "court_level": "federal-district", "state": "IL", "date_filed": "2026-03-31", "citation": null, "docket_number": "d: 03/31/26", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court resolved the motion to dismiss and warned counsel that further false quotations or unsupported legal authorities could trigger sanctions.", "ai_passage": "true and construing all reasonable inferences in the plaintiff’s favor. Id. at 458. To state a claim for relief, a plaintiff need only provide a short and plain statement of the claim showing he is entitled to relief and giving defendants fair notice of the claims. Maddox v. Love, 655 F.3d 709, 718 (7th Cir. 2011). However, the complaint must set forth facts that plausibly demonstrate a claim for relief. Bell Atl. Corp v. Twombly, 550 U.S. 544, 547 (2007). A plausible claim is one that alleges factual content from which the Court can reasonably infer that defendants are liable for the misconduct alleged. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Merely reciting the elements of a cause of action or supporting claims with conclusory statements is insufficient to state a claim. Id. The complaint must do more than assert a right to relief that is “speculative.” Virnich v. Vonvald, 664 F.3d 206, 212 (7th Cir. 2011). B. Analysis4 Throughout their response Plaintiffs cite nonexistent cases or contend that cases, although real, stand for wholly unsupported or undiscussed legal conclusions. For example, Plaintiffs cite “Doe v. Madison Metro. Sch.", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Rost v. Steamboat Springs RE-2 Sch. Dist and Busse v. Motorola, Inc, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "feldman-trost-v-district-6-board-of-education", "courtlistener_url": null, "text_sha256": "8da232d34b66655dfc2c89856aa07cb17c2f4eb8192c8a07c52c7ece8e8c127f", "source_url": "https://www.damiencharlotin.com/documents/1947/Feldman__Trost_v._School_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ilcd-2026-feldman-and-trost-v-district-6-board", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilcd-2026-feldman-and-trost-v-district-6-board" }, { "decision_id": "dcd-2026-zavadovsky-v-republic-of-austria", "case_name": "Zavadovsky v. Republic of Austria, et al.", "court": "U.S. District Court for the District of Columbia", "court_code": "dcd", "court_level": "federal-district", "state": "DC", "date_filed": "2026-03-31", "citation": null, "docket_number": "25-1008 (RC)", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court warned the plaintiffs after cataloging fake quotations, nonexistent cases, and misrepresented holdings that appeared to be AI-generated.", "ai_passage": "id. at (citing a fake quotation from Thomas v. Patton, 939 So. 2d 139 (Fla. Dist. Ct. App. 2006)); id. (citing a case, Young v. District of Columbia, 752 F. Supp. 2d 1 (D.D.C. 2010), that does not exist); Pls.’ Mot. Strike Response at 3 (misrepresenting the effect of Fla. R. App. P. 9.110(b)); id. (citing a case, Beaucage v. Beaucage, 583 So 2d 846 (Fla. 5th DCA 1991), that does not exist); id. (citing a fake quotation from Miller v. Fortune Ins. Co., 484 So. 2d 1221 (Fla. 1986)); Pls.’ Opp’n to Austrian Defs.’ Mot. at 10–11 (misrepresenting a holding from Foremost-McKesson, Inc. v. Islamic Republic of Iran, 905 F.2d 438 (D.C. Cir. 1990)); id. at 13 (misrepresenting a holding from Wheat v. United States, 486 U.S. 153 (1988)). Plaintiffs’ citations to hallucinated authorities bear the hallmarks of reliance on an artificial intelligence (“AI”) tool. See Williams v. Cap. One Bank, N.A., No. 15 24-cv-2032, 2025 WL 843285, at *7 (D.D.C. Mar. 18, 2025) (“Courts have recently seen increasing reliance on artificial intelligence in legal proceedings, leading to the use of nonexistent citations in court documents.”). Plaintiffs insist that", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used fake quotations, nonexistent cases, and misrepresented procedural rules in support of strike and response arguments.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "zavadovsky-v-republic-of-austria-et-al", "courtlistener_url": null, "text_sha256": "bfb11afb2d135dbfa8ac9a9bbd513dc2ae39e5628c4eb568d900762c614c1864", "source_url": "https://www.damiencharlotin.com/documents/1921/Zavadovsky_v._Austria_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/dcd-2026-zavadovsky-v-republic-of-austria", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/dcd-2026-zavadovsky-v-republic-of-austria" }, { "decision_id": "dcd-2026-nguedi-v-general-dynamics-information-technology", "case_name": "Nguedi v. General Dynamics Information Technology", "court": "U.S. District Court for the District of Columbia", "court_code": "dcd", "court_level": "federal-district", "state": "DC", "date_filed": "2026-03-31", "citation": null, "docket_number": "23-2965 (RDM)", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted judgment to the employer and rejected the plaintiff’s filings after finding inaccurate citations and unsupported legal propositions.", "ai_passage": "are the people of Sudan, Ethiopia, Somalia.” Id. at 156 (Nguedi Dep. 156:1–3). “[T]he people who built the pyramids in Africa” are “the true . . . Jews and me, because I’m the Second Coming of course.” Id. (Nguedi Dep. 156:3–7). Plaintiff further believes that “[t]he Jews that are at the Federal Reserve, they are fake first, . . . fake Jews, all of them.” Id. at 149 (Nguedi Dep. 149:10–12). And he believes that “the Jews are going to be put in front” in “the whole white supremacy agenda.” Id. at 114 (Nguedi Dep. 114:21–22). As for the “fake federal reserve,” it appears Plaintiff believes that the Federal Reserve is itself fake. When asked, “What do you mean by that, that term, ‘fake Federal Reserve,’?” Plaintiff responded, “It’s fake. The Federal Reserve is supposed to be a reserve of gold, silver, and bronze. If there is no gold, silver, or bronze, it’s fake. It’s just paper.” Id. at 108 (Nguedi Dep. 108:14–20). Elsewhere, Plaintiff states that the “fake Federal Reserve,” is “printing money out of thin air, infiltrating things to sabotage Black people,” id. at 111 (Nguedi Dep. 111:9–12),", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Brady v. Office of Sergeant at Arms and Figueroa v. Pompeo, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "nguedi-v-general-dynamics-information-technology", "courtlistener_url": null, "text_sha256": "f0293f8729b1f0c96a161a1d2cfe485128e312ff0d985487983d4ff5efa6fb05", "source_url": "https://www.damiencharlotin.com/documents/1909/Nguedi_v._AO_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/dcd-2026-nguedi-v-general-dynamics-information-technology", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/dcd-2026-nguedi-v-general-dynamics-information-technology" }, { "decision_id": "ctsuperct-2026-mohamed-hussain-v-mansoor-quraishi", "case_name": "Mohamed Hussain et al. v. Mansoor Quraishi et al.", "court": "Connecticut Superior Court", "court_code": "ctsuperct", "court_level": "state-trial", "state": "CT", "date_filed": "2026-03-31", "citation": "2026 WL 948918", "docket_number": "Entry 123 for a list of the AI generated/", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The 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.", "ai_passage": "MOHAMED HUSSAIN ET AL. the defendant has statutory right to file the special motion v. to dismiss, the court will consider the defendant's motion to MANSOOR QURAISHI ET AL. dismiss without the AI generated portions of the brief. See order at Docket Entry 123 for a list of the AI generated/ DOCKET NO. TTD-CV25-5019431-S hallucinated portions of the brief. | MARCH 31, 2026 FACTS AND PROCEDURAL BACKGROUND MEMORANDUM OF DECISION RE: DEFENDANT'S General Statutes § 52-196a (e)(2) provides: “When ruling on MOTION TO DISMISS (Entry No. 107.00) a special motion to dismiss, the court shall consider pleadings Graff, J. and supporting and opposing affidavits of the parties attesting to the facts upon which liability or a defense, as the case *1 On October 22, 2025, the defendant, Mansoor Quraishi, may be, is based.” The court finds the following facts based filed a special motion to dismiss, with an accompanying on the complaint, dated August 26, 2025, and the affidavits memorandum of law and exhibits. Docket Entry 107. On submitted by both sides. November 26, 2025, the plaintiffs filed an objection to the special motion to dismiss. Docket Entry 114. On December Mohamed Hussain, is the sole member of VCare Family 3, 2025, the plaintiffs filed a supplemental objection to the Practice LLC. Aiholaney Garcia is an employee of VCare special motion to dismiss. Docket Entry 116. Oral argument Family Practice LLC. From August 2016 to February 14, on the special motion to dismiss was held on December 5, 2018, the defendant provided computer/technological support", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "pending", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "mohamed-hussain-et-al-v-mansoor-quraishi-et-al", "courtlistener_url": null, "text_sha256": "ab51dbb893f504b4edc5e9cc7bbaa45ee711b6a22fba53a3ee230fe4caaee98a", "source_url": "https://www.damiencharlotin.com/documents/1958/Hussain_v._Mansoor_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ctsuperct-2026-mohamed-hussain-v-mansoor-quraishi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ctsuperct-2026-mohamed-hussain-v-mansoor-quraishi" }, { "decision_id": "ctd-2026-christopher-a-ambrose-v-bandy-x-lee", "case_name": "Christopher A. Ambrose v. Bandy X. Lee", "court": "U.S. District Court for the District of Connecticut", "court_code": "ctd", "court_level": "federal-district", "state": "CT", "date_filed": "2026-03-31", "citation": null, "docket_number": "1 at 19", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court cautioned the self-represented defendant that severe AI-assisted misreadings of law could lead to sanctions under Rule 11.", "ai_passage": "334 F.3d 204, 206 (2d Cir. 2003) (per curiam); S. New Eng. Tel. Co. v. Glob. NAPs Inc., Given Defendant’s serious misreading of Tyler, the Court suspects she used artificial intelligence (“AI”) to draft at least that portion of her brief. The Court cautions Defendant that the use, without verification, of the accuracy of the information AI platforms generate—like any other shoddy research method from other sources or tools—implicates Federal Rule of Civil Procedure 11, the central purpose of which is to deter baseless filings in district court and thus to streamline the administration and procedure of the federal courts. Rule 11 applies fully to pro se litigants. Therefore, all parties are on notice that the Court has a no-tolerance policy for any briefing (AI-assisted or not) that hallucinates legal propositions or otherwise severely misstates the law. Such filings will often result in sanctions absent reasonable excuse. See generally Willis v. U.S. Bank Nat’l Ass’n et al, No. 3:25-CV-516-BN, 2025 WL 1408897 (N.D. Tex. May 15, 2025). Defendant makes no separate argument that the service was improper, as opposed to the service of process being improper. Thus, the Court does", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief used fabricated or nonexistent authorities and mischaracterized authorities, including Tyler v. Tyler and Martin v. Hearst Corp, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "christopher-a-ambrose-v-bandy-x-lee", "courtlistener_url": null, "text_sha256": "59441429dbe5ff015a6f263828dd4b623a01af716b01607682d76f775a6a0e96", "source_url": "https://www.damiencharlotin.com/documents/1914/Ambrose_v._Lee_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ctd-2026-christopher-a-ambrose-v-bandy-x-lee", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ctd-2026-christopher-a-ambrose-v-bandy-x-lee" }, { "decision_id": "cacd-2026-leonard-colbert-v-county-of-riverside", "case_name": "Leonard Colbert v. County of Riverside", "court": "U.S. District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "state": "CA", "date_filed": "2026-03-31", "citation": "2026 WL 931542", "docket_number": "d a Reply on October 28", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court admonished counsel after finding a false statutory quotation and no supporting case, federal or state, for the quoted language.", "ai_passage": "Compl. ¶¶ 13-20. Plaintiff's Opposition includes a quotation of purported language from § 845.4 (Opp. at 5); however, the court could not locate the quoted statutory language in § 845.4 or any other section of the California Government Code. Nor could the court find any case, federal or state, containing the quoted language. This suggests counsel may have used artificial intelligence to draft the opposition memorandum and failed to confirm the accuracy of the citations and quotes. All counsel who appear before this court must comply with the California Rules of Professional Conduct and Federal Rules of Civil Procedure and, among other things, not make false statements of fact or law. See, e.g., Cal. R. Prof. Conduct 3.3(a)(1); Fed. R. Civ. P. 11(b)(2). Although this court has not yet enacted rules or orders specifically addressing the use of artificial intelligence, this does not permit counsel to submit a brief with non-existent authority. Cf. Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 461 (S.D.N.Y. 2023) (“A fake opinion is not ‘existing law’ and ... [a]n attempt to persuade court or oppose an adversary by relying on fake opinions is an", "cited_authorities": [ "Fed. R. Civ. P. 11(b)(2)" ], "summary": "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.", "incident": { "conduct": "The opposition brief used multiple nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Mata v. Avianca, Inc, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "leonard-colbert-v-county-of-riverside", "courtlistener_url": null, "text_sha256": "de0d86fa8bb227aed64ffd375d38f760c69c4a4ad3a93129a7dfd3dd91287d77", "source_url": "https://www.damiencharlotin.com/documents/1956/Colbert_v._Riverside_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/cacd-2026-leonard-colbert-v-county-of-riverside", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-leonard-colbert-v-county-of-riverside" }, { "decision_id": "azd-2026-federal-trade-commission-v-james-d-noland", "case_name": "Federal Trade Commission v. James D. Noland, Jr., et al.", "court": "U.S. District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "state": "AZ", "date_filed": "2026-03-31", "citation": null, "docket_number": "CV-20-00047-PHX-DWL", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the emergency stay request and warned the self-represented movant that future inaccurate citations may expose him to sanctions.", "ai_passage": "logical vehicle for seeking some of the categories of relief sought in the emergency stay request. provision of future inaccurate citations may expose them to sanctions. Ghadimi v. Ariz. Bank & Trust, 2025 WL 2928933, *4 (D. Ariz. 2025) (“Ghadimi is proceeding pro se but he still must follow the same rules of procedure that govern other litigants. . . . It appears the incorrect citations may be the result of Ghadimi using artificial intelligence to draft his filings. But whether Ghadimi used artificial intelligence or simply imagined the cases himself, filing documents that contain such cases results in confusion and unnecessary work for opposing parties and the court. In the future, filing documents with fictitious cases will subject Ghadimi to sanctions under Rule 11.”) (citations omitted). Accordingly, IT IS ORDERED that: 1. The Individual Defendants’ Rule 60(b) motion (Doc. 618) is denied. 2. The Individual Defendants’ emergency stay request (Doc. 625) is denied. Dated this 31st day of March, 2026.", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities, including Ghadimi v. Ariz. Bank & Trust, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "federal-trade-commission-v-james-d-noland-jr-et-al", "courtlistener_url": null, "text_sha256": "a109dd11c8c04a6c887bc33b3cc959436c63eb01eb2ecc0e927cc0c69ff1d1a7", "source_url": "https://www.damiencharlotin.com/documents/1891/FTC_v._Noland_USA_31_March_2025.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/azd-2026-federal-trade-commission-v-james-d-noland", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-federal-trade-commission-v-james-d-noland" }, { "decision_id": "azd-2026-chelsea-montes-v-suns-legacy-partners", "case_name": "Chelsea Montes v. Suns Legacy Partners LLC", "court": "U.S. District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "state": "AZ", "date_filed": "2026-03-31", "citation": null, "docket_number": "CV-25-01295-PHX-GMS", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court ordered cost reimbursement, remedial AI education, and notice measures after finding counsel’s filed motion contained fake cases and quotations.", "ai_passage": "from an actual case” that “looks correct.” Francis & Jarral, supra, at 5-6; see also Hayes, 763 F. Supp. 3d at 1065 (“fictitious case citations created by generative AI tools” can “look[] like a real case with a case name”). Thus, Defendant’s adjustment of language in the filed motion, by noting that some of the fictitious “case[s] do[] not exist as cited,” does not substantially alter the grounds of Defendant’s served motion. (Doc. 50 at 8 (emphasis added)). The contention is still the same argument: Plaintiff’s counsel included fabricated cases and quotations that bear the characteristics of AI-hallucinated content.21 20 Defendant notes that it “adjusted certain language from ‘Case does not exist’ in the served version of the motion to ‘Case does not exist as cited’ in the filed motion to distinguish two forms of fake citations found in the offending filings: (1) fake citations where there is not even a case with the same name, and (2) fake citations that include the name of a real case, but which are otherwise fabricated—with made-up dates, courts, or Westlaw or reporter numbers—and where the real case with the same name generally", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion cited fake cases and quotations, including supposed Arizona privilege authorities, that looked real but did not exist as cited.", "outcome": "costs-order", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "chelsea-montes-v-suns-legacy-partners-llc", "courtlistener_url": null, "text_sha256": "effdbd7711ac9a19f0ce8938b8993c2a4baa8a449172bd3dd20fe49d01c78ced", "source_url": "https://www.damiencharlotin.com/documents/1872/Montes_v._Suns_Legacy_Partners_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/azd-2026-chelsea-montes-v-suns-legacy-partners", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-chelsea-montes-v-suns-legacy-partners" }, { "decision_id": "arizctapp-2026-hampton-v-lofton", "case_name": "Hampton v. Lofton", "court": "Arizona Court of Appeals, Division One", "court_code": "arizctapp", "court_level": "state-appellate", "state": "AZ", "date_filed": "2026-03-31", "citation": null, "docket_number": "1 CA-CV 25-0650 FC", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed and denied costs while noting that both self-represented appellate briefs contained hallucinated or unsupported citations.", "ai_passage": "argument because he has shown no error—neither cumulative nor singular. ¶15 It’s worth noting that though Father urges us to disregard Mother’s brief for failing to include citations to the record or legal authority as required by ARCAP 13, Father’s opening brief contained only minimal citations to the record, some of which were hallucinated, supra ¶ 10, and that both his opening and reply briefs contained legal citations that either do not support his positions or appear to be fictitious. See ARCAP 13(a)(7), (d) (requiring citations of legal authorities and references to the record). As for Father’s request that we award him his costs, we deny his request since Father has not succeeded on appeal. As the successful party on appeal, Mother is awarded her costs upon compliance with ARCAP 21. CONCLUSION ¶16 We affirm. MATTHEW J. MARTIN • Clerk of the Court FILED: JR", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief used fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "hampton-v-lofton", "courtlistener_url": null, "text_sha256": "3766f2fc9699f12791de417f8b2ba6d04d9e7b848dbb97d10869f33832af55ea", "source_url": "https://www.damiencharlotin.com/documents/1912/Hampton_v._Lofton_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/arizctapp-2026-hampton-v-lofton", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arizctapp-2026-hampton-v-lofton" }, { "decision_id": "alsd-2026-heimkes-v-fairhope-motorcoach-resort", "case_name": "Heimkes v. Fairhope Motorcoach Resort Condominium Owners Association, Inc.", "court": "U.S. District Court for the Southern District of Alabama", "court_code": "alsd", "court_level": "federal-district", "state": "AL", "date_filed": "2026-03-31", "citation": null, "docket_number": "ACT. NO. 1:22-cv-448-TFM-N", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": "Cocounsel (Westlaw)", "disposition": "The court publicly reprimanded counsel, ordered payment of $55,597 in fees and costs, required notice in related cases, and referred the matter for discipline.", "ai_passage": "Avianca, Inc., 678 F. Supp.3d 443, 448 (S.D.N.Y. 2023). This concept is well known and is a longstanding principle in the practice of law. Yet, the improper use of generative AI is a problem that sadly is not going away despite the general knowledge in the legal community that AI can hallucinate and make up cases. AI hallucination has been reported on extensively in media (not just in the legal context, but at large) and the subject of many seminars and continuing legal education trainings offered by bar associations, articles written in legal journals, and numerous well reported instances of courts sanctioning attorneys. Somehow the message still has not been hammered home as the epidemic of citing fake cases continues unabated. See, e.g. Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024); United States v. McGee, 806 F. Supp. 3d 1264 (S.D. Ala. 2025); Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025); Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341 (E.D.N.Y. 2025); Ferris v. Amazon.com Servs., LLC, 778 F. Supp. 3d 879 (N.D. Miss. 2025); United States v. Hayes, 763 F. Supp. 3d 1054", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Park v. Kim, 91 F.4th 610, 615 and United States v. McGee, which the court found nonexistent, misquoted, or unsupported.", "outcome": "referral", "actor": "lawyer", "monetary_penalty": 55597, "currency": "USD", "ai_tool": "Cocounsel (Westlaw)" }, "tracker_slug": "heimkes-v-fairhope-motorcoach-resort-condominium-owners-association-inc", "courtlistener_url": null, "text_sha256": "1ffd9c8dc4976f57f3422725e5d9bb5eea21cf89ccd6bbbd8ce327344126a4bf", "source_url": "https://www.damiencharlotin.com/documents/1890/Heimkes_v._Fairhope_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/alsd-2026-heimkes-v-fairhope-motorcoach-resort", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alsd-2026-heimkes-v-fairhope-motorcoach-resort" }, { "decision_id": "almd-2026-staley-v-city-of-elba", "case_name": "Staley v. City of Elba, et al.", "court": "U.S. District Court for the Middle District of Alabama", "court_code": "almd", "court_level": "federal-district", "state": "AL", "date_filed": "2026-03-31", "citation": null, "docket_number": "1:24-cv-00141-BL-SMD", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court adopted the recommendation, dismissed claims, and noted that the plaintiff’s response and objections used nonexistent cases and false quotations.", "ai_passage": "Cir.2013) (same). The Supreme Court progenitor in both cases, however, Swierkiewicz v. Sorema N.A., 534 U.S. 506, 122 S. Ct. 992, 152 L.Ed.2d 1 (2002), was overturned in [Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007),] As the Defendants point out, in his response to the motion to dismiss and his objections to the Recommendation, Staley uses citations to cases that do not exist and falsely purports to quote language which does not exist in any case. (Doc. 52 at 10–13); See, e.g., doc. 43 at 23 (purporting to quote Kidd v. Mando Am. Corp., 731 F.3d 1196, 1200 (11th Cir. 2013); doc. 43 at 24 (purporting to cite “Est. of Osorio v. Miami-Dade Cnty., 2023 WL 4003457 (S.D. Fla. June 15, 2023)”); and doc. 49 at 28 (purporting to cite “Greer v. DeKalb County, 2009 WL 10101675, at *4 (N.D. Ga. July 13, 2009)”). and replaced by the more exacting pleading standard discussed in in Twombly and [Ashcroft v. Iqbal, 556 U.S. 662 (2009)]. See Francis v. Giacomelli, 588 F.3d 186, 192 n. 1 (4th Cir.2009) (noting that the pleading standard in Swierkiewicz “was explicitly overruled in Twombly”", "cited_authorities": [ "Greer v. DeKalb County, 2009 WL 10101675" ], "summary": "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.", "incident": { "conduct": "The motion used false quotations and fabricated or nonexistent authorities, including Kidd v. Mando Am. Corp and Osorio v. Miami-Dade Cnty, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "staley-v-city-of-elba-et-al", "courtlistener_url": null, "text_sha256": "25b91d6cfeedd911f7593fde1e2e67a1006d0782c677ef9ffd48cebf30b8c774", "source_url": "https://www.damiencharlotin.com/documents/1911/Staley_USA_31_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/almd-2026-staley-v-city-of-elba", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/almd-2026-staley-v-city-of-elba" }, { "decision_id": "tnwd-2026-randel-edward-page-jr-v-apperson-crump", "case_name": "Randel Edward Page, Jr. v. Apperson Crump", "court": "U.S. District Court for the Western District of Tennessee", "court_code": "tnwd", "court_level": "federal-district", "state": "TN", "date_filed": "2026-03-30", "citation": null, "docket_number": "d on February 25", "document_type": "report-and-recommendation", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the appeal and warned that continued nonexistent, erroneous, or misrepresentative citations after admitted AI drafting could lead to sanctions.", "ai_passage": "DENIED. Lastly, Appellee’s response raises its discovery that Page relied on three nonexistent, erroneous or misrepresentative case citations in his motion for summary reversal. (D.E. 20 at PageID 423 (citing D.E. 11 at PageID 345-46).) The Court’s research confirms Appellee’s report about these citations. In his affidavit, Page addresses these “citation errors,” after admitting that he used “an artificial intelligence tool” to draft “a substantial portion of the legal documents” filed in this appeal. (D.E. 26 at PageID 517.) He states, “I disclose the AI assistance not to excuse the citation errors but to be transparent with this Court about how they occurred and to ensure the record reflects the truth. Every factual assertion in every document I have filed is true to the best PageID 536 of my knowledge.” (Id.) The Court warns Appellant that it may impose sanctions if he continues to submit nonexistent or misrepresentative citations. See Fed. R. Civ. P. 11(b)(2) (“By presenting to the court a pleading, written motion, or other paper . . . an attorney or unrepresented party certifies . . . the claims, defenses, and other legal contentions are warranted by existing", "cited_authorities": [ "Fed. R. Civ. P. 11(b)(2)" ], "summary": "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.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "randel-edward-page-jr-v-apperson-crump", "courtlistener_url": null, "text_sha256": "619df643fac22946e40873983fc1bd958bba98bd09de6241f1168cf4db5dade9", "source_url": "https://www.damiencharlotin.com/documents/1915/Page_v._Apperson_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/tnwd-2026-randel-edward-page-jr-v-apperson-crump", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tnwd-2026-randel-edward-page-jr-v-apperson-crump" }, { "decision_id": "tnwd-2026-edward-reynolds-v-progressive-technologies", "case_name": "Edward Reynolds v. Progressive Technologies, Inc.", "court": "U.S. District Court for the Western District of Tennessee", "court_code": "tnwd", "court_level": "federal-district", "state": "TN", "date_filed": "2026-03-30", "citation": null, "docket_number": "15-2472", "document_type": "report-and-recommendation", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed the magistrate judge’s order and warned that continued fabricated authority could result in dismissal without further warning.", "ai_passage": "routinely strike or disregard overlength briefs filed without leave” are fake ones. (See ECF No. 26 at PageID 272.) The cases either do not exist, or they exist but are not decisions from the courts Plaintiff cites. Nor do the cases stand for the proposition Plaintiff asserts. Judge Christoff exercised her discretion with marked restraint. Because Plaintiff has repeatedly cited fake authority, this Court would be justified in dismissing his case. But the Court will give Plaintiff one more chance to show that he is able to follow the law. As Judge Christoff ordered, Plaintiff must review his citations for accuracy going forward. The Court warns Plaintiff if he continues to cite fabricated legal authority, the Court may dismiss his entire case without any further warning. (ECF No. 54 at PageID 930.) Because the Court finds no legal error in Judge Christoff’s decision, it AFFIRMS her Order and next considers the R&R. PageID 964 II. The R&R Having reviewed the record, the Court finds no clear error in Judge Christoff’s R&R. In fact, the Court agrees with her well-reasoned analysis. A. FMLA Claims Plaintiff brings claims for entitlement and retaliation", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief used multiple fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "edward-reynolds-v-progressive-technologies-inc", "courtlistener_url": null, "text_sha256": "2fb65aa8889d7fadb6af2092b8dbc7fb77772d53cf3cc3525defb38799530506", "source_url": "https://www.damiencharlotin.com/documents/1880/Reynolds_v_Progressive_Technologies_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/tnwd-2026-edward-reynolds-v-progressive-technologies", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tnwd-2026-edward-reynolds-v-progressive-technologies" }, { "decision_id": "ord-2026-yves-hector-vimegnon-v-gallagher-bassett-services", "case_name": "Yves Hector Vimegnon v. Gallagher Bassett Services, Inc.", "court": "U.S. District Court for the District of Oregon", "court_code": "ord", "court_level": "federal-district", "state": "OR", "date_filed": "2026-03-30", "citation": null, "docket_number": "3:25-cv-00572-JR", "document_type": "report-and-recommendation", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court declined to sanction the plaintiff for a single erroneous citation but warned that fabricated authority can lead to monetary sanctions, striking, or dismissal.", "ai_passage": "pages 514-15. Neither Tyler nor O’Donnell have any relevance to the third-party beneficiary issue for which plaintiff cites “Abbot v. Washington County,” nor can the Court locate another relevant case by that name. Although the Court declines to sanction plaintiff for this single erroneous citation for an uncontroversial proposition, plaintiff is warned that inclusion of non-existent or fabricated legal authority in filings with the Court justifies a range of sanctions including monetary penalties, striking of offending briefs, and dismissal of the case. See Couvrette v. Wisnovsky, No. 1:21-cv-00157-CL, 2025 WL 4109655, at *15 (D. Or. Dec. 12, 2025). Because the PAC fails to sufficiently allege that plaintiff is an intended beneficiary, which is a required element for both donee and creditor beneficiaries, the distinction between the two is irrelevant to this decision. defendant settled claims with others involved in the underlying car accident and did not timely inform plaintiff, that it had a “broader role and responsibility that aligns with the functions of an insurer,” and that it failed to reopen the claim file when plaintiff disputed liability, see Pl. Obj. 3, 5—are not relevant to the question of whether", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief used fabricated or nonexistent authorities, including Abbott v. Washington County, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "yves-hector-vimegnon-v-gallagher-bassett-services-inc", "courtlistener_url": null, "text_sha256": "3e62e086c621cde2812912df17f670b07a6cd4f38a7f354ffb6320029d964392", "source_url": "https://www.damiencharlotin.com/documents/1879/Vimegnon_v_Gallagher_Bassett_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ord-2026-yves-hector-vimegnon-v-gallagher-bassett-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ord-2026-yves-hector-vimegnon-v-gallagher-bassett-services" }, { "decision_id": "ord-2026-shaun-fleck-v-del-one-federal", "case_name": "Shaun Fleck v. Del-One Federal Credit Union", "court": "U.S. District Court for the District of Oregon", "court_code": "ord", "court_level": "federal-district", "state": "OR", "date_filed": "2026-03-30", "citation": null, "docket_number": "3:25-cv-01048-SB", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court ordered screening conditions and warned that any further hallucinated legal citations would expose the plaintiff to sanctions or dismissal.", "ai_passage": "case” and the only source on Westlaw that includes the quote that Fleck attributes to the non-existent case is Fleck’s response in this case. Cf. Whiting v. City of Athens, No. 24-5918, --- F.4th ---- , 2026 WL 710568, at *1, *3, *10-13 (6th Cir. Mar. 13, 2026) (sanctioning lawyers for submitting briefing that “cited non-existent cases[] and cited cases for propositions of law that they did not even discuss, much less support,” explaining that the “appeal [was] frivolous as argued because [the lawyers] submitted fake cases, and inventing case law is a misrepresentation of law,” and providing examples that the Sixth Circuit was unable to locate, citations that did “not generate a case,” and an instance in which the “only source on Westlaw” was a lawyer’s “briefing in th[e] case”). It is also important to consider “when AI is used to prepare a brief, ‘AI hallucinations are more likely to occur when there are little to no existing authorities available that clearly satisfy the user’s request—such as, for example, when a [litigant] asks a generative AI tool to supply a citation for an unsupported principle of law.’” Id. at", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief attributed a quotation to a non-existent case and relied on that authority for a proposition not supported by real law.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "shaun-fleck-v-del-one-federal-credit-union", "courtlistener_url": null, "text_sha256": "22f6bf3278d89f143f344f4e28ec1a74679faa9b8656ae6bec455641a5a3273c", "source_url": "https://www.damiencharlotin.com/documents/1884/Fleck_v_Del-One_Federal_Credit_Union_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ord-2026-shaun-fleck-v-del-one-federal", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ord-2026-shaun-fleck-v-del-one-federal" }, { "decision_id": "nywd-2026-beedemariam-kassaw-v-wal-mart", "case_name": "Beedemariam Kassaw v. Wal-Mart Corporation", "court": "U.S. District Court for the Western District of New York", "court_code": "nywd", "court_level": "federal-district", "state": "NY", "date_filed": "2026-03-30", "citation": null, "docket_number": "1619", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court struck the January 2026 filings and ordered the plaintiff to submit any future request to file additional papers as a motion.", "ai_passage": "Under the policy, each instance of employee misconduct is assigned a level of accountability, up to and including termination, based on the severity of the conduct and/or where the employee is in the progressive discipline process. (Id.). The first level of accountability is a yellow disciplinary action (“DA1-Yellow”), followed by an orange disciplinary action (“DA2- Orange”), and the final level of accountability before termination is a red disciplinary action (“DA3-Red”). (Id. at ¶ 23). The policy provides that an employee “may receive only one of each level of disciplinary action in any 12-month period” and “levels may be skipped based on the circumstances.” (Id. at ¶ 24). If an employee achieves a DA3-Red and an additional instance of misconduct warranting disciplinary action occurs, the next level of accountability is termination. (Id. at ¶ 25; see also Dkt. 54-3 at ¶¶ 18-24). Plaintiff was aware of this policy. (Dkt. 54-1 at ¶ 26). In the seven months leading up to his termination, Plaintiff achieved the highest- level disciplinary action. (Id. at ¶ 29). On March 7, 2020, assistant manager David Shepard gave Plaintiff a DA1-Yellow, for excessive meal violations over a", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "strike-off", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "beedemariam-kassaw-v-wal-mart-corporation", "courtlistener_url": null, "text_sha256": "e42e97faa212b838cdd97bbf8aa28e807f3dfe545893df7d0a165a9502a57fd8", "source_url": "https://www.damiencharlotin.com/documents/1885/Kassaw_v._Walmart_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nywd-2026-beedemariam-kassaw-v-wal-mart", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nywd-2026-beedemariam-kassaw-v-wal-mart" }, { "decision_id": "nysd-2026-route-6-holdings-v-town-of-yorktown", "case_name": "76 Route 6 Holdings Inc. v. Town of Yorktown, NY", "court": "U.S. District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "state": "NY", "date_filed": "2026-03-30", "citation": null, "docket_number": "25-CV-693 (KMK)", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the complaint and admonished counsel to verify quotations and authorities after finding nonexistent quotations and misstated precedent.", "ai_passage": "Mar. 31, 2023) (concluding 30-month gap too lengthy). In the Complaint, Plaintiff has not alleged when the comment pertaining to AAA Carting were made, or when the waste hauling bidding occurred. (See generally Compl.) Without allegations as to the timeline—when the comments might have been made years or even decades earlier—the Court cannot rely on temporal proximity to demonstrate causation, even on a Motion to Dismiss. See Nelson v. Argyropoulous, No. 18-CV-11413, 2021 WL 4352313, at *3 (S.D.N.Y. Sept. 24, 2021) (“Because Plaintiff has not set forth a time frame for his complaints, the Court cannot conclude that a close temporal proximity establishes causality.”); Amato v. Elicker, No. 20-CV-464, 2021 WL 1428192, at *6 (D. Conn. Apr. 15, 2021) (dismissing claims where the plaintiffs “allege[d] no dates or other facts” about allegedly targeted events and did “not even allege facts suggesting that the [defendant] was aware that they had hosted these events”). And, assuming the Court has correctly identified the state court litigation referenced in the Complaint, that litigation went on for years prior to the allegedly retaliatory activity described here. Where the “First Amendment[-protected] speech occurred with great regularity", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint quoted language from McEachin and Goel that the court found did not appear in those cases.", "outcome": "warning", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "76-route-6-holdings-inc-v-town-of-yorktown-ny", "courtlistener_url": null, "text_sha256": "f10ff4ba64adc5343593c55b47ff4a86503c06cab089e7c5318f175fd780579e", "source_url": "https://www.damiencharlotin.com/documents/1882/76_Route_6_Holdings_Inc_v_Town_of_Yorktown_New_York_et_al_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nysd-2026-route-6-holdings-v-town-of-yorktown", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-route-6-holdings-v-town-of-yorktown" }, { "decision_id": "mad-2026-souza-v-city-of-fitchburg", "case_name": "Souza v. City of Fitchburg", "court": "U.S. District Court for the District of Massachusetts", "court_code": "mad", "court_level": "federal-district", "state": "MA", "date_filed": "2026-03-30", "citation": null, "docket_number": "23-cv-10140-DJC", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the complaint and warned that generative AI may fabricate law, causes of action, and cases if a filer does not verify it.", "ai_passage": "United States District Judge It is apparent to the Court that Plaintiff relied on generative AI in multiple instances to create his filings. [See e.g. ECF No. 8 at 4 (multiple instances where it appears the generative AI program is speaking directly to Plaintiff, using terms like “you” and “your” to refer to Plaintiff, and “he” to refer to defense counsel)]. While there is no rule requiring litigants to abstain from using generative AI, the Court warns Plaintiff that generative AI is unreliable for legal assistance and often “hallucinates,” where it either misstates the law or completely fabricates causes of actions and caselaw. See Mata v. Avianca, Inc., No. 22-cv-1461 (PKC), 2023 WL 3696209, at *2 (S.D.N.Y. May 4, 2023) (exemplifying generative AI-production of multiple fabricated case citations); see also Allbaugh v. U. of Scranton, No. 3:24-CV-2237, 2025 WL 2484188, at *6 (M.D. Pa. Aug. 28, 2025) (“Increased use of Artificial Intelligence (“AI”), particularly Generative AI (including, but not limited to, OpenAI's ChatGPT or Google's Bard), in the practice of law raises a number of practical concerns for the Court, including the risk that the generative AI tool might generate legally or factually incorrect information, or that it might create unsupported or nonexistent legal citations.”).", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The opposition brief used 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, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "souza-v-city-of-fitchburg", "courtlistener_url": null, "text_sha256": "0fd7667f864dec7cec69ccaa0df2612d864d5feb7f4b16673b260372afc982bf", "source_url": "https://www.damiencharlotin.com/documents/1920/Souza_v._Fichtburg_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/mad-2026-souza-v-city-of-fitchburg", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mad-2026-souza-v-city-of-fitchburg" }, { "decision_id": "indctapp-2026-nicole-olbera-v-tiara-sykes", "case_name": "Nicole Olbera, et al. v. Tiara Sykes", "court": "Indiana Court of Appeals", "court_code": "indctapp", "court_level": "state-appellate", "state": "IN", "date_filed": "2026-03-30", "citation": "2026 WL 860644", "docket_number": "25A-JP-2005 pregnant", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court reached the merits despite briefing defects and warned that the self-represented brief included an apparently hallucinated Indiana case.", "ai_passage": "“must treat a wife as a parent even if she did born in wedlock, while denying an equivalent presumption not provide an egg.” Id. In coming to this conclusion, it to parents in same-sex marriages. Because Ind. Code § found that sections 31-9-2-15, -16, and 31-14-7-1 worked 31-14-7-1(1) does that, its operation was properly enjoined.” together to unconstitutionally discriminate against same-sex Id. at 487. Accordingly, the Seventh Circuit affirmed the couples under the Due Process and Equal Protection Clauses district court's order requiring Indiana to recognize the of the Fourteenth Amendment. Id.; see also Obergefell children of the married, female, same-sex couple plaintiffs v Hodges, 576 U.S. 644, 681 (2015) (finding same-sex “as legitimate children, born in wedlock, and to identify both couples have the constitutional right to marry and be treated wives in each union as parents[.]” Id. at 488. the same as opposite-sex couples in marriage); Pavan v. Smith, 582 U.S. 563, 567 (2017) (holding unconstitutional [22] However, the Seventh Circuit found that some parts of a provision of Arkansas law requiring the birth certificate the district court's remedy were broader than legally justified of a child conceived", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief used fabricated or nonexistent authorities, including Pavan v. Smith, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "nicole-olbera-et-al-v-tiara-sykes", "courtlistener_url": null, "text_sha256": "1bf7162a5e0303945dc805de1cfed8389ed38d9f962b7851770f1bd65dbb81c6", "source_url": "https://www.damiencharlotin.com/documents/1876/Nicole_Olbera_et_al_Appellants_v_Tiara_Sykes_Appellee-Plaintiff.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/indctapp-2026-nicole-olbera-v-tiara-sykes", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/indctapp-2026-nicole-olbera-v-tiara-sykes" }, { "decision_id": "ilnd-2026-williams-v-chicago-board-of-education", "case_name": "Williams v. Chicago Board Of Education", "court": "U.S. District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "state": "IL", "date_filed": "2026-03-30", "citation": null, "docket_number": "s will be consolidated. See 1:24-cv-11729", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court ordered counsel to file a statement explaining the nonexistent quotations, the Engquist misstatement, and whether the same source caused other errors.", "ai_passage": "Arlington Heights, 782 F.3d 911, 917 (7th Cir. 2015): “not every governmental activity that might incidentally prevent crime constitutes ‘police protection service’ within the meaning of section 4-102.’” Pl.’s Resp. Br. at 9. But this quote does not exist. This kind of totally made-up quotations might very well be hallucinated quotations from generative artificial intelligence. What’s more, the brief severely misrepresents the holdings of several other cases, well beyond just an aggressive reading of a holding. For instance, the brief cites Engquist v. Oregon Department of Agriculture, 553 U.S. 591, 598 (2008), to support Williams’s “class-of-one” equal-protection claim. Pl.’s Resp. Br. at 7. But Enquist held that public employees like Williams cannot bring class-of-one claims. Perhaps there are reasonable explanations for how these problems came to be. But because these issues appear throughout the response brief, the Court requires Williams’s counsel to provide a Statement of Explanation to explain (1) how the three identified problems happened (the two non-existent quotations and the citation to Engquist); and (2) whether the source of the problems caused other similar problems in the response brief. The Statement is due by April 13, 2026. V.", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The response brief used two false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including EEOC v. Univ. of Chicago Hospitals and Doe v. Village of Arlington Heights, which the court found nonexistent, misquoted, or unsupported.", "outcome": "pending", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "williams-v-chicago-board-of-education", "courtlistener_url": null, "text_sha256": "72a7b222eda1fd2cf79fefad6cb1c2f92adeb70c2aa74077888a6938358a7435", "source_url": "https://www.damiencharlotin.com/documents/1919/Williams_v._Chicago_Board_of_Education_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-williams-v-chicago-board-of-education", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-williams-v-chicago-board-of-education" }, { "decision_id": "haw-2026-megan-e-bryan-v-child-support-enforcement", "case_name": "Megan E. Bryan v. Child Support Enforcement Agency, State of Hawaiʻi", "court": "Supreme Court of Hawaiʻi", "court_code": "haw", "court_level": "state-supreme", "state": "HI", "date_filed": "2026-03-30", "citation": null, "docket_number": "1UF201006070)", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the mandamus petition and warned that non-existent or hallucinated citations in a family-court filing violate the reasonable-inquiry duty.", "ai_passage": "without merit, as the statute contains no language terminating jurisdiction in the manner asserted. The petition included four additional inaccurate citations, none of which supported the propositions for which they were cited. The petition’s reliance on non-existent or hallucinated case citations strongly suggests that portions of the filing were generated using artificial intelligence (AI). HFCR Rule 11 requires a party to conduct a “reasonable inquiry” to ensure that a filing is “warranted by existing law.” HFCR Rule 11. When a party submits a filing that contains citations to non-existent cases, this conduct on its own constitutes a violation of HFCR Rule 11. The fake case citation makes clear that the party failed to conduct a reasonable inquiry into the validity of the legal authorities cited. This is because a check of the citation would have revealed that the case did not exist. To satisfy Rule 11’s duty of a “reasonable inquiry,” Petitioner was required to verify that each citation was accurate and that the cited authority supports the proposition asserted. Notably, free on-site access to legal research databases is available at the Hawaiʻi State Law Library. Reliance solely on AI-generated content to produce a case filing is inadequate because such content provides no assurance that the citations produced by it are valid or correctly described.", "cited_authorities": [ "HFCR Rule 11" ], "summary": "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.", "incident": { "conduct": "The petition used fabricated or nonexistent authorities and mischaracterized authorities, including State v. Burdett and State v. Masaniai, 63 Haw. 354, 628 P.2d 1018, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "megan-e-bryan-v-child-support-enforcement-agency-state-of-hawai-i", "courtlistener_url": null, "text_sha256": "773118d7a59cc7adcad88f41c0a28c2e832c0c584e2b90578e5ed12351cef40b", "source_url": "https://www.damiencharlotin.com/documents/1881/Bryan_v._Hawaii_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/haw-2026-megan-e-bryan-v-child-support-enforcement", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/haw-2026-megan-e-bryan-v-child-support-enforcement" }, { "decision_id": "ctd-2026-jacobs-v-payward", "case_name": "Jacobs v. Payward, Inc.", "court": "U.S. District Court for the District of Connecticut", "court_code": "ctd", "court_level": "federal-district", "state": "CT", "date_filed": "2026-03-30", "citation": null, "docket_number": "45 at 7", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court admonished the plaintiff that hallucinated citations and excessive exhibits waste judicial resources and undermine the validity of his filings.", "ai_passage": "to the undersigned, is a hallucinated case citation.6 Third, Hottle v. BDO Seidman, LLP, does not discuss CUTPA at all. 268 Conn. 694 (2004). Finally, F.T.C. v. Wyndham Worldwide Corp. is an out-of-circuit case entitled to nothing more than The Court takes this opportunity to address Plaintiff’s inclusion of hallucinated case citations and excessive inclusion of exhibits. Even though Plaintiff is proceeding pro se, Plaintiff still has the responsibility to ensure, to the best of his knowledge, that his pleadings are accurate and that he, or any potential drafting tool he may have used, cites to existing legal authority for his claims. When Plaintiff includes hallucinated case citations in his briefing, it calls into question the validity not only of his arguments, but also the validity of all materials he submits to the Court, including the exhibits he attaches to his pleadings. This concern is compounded when Plaintiff insists on including numerous verbose, redundant, and even irrelevant exhibits. The effect of these superfluous filings, which the Court must review to ensure their accuracy, is a waste of limited judicial resources. persuasive weight and, in any event, by Plaintiff’s own admission,", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief relied on hallucinated or irrelevant CUTPA authorities, including Hottle and Wyndham citations that did not support the propositions asserted.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "jacobs-v-payward-inc", "courtlistener_url": null, "text_sha256": "d4dd1867f091f4dfa1922efb37581e784077ac10d62d394144fe1ffdcd2367e9", "source_url": "https://www.damiencharlotin.com/documents/1878/Jacobs_v._Payward_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ctd-2026-jacobs-v-payward", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ctd-2026-jacobs-v-payward" }, { "court_code": "cod", "state": "CO", "citation": null, "docket_number": "1:25-cv-01991-SKC-MDB", "ai_tool_named": "ChatGPT; Claude; Gemini; Harvey.AI; Bard", "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "3dbd35c3c7b02eed82131552f850f837ad1d554291c19ce51d2eb050b7ad54ba", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": null, "decision_id": "cod-2026-morgan-v-v2x", "case_name": "Morgan v. V2X, Inc.", "court": "U.S. District Court for the District of Colorado", "court_level": "federal-district", "date_filed": "2026-03-30", "document_type": "order", "topics": [ "privilege-work-product", "discovery-ediscovery" ], "primary_topic": "discovery-ediscovery", "court_used_ai": false, "disposition": "The court granted in part and denied in part the motion to amend the protective order and required disclosure of the AI platform used with confidential information.", "ai_passage": "Here, like in Warner v. Gilbarco, Inc., 2026 WL 373043 (E.D. Mich. Feb. 10, 2026), Plaintiff can assert work product protections in connection with his AI use. It is true that AI systems like ChatGPT, Claude, Gemini, and others widely available to the public, collect user data for training and other purposes. But in this Court’s estimation, that does not eliminate all expectations of privacy or automatically waive protections. ... If Plaintiff already submitted Confidential Information to some AI system—and it appears he has—Defendant is entitled to know which system. ... No party or authorized recipient may input, upload, or submit CONFIDENTIAL Information into any modern artificial intelligence platform, including any generative, analytical, or large language model-based tool (“AI”), unless the AI provider is contractually prohibited from: (1) storing or using inputs to train or improve its model; and (2) disclosing inputs to any third party except where such disclosure is essential to facilitating delivery of the service.", "cited_authorities": [ "Warner v. Gilbarco, Inc., 2026 WL 373043 (E.D. Mich. Feb. 10, 2026)", "United States v. Heppner, 2026 WL 436479 (S.D.N.Y. Feb. 17, 2026)", "Fed. R. Civ. P. 26(b)(3)" ], "summary": "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.", "source_url": "https://www.govinfo.gov/content/pkg/USCOURTS-cod-1_25-cv-01991/pdf/USCOURTS-cod-1_25-cv-01991-0.pdf", "verification": "fetched-and-read", "lead_source": [ "GovInfo search", "keyword sweep" ], "url": "https://safelegalai.com/courts/opinions/cod-2026-morgan-v-v2x", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cod-2026-morgan-v-v2x" }, { "decision_id": "ca7-2026-danuta-dec-v-homeland-security", "case_name": "Danuta Dec v. Homeland Security", "court": "U.S. Court of Appeals for the Seventh Circuit", "court_code": "ca7", "court_level": "federal-appellate", "state": null, "date_filed": "2026-03-30", "citation": null, "docket_number": "25-2417", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court admonished counsel for non-existent citations and a false quotation, but declined monetary sanctions because counsel accepted responsibility and showed contrition.", "ai_passage": "No. 25-2417 B This court recently acknowledged the promise and pitfalls of AI in pro se litigation. See Jones v. Kankakee Cnty. Sheriff’s Dep’t, 164 F.4th 967, 970 (7th Cir. 2026). Other courts have also grappled with the use of generative AI in briefing, referring to AI hallucinations and non-existent case citations as repeat offenders. See, e.g., In re Nwaubani, 2026 WL 687194 at *3 (4th Cir. Mar. 11, 2026) (collecting cases). The use of AI will only become more common and sophisticated. So, “we have little doubt that litigants and courts alike will arrive over time at sound and workable practices, policies, and rules that account for these realities and the nuanced consideration they de- serve.” Jones, 164 F.4th at 970. Whatever AI’s future in litigation, our concern lies with trained lawyers failing to check the accuracy of legal citations and quotations in their filings. We remind counsel that this is easier now than ever. Entire briefs can be submitted to Westlaw or LexisNexis to check citations. Though Dec’s coun- sel described her efforts to mitigate future errors, she should have been more careful. Still, she took responsibility and showed contrition. That opposing counsel also failed to catch these errors and bring them to our attention also gives us pause, albeit to a lesser degree.", "cited_authorities": [ "In re Nwaubani, 2026 WL 687194" ], "summary": "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.", "incident": { "conduct": "The brief used false quotations and fabricated or nonexistent authorities, including Jones v. Kankakee Cnty. Sheriff’s Dep’t and In re Nwaubani, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "danuta-dec-v-homeland-security", "courtlistener_url": null, "text_sha256": "76bf93e2a6efa0b7e26eca27d865ca9f94b04c14344d3ea4fe76cb6b3c3b1f9b", "source_url": "https://www.damiencharlotin.com/documents/1870/Danuta_Dec_USA_30_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ca7-2026-danuta-dec-v-homeland-security", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca7-2026-danuta-dec-v-homeland-security" }, { "decision_id": "njsuperctappdiv-2026-o-justin-mcginness-v-liberty-mutual-insurance", "case_name": "Amtrust North America o/b/o Justin McGinness v. Liberty Mutual Insurance Company", "court": "Superior Court of New Jersey, Appellate Division", "court_code": "njsuperctappdiv", "court_level": "state-appellate", "state": "NJ", "date_filed": "2026-03-27", "citation": null, "docket_number": "A-2587-24", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed in part, remanded for dismissal without prejudice, and imposed a $1,000 personal sanction on appellate counsel.", "ai_passage": "look like real cases as they are identified by a case name, a citation dismissal. Indeed, we do not know whether the proper to a reporter, the name of a district or appellate [*9] insurance company would have denied the claim as it court, and the year of the decision. But they are not real has never been tendered to it. cases. However, our review of this matter does not end there. Citation of hallucinated caselaw violates the RPCs, as As stated, plaintiff's counsel cites to four cases in his noted in the Supreme Court's Preliminary AI Guidelines: merits brief that do not exist: RPC 3.3 requires a lawyer to uphold candor to the • \"Aetna Cas. & Sur. Co. v. Hanna, 224 N.J. Super. 462 tribunal, including by not knowingly making \"a false (App. Div. 1988).\" Plaintiff cites this case with the following parenthetical: (\"the Appellate Division affirmed 9 A- 2587-24 a workers' compensation carrier's right to subrogation statement of material fact or law . . . .\" or offering against an employee's personal UIM benefits.\") This \"evidence that the lawyer knows to be false . . . .\"", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief cited four fabricated insurance cases that resembled real reporter citations but did not exist.", "outcome": "costs-order", "actor": "lawyer", "monetary_penalty": 1000, "currency": "USD", "ai_tool": null }, "tracker_slug": "amtrust-north-america-o-b-o-justin-mcginness-v-liberty-mutual-insurance-company", "courtlistener_url": null, "text_sha256": "8a1673e0615827622e8b47d4b8e587072d3c64ef7c9f935ed811a26dbba9e1d0", "source_url": "https://www.damiencharlotin.com/documents/1827/Amtrust_N._Am._O_B_O_Justin_McGinness_v._Liberty_Mut._Ins._Co_USA_27_March_2026.Pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/njsuperctappdiv-2026-o-justin-mcginness-v-liberty-mutual-insurance", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/njsuperctappdiv-2026-o-justin-mcginness-v-liberty-mutual-insurance" }, { "decision_id": "mied-2026-pizzimenti-v-city-of-detroit", "case_name": "Pizzimenti v. City of Detroit, et al.", "court": "U.S. District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "state": "MI", "date_filed": "2026-03-27", "citation": null, "docket_number": "25-11506", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the claims and warned that factitious citations in the complaint and motion could be treated as AI-created hallucinations.", "ai_passage": "Court has noticed factitious citations in other filings by Plaintiff, such as the complaint. 4 The Court is concerned by these factitious citations, which may be created by generative artificial intelligence (“AI”) tools. See United States v. Hayes, 763 F. Supp. 3d 1054, 1065 (E.D. Cal. 2025). “It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, Plaintiff’s complaint (ECF No. 1) contains factitious citations. As previously mentioned, see supra n.2, Plaintiff’s reference to Opulent Life Church, 697 F.3d 279, related to his Eighth Amendment claim does not make sense. (See ECF No. 1, PageID.10.) Additionally, the complaint makes repeated references to “Thaxton v. City of Pontiac, No. 298862, 2011 WL 522951 (Mich. Ct. App. Feb. 15, 2011),” (ECF No. 1, PageID.8, 9), but this case does not exist. Similarly, the complaint references “Smith v. State, 26 N.E.3d 1167 (Ind. 2015)” (ECF No. 1, PageID.3, 5, 6, 17, 18), but the Court is unable to find a case resembling this citation that has any relevance to the issues raised in this case. courts have seen a rash of cases in", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used 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, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "pizzimenti-v-city-of-detroit-et-al", "courtlistener_url": null, "text_sha256": "bb2aa4cd62afdbbfe7f9664d6cc455eb5dc6531a6ef183cc247bdadd94c7cb74", "source_url": "https://www.damiencharlotin.com/documents/1877/Pizzimenti_USA_27_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/mied-2026-pizzimenti-v-city-of-detroit", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-pizzimenti-v-city-of-detroit" }, { "decision_id": "mied-2026-patrick-c-shaltry-i-v-brent-benzing", "case_name": "Patrick C. Shaltry, I v. Brent Benzing, et al.", "court": "U.S. District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "state": "MI", "date_filed": "2026-03-27", "citation": null, "docket_number": "1:25-cv-13704", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court warned the plaintiff that repeated false quotations and citations, including apparent AI hallucinations, would lead to sanctions for future violations.", "ai_passage": "final conviction and is presumed innocent while his appeal of right remains pending.” (E.g., ECF No. 31, PageID.620 (emphasis in original)). Because his appeal of right is still ongoing, Plaintiff contends that, as a matter of law, he has not been “convicted.” (Id.). In support, Plaintiff appears to quote several cases that, upon review, appear to be AI hallucinations. 2 (See ECF No. 29, PageID.605–06). For example, Plaintiff cites People v. Swafford, 762 N.W.2d 902, 904–05 (Mich. 2009), and attributes this quote to the case: “A conviction is not final until the completion of the direct appeal.” Although this case is real, the asserted quote is found nowhere within the case. The closest the cited case comes to Plaintiff’s proposition actually cuts the other way— that the defendant was convicted, notwithstanding that the conviction may later be overturned on appeal. See Id. at 905 n.5 (“Accordingly, the trial court did not have proper jurisdiction to bring defendant to trial or convict defendant.”). Thus, although AI “hallucinations” are instances where AI programs make stuff up. See Hunt v. Morissette, No. 24-cv-12947, 2025 WL 1660358, at *1 (E.D. Mich. June 11, 2025).", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief used several false quotations and fabricated or nonexistent authorities, including People v. Swafford and People v. Kennedy, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "patrick-c-shaltry-i-v-brent-benzing-et-al", "courtlistener_url": null, "text_sha256": "4a996bfec8d44e51a8256b59a3243c662218cb2058c0f8d4523155a35a56bc1f", "source_url": "https://www.damiencharlotin.com/documents/1924/Shaltry_v._Benzing_USA_27_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/mied-2026-patrick-c-shaltry-i-v-brent-benzing", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-patrick-c-shaltry-i-v-brent-benzing" }, { "decision_id": "nvd-2026-anthony-wallace-v-pennymac-loan-services", "case_name": "Anthony Wallace v. PennyMac Loan Services, LLC, et al.", "court": "U.S. District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "state": "NV", "date_filed": "2026-03-26", "citation": "2026 WL 837418", "docket_number": "17 at 2", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted amendment in part, denied the motion to dismiss as moot, and warned that fake AI-drafted cases must be verified.", "ai_passage": "and as the result of using generative AI software, like ChatGPT, deny the motion to dismiss (ECF No. 6) as moot. to draft pleadings. Chavez-DeRemer v. NAB, LLC, No. 2:21- Wallace moves to amend and attaches a proposed second CV-00984-JAD-EJY, 2025 WL 2308676, at *3 (D. Nev. amended complaint. ECF No. 43-1. The defendants oppose, Aug. 11, 2025). Generative AI often invents fake cases and arguing amendment is futile and Wallace is repeatedly legal precedent in its drafting, and using it is no excuse for amending to prolong the proceedings and stave off not verifying the veracity of citations. See Whiting, 2026 foreclosure. WL 710568, at *4 (“Citing even a single fake case can be sanctionable because no brief, pleading, motion, or any *4 I must “freely give leave” to a plaintiff to amend his other paper filed in any court should contain any citations complaint “when justice so requires.” Fed. R. Civ. P. 15(a)(2). —whether provided by generative AI or any other source I am to apply this policy “with extreme liberality.” Eminence —that a lawyer [or pro se party] has not personally read Cap., LLC v. Aspeon, Inc.,", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used false quotations and fabricated or nonexistent authorities, including Bally v. Home Loan Servicing, LP, No. 2:09-cv-02445-MCE-KJM and Pasillas v. HSBC Bank USA, N.A., No. 2:12-cv-01107, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "anthony-wallace-v-pennymac-loan-services-llc-et-al", "courtlistener_url": null, "text_sha256": "7df65b0094d6102c70da217d0929ea1db461682fbcfe85c13a7d9bb795bb92ce", "source_url": "https://www.damiencharlotin.com/documents/1841/Wallace_v._Pennymac_USA_26_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nvd-2026-anthony-wallace-v-pennymac-loan-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-anthony-wallace-v-pennymac-loan-services" }, { "decision_id": "njd-2026-baker-v-rastelli-foods", "case_name": "Baker v. Rastelli Foods LLC", "court": "U.S. District Court for the District of New Jersey", "court_code": "njd", "court_level": "federal-district", "state": "NJ", "date_filed": "2026-03-26", "citation": null, "docket_number": "24–cv–08882–ESK–AMD", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the patent claims without prejudice and required plaintiffs to provide PDFs and highlighted support for cited cases before amendment.", "ai_passage": "200, 209 (3d Cir. 2021). But plaintiffs will not be permitted to file an amended complaint without also meeting additional requirements. Rastelli Defendants have requested that the Court impose a filing injunction on plaintiffs or, in the alternative, prohibit plaintiffs from using artificial intelligence to prepare filings or require that plaintiffs include affidavits with their filings indicating whether they have used artificial intelligence or other assistance. (Rastelli Defs.’ Mot. Br. pp. 35–37.) Plaintiffs contend that Rastelli Defendants’ request is a distraction intended to avoid accountability by constraining plaintiffs’ efforts to enforce their rights. (Pls.’ Opp’n Br. – Rastelli p. 10.) Somewhat surprisingly, Rastelli Defendants do not appear to have reviewed the cases cited in the complaint. The Court has. Multiple cases cited by plaintiffs are so inaccurately cited that the Court is unable to locate them, assuming they exist at all. This represents a separate—and potentially more egregious—issue than Rastelli Defendants’ assertion that the sources cited by plaintiffs in their opposition do not support their stated propositions (Rastelli Defs.’ Reply Br. pp. 17–19), which itself warrants Court action. Plaintiffs’ use of a quotation that does not appear in the cited", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The opposition brief used multiple false quotations and fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "pending", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "baker-v-rastelli-foods-llc", "courtlistener_url": null, "text_sha256": "123a6211c4233825e60c51937299502dc3eb2c53d18f0f3ff7c640ce0db297d3", "source_url": "https://www.damiencharlotin.com/documents/1922/Baker_v._Rastelli_Foods_USA_26_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/njd-2026-baker-v-rastelli-foods", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/njd-2026-baker-v-rastelli-foods" }, { "decision_id": "nced-2026-curry-v-capital-one-auto-finance", "case_name": "Curry v. Capital One Auto Finance", "court": "U.S. District Court for the Eastern District of North Carolina", "court_code": "nced", "court_level": "federal-district", "state": "NC", "date_filed": "2026-03-26", "citation": null, "docket_number": "P. 12(b)(6). The focus is on", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied leave to amend because the proposed amended complaint’s additional fabricated citations showed bad faith and amendment would be futile.", "ai_passage": "so requires. Fed. R. Civ. P. l 5(a). Leave to amend should only be denied where there is bad faith on the part of the moving party, the amended would be futile , or granting leave would prejudice the non-moving party. See Johnson v. Oroweat Foods Co., 785 F.2d 503 , 509 (4th Cir. 1986). Here, plaintiffs inclusion of more fabricated citations in the proposed amended complaint constitutes bad faith . The motion for leave to amend is also denied because amendment would be futile. \"Futility is apparent if the proposed amended complaint fails to state a claim under the applicable rules and accompanying standards[.]\" Katyle v. Penn Nat. Gaming, Inc. , 637 F.3d 462, 471 (4th Cir. 2011). An amendment is therefore futile where the plaintiff fails to state a facially plausible claim, meaning that the facts pled \"allow[] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.\" Iqbal, 556 U.S. at 678. Courts should be liberal in their construction of pro se complaints, but they should not go beyond deciphering the meaning of words written in the complaint to attempt to", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used nonexistent or misstated legal provisions and fabricated or nonexistent authorities, including Johnson v. Oroweat Foods Co and Katyle v. Penn Nat. Gaming, Inc, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "curry-v-capital-one-auto-finance", "courtlistener_url": null, "text_sha256": "6e30ef67a8f8f61f8d521503c2d8b0d363cf4593fc1e5b73d78501a5fcebdabc", "source_url": "https://www.damiencharlotin.com/documents/1918/Curry_v._Capital_One_Finance_USA_26_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nced-2026-curry-v-capital-one-auto-finance", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nced-2026-curry-v-capital-one-auto-finance" }, { "decision_id": "mnd-2026-l-h-m-v-u-s-department", "case_name": "The Advocates for Human Rights and L.H.M. v. U.S. Department of Homeland Security, et al.", "court": "U.S. District Court for the District of Minnesota", "court_code": "mnd", "court_level": "federal-district", "state": "MN", "date_filed": "2026-03-26", "citation": null, "docket_number": "0:26-cv-00749-NEB-DLM", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court rejected defendants’ heightened-injunction argument after identifying misquotations and miscites in their brief and receiving unsatisfactory explanations at the hearing.", "ai_passage": "the hold increased detainee time at Whipple; indeed, overcrowding has decreased since the TRO. (Ex. 346 (sealed); ECF No. 143 (“Simard Decl.”) ¶¶ 12–13, 15.) B. Locating Detainees Before the TRO, Defendants transferred people so quickly that even Defendants struggled to locate detainees. (Glenn Decl. ¶ 5 (“In two of my cases, for example, [the government] was unable to locate my clients for days after transporting them out of state.”).) Often, Defendants did not accurately or timely input information into the Online Detainee Locator System (“ODLS”). (Tr. at 223 (explaining that before the TRO, it took “hours, sometimes days after the initial detention” to update the ODLS).) The ODLS either produced no search results or instructed attorneys to call for details, referencing a Joint exhibit admitted on the record; not filed. CASE 0:26-cv-00749-NEB-DLM Doc. 178 Filed 03/26/26 Page 10 of 69 phone number that ICE did not answer. (Tr. 238 (“Every time I have called, it has just rang and rang and rang.”); Kelley Decl. ¶¶ 16, 18; Glenn Decl. ¶ 4 (“[E]very time I have tried to call ICE’s St. Paul Field Office I am met with a busy", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief used false quotations that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "other", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "the-advocates-for-human-rights-and-l-h-m-v-u-s-department-of-homeland-security-e", "courtlistener_url": null, "text_sha256": "4a44b98a161b7c4b34b60563813ca56396de82d538176701806dd28eeb69ccfb", "source_url": "https://www.damiencharlotin.com/documents/1859/Advocates_for_Human_Rights_v._ICA_USA_26_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/mnd-2026-l-h-m-v-u-s-department", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mnd-2026-l-h-m-v-u-s-department" }, { "decision_id": "gao-2026-mission-critical-project-services", "case_name": "Mission Critical Project Services, Inc.", "court": "U.S. Government Accountability Office", "court_code": "gao", "court_level": "federal-specialty", "state": null, "date_filed": "2026-03-26", "citation": null, "docket_number": "B-424081.2", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The Office warned the protester that future filings with non-existent authority may result in sanctions after reviewing erroneous AI-like citations.", "ai_passage": "propositions asserted by MCPS, and non-existent decisions. See Electronic Protest Docketing System (Dkt.) No. 8, Response to Dismissal Request; Dkt. No. 12, Appendix A, GAO Decisions Cited. MCPS’ erroneous citations bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) without adequate verification that the generated results were accurate. See KE Sys. Servs., Inc., B-423881 et al., Dec. 22, 2025, at 6. The use of AI programs to draft or assist in drafting legal filings can result in the citation of non-existent decisions, such that reliance on those programs without review for accuracy wastes the time of all parties and GAO. Raven Investigations & Sec. Consulting, LLC, B-423447, May 7, 2025, at 4. As we have explained, our Office necessarily reserves an inherent right to dismiss any protest and to impose sanctions against a protester, where a protester’s actions undermine the integrity and effectiveness of our process. Raven, supra. The protester is advised that any future submission of filings with citations to non-existent authority may, after a review of the totality of the circumstances, result in the imposition of sanctions. Id. Page 6 B-424081.2", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "warning", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "mission-critical-project-services-inc", "courtlistener_url": null, "text_sha256": "d905942147a08bbf28da657c67c91ee476add6b7c047fab65a31a423dc096f49", "source_url": "https://www.damiencharlotin.com/documents/1856/Mission_Critical_Project_Serv._B-424081.2_March_26_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/gao-2026-mission-critical-project-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gao-2026-mission-critical-project-services" }, { "decision_id": "alnd-2026-state-national-insurance-v-damon-treadwell", "case_name": "State National Insurance Company, Inc. v. Damon Treadwell, et al.", "court": "U.S. District Court for the Northern District of Alabama", "court_code": "alnd", "court_level": "federal-district", "state": "AL", "date_filed": "2026-03-26", "citation": null, "docket_number": "2:24-cv-1424-HDM", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": "ChatGPT; OpenCase", "disposition": "The court publicly reprimanded counsel and ordered notice of the reprimand after counsel admitted ChatGPT and OpenCase produced made-up quotations.", "ai_passage": "the final version did, in fact, exist. Transcript of Show-Cause Hearing at 21–22 (March 26, 2026). Mr. May confirmed that the quotations were hallucinations of one or both of two popular generative artificial intelligence (“AI”) applications used by Mr. May—ChatGPT and OpenCase. (Doc. 69 at 2). In simpler terms, the quotes Mr. May cited were completely made up and resulted from what Mr. May admits was a “lack of diligence” on his part. (Doc. 69 at 3). FINDINGS OF FACT AND CONCLUSIONS OF LAW Citations to fake legal authority pose a serious threat to the fair administration of justice and the integrity of the judicial system, and they require an equally serious sanction. Johnson v. Dunn, 792 F. Supp. 3d 1241, 1246 (N.D. Ala. 2025). This court has stated, Even in cases like this one, where lawyers who cite AI hallucinations accept responsibility and apologize profusely, much damage is done. . . . [T]he court spends time reviewing materials, holding hearings, deliberating about sanctions, and explaining its ruling; the substance of the case is delayed; and public confidence about the trustworthiness of legal proceedings may be diminished. Id. at 1257", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used false quotations and fabricated or nonexistent authorities, including Co. v. Houston National Bank and Whelan v. Abell, which the court found nonexistent, misquoted, or unsupported.", "outcome": "sanctions", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": "ChatGPT; OpenCase" }, "tracker_slug": "state-national-insurance-company-inc-v-damon-treadwell-et-al", "courtlistener_url": null, "text_sha256": "f01c007dbbfef89c6f102e9fabdb4da5edaf6527b34eedb4971333e20cb1ca1d", "source_url": "https://www.damiencharlotin.com/documents/1916/State_National_v._Dimon_Treadwell_USA_27_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/alnd-2026-state-national-insurance-v-damon-treadwell", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/alnd-2026-state-national-insurance-v-damon-treadwell" }, { "decision_id": "ohnd-2026-hong-chris-lu-v-capital-one-n", "case_name": "Hong Chris Lu v. Capital One, N.A., et al.", "court": "U.S. District Court for the Northern District of Ohio", "court_code": "ohnd", "court_level": "federal-district", "state": "OH", "date_filed": "2026-03-25", "citation": null, "docket_number": "1:25-cv-1057", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the case with prejudice and treated the repeated fake cases in successive filings as a factor supporting dismissal.", "ai_passage": "conference, was not in compliance with the Court’s standing order regarding discovery and sanction motions, Doc. 36. Lu then filed, in opposition to Capital One’s dismissal motion, a brief which contained numerous fake cases and other troubling citation inconsistencies. Doc. 39. After Capital One pointed this out, Doc. 41, at 2, Lu submitted another filing with fake cases, Doc. 43. The Court issued a show cause order to Lu, non- document Order (filed October 22, 2025), and Lu apologized and withdrew or corrected his filings, Doc. 47. That same month, problems between Lu and HP began to surface. HP had asked for inspection of the allegedly defective computer that Lu purchased from HP, Doc. 50, but Lu refused to produce the computer for inspection, Doc. 51. The Court held a conference on October 29 and ruled that Lu must produce the computer for inspection. Doc. 52, at 1–2. The parties agreed that HP’s counsel would pick up the computer from Lu’s residence on November 3. Id. On October 29, Lu filed on the docket a “Notice regarding compliance” with the Court’s Minute Order, “confirm[ing] that HP would inspect the computer", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The opposition brief used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "dismissal", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "hong-chris-lu-v-capital-one-n-a-et-al", "courtlistener_url": null, "text_sha256": "00ec462d15c357736ccd26cbc7299ef6f25f6033b20d57e83ed608fb4e55daa7", "source_url": "https://www.damiencharlotin.com/documents/1830/LU_v._Capital_One_USA_25_March_2025.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ohnd-2026-hong-chris-lu-v-capital-one-n", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohnd-2026-hong-chris-lu-v-capital-one-n" }, { "decision_id": "nysd-2026-fecteau-v-safety-national-casualty", "case_name": "Fecteau v. Safety National Casualty Corporation", "court": "U.S. District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "state": "NY", "date_filed": "2026-03-25", "citation": null, "docket_number": "25-CV-3821", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court imposed Rule 11 sanctions for repeated arguments that included fictitious statutory language and false legal support.", "ai_passage": "National also requests sanctions on several different bases that essentially boil down to the following: Plaintiff has repeatedly made, without complying with the Court’s Individual Rules, seriatim filings that assert the same meritless arguments. (Dkt. No. 94 at 24– 27.) He persisted in doing so even after Safety National directed him to binding authority that foreclosed his arguments. (Id.) Several of these filings involve fabricated quotes and, in one case, statutory language that simply does not exist (as described above). (Id. at 15, 25–26.) In some of these filings, Safety National says, Plaintiff continued to make baseless representations in his filings as to the Defendants’ corporate citizenship. (Id. at 25–26.) Plaintiff has, indeed, filed an excessive number of repetitive motions without authorization. By the Court’s assessment, each of his primary arguments in favor of remand was raised in at least two Motions, as laid out further in footnotes.34 Many of these Motions were on “the intent of the potentially sanctionable conduct, not on its effect”). Plaintiff’s withdrawal of the direct claims further supports the conclusion that the filing of the Amended Complaint and Complaint alleging direct claims are not worth", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used one nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Conroy v. Aniskoff, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "fecteau-v-safety-national-casualty-corporation", "courtlistener_url": null, "text_sha256": "1497966dd585dddd243f39a61966cf8c04d047dbe79bd39c5260351ebf9d740e", "source_url": "https://www.damiencharlotin.com/documents/1826/Fecteau_USA_25_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nysd-2026-fecteau-v-safety-national-casualty", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-fecteau-v-safety-national-casualty" }, { "decision_id": "fladistctapp4-2026-elilton-alves-gouveia-v-meridian-financial-investments", "case_name": "Elilton Alves Gouveia v. Meridian Financial Investments", "court": "Florida Fourth District Court of Appeal", "court_code": "fladistctapp4", "court_level": "state-appellate", "state": "FL", "date_filed": "2026-03-25", "citation": null, "docket_number": "4D2025-0843", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court cautioned the self-represented appellant, in prose and a limerick, that future briefs with nonexistent cases may invite sanctions.", "ai_passage": "• AI Spotted There once was a litigant pro se, Who let an AI lead the way. It briefed every claim, Cited cases—by name, That vanished by morning’s next day. Limerick on Pro Se Parties Using Artificial Intelligence (on file with the Fourth District Court of Appeal) (generated by ChatGPT 5.2). It appears to us the defendant used a large language model (LLM) 1 to write his briefs. Popular LLMs include OpenAI’s ChatGPT, Google’s Gemini, and Microsoft’s Copilot. See In re Kenney, 2025-0389 (La. App. 5 Cir. 10/23/25), 422 So. 3d 905, 912 n.5. Technology, specifically artificial intelligence, is a marvel of the age we live in. It is an important and productive tool, but left unchecked for accuracy and legitimacy, it can be a plague upon the judicial system, creating more problems than it solves, and resulting in violation of the rules of appellate procedure. As Judge Forst reminded us: An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system [….] Many harms flow from the submission of fake opinions [….] These include wasting the opposing party’s time LLMs “are [artificial intelligence] systems that aim to model language, sometimes using millions or billions of parameters[.]” See LAURIE HARRIS, CONG. RSCH. SERV., IF12426, GENERATIVE ARTIFICIAL INTELLIGENCE: OVERVIEW, ISSUES,", "cited_authorities": [ "In re Kenney, 2025-0389" ], "summary": "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.", "incident": { "conduct": "The appellate brief used fabricated or nonexistent authorities and mischaracterized authorities, including In re Kenney, 2025-0389, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "elilton-alves-gouveia-v-meridian-financial-investments", "courtlistener_url": null, "text_sha256": "cc5720e8e018eaa4187f142fc60a1889477d01969799bd55dc35b869821f232b", "source_url": "https://www.damiencharlotin.com/documents/1822/Elilton_v._Meridian_USA_25_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-elilton-alves-gouveia-v-meridian-financial-investments", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-elilton-alves-gouveia-v-meridian-financial-investments" }, { "decision_id": "cacd-2026-jared-ashcraft-v-first-citizens-bank", "case_name": "Jared Ashcraft v. First-Citizens Bank and Trust Company, et al.", "court": "U.S. District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "state": "CA", "date_filed": "2026-03-25", "citation": "2026 WL 851435", "docket_number": "2:26-cv-02251-JLS (JDEx)", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the motion for discovery sanctions and advised that false citations in future briefs may result in sanctions.", "ai_passage": "apply. properly served with process. See Fed. R. Civ. P. 4(b), (c) (1). Absent such service, the Court lacks personal jurisdiction over Defendants and Plaintiff may not seek sanctions against *2 Courts may deny discovery motions for failure to comply such unserved parties. with the Local Rules' requirements for such motions. See Pina v. Lewis, 717 F. App'x 739, 740 (9th Cir. 2018) (district Nonetheless, even assuming Defendants were properly served court may properly deny a motion to compel “for failing to with a proper summons and the Complaint on March 13, comply with local rules”); see also Tri-Valley CARES v. U.S. 2026, Defendants would not have been subject to this Court's Dep't of Energy, 671 F.3d 1113, 1131 (9th Cir. 2012) (“Denial rules of procedure before that time. Thus, again assuming a of a motion as the result of a failure to comply with local proper service of process had been effected on March 13, rules is well within a district court's discretion.”); Lumber 2026, the earliest Plaintiff could have sent a compliant L.R. Liquidators, Inc. v. Sullivan, 2012 WL 4464867, at *4 (C.D. 37-1 meet and confer letter", "cited_authorities": [ "Inc. v. Sullivan, 2012 WL 4464867" ], "summary": "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.", "incident": { "conduct": "The complaint cited a nonexistent Plantronics decision while seeking discovery sanctions.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "jared-ashcraft-v-first-citizens-bank-and-trust-company-et-al", "courtlistener_url": null, "text_sha256": "954a83171419412b2d7e553b79a195e204537ccf6425f5507ee57934ea94ee0f", "source_url": "https://www.damiencharlotin.com/documents/1927/Jared_Ashcraft_v_First-Citizens_Bank_and_Trust_Company_et_al_USA_25_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/cacd-2026-jared-ashcraft-v-first-citizens-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-jared-ashcraft-v-first-citizens-bank" }, { "decision_id": "almd-2026-michael-a-devita-v-midtown-motors", "case_name": "Michael A. DeVita v. Midtown Motors, et al.", "court": "U.S. District Court for the Middle District of Alabama", "court_code": "almd", "court_level": "federal-district", "state": "AL", "date_filed": "2026-03-25", "citation": null, "docket_number": "1:25-cv-435-RAH-KFP", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the complaint without prejudice and warned that hallucinated citations and shotgun pleading defects did not state a claim.", "ai_passage": "Complaint such as “Lipham v. General Motors LLC, 665 F.3d 1314 (11th Cir. 2011),” “Zinnerman v. Williams, 749 So. 2d 453 (Ala. Civ. App. 1999),” and “FTC v. Sage Auto Group, No. 16-cv-07329 (C.D. Cal. 2016)” that do not appear to exist and therefore appear to be hallucinated. The hallucinated case citations and overall nature and format of the pleading strongly suggest that DeVita is using some form of generative artificial intelligence to draft his complaints. That generative AI may be used or consulted does not mean that an AI-generated complaint is legally sufficient or that DeVita is excused from ensuring the accuracy of his case citations and legal authorities. Whether true or not, the point remains that DeVita has not filed a legally sufficient complaint and has announced his position that he will not file another one. As such, an order from this Court to file another complaint is not warranted. Accordingly, upon an independent and de novo review of the record, it is ORDERED as follows: 1. Plaintiff’s Objections (doc. 30) are OVERRULED; 2. The Recommendation (doc. 28) of the Magistrate Judge is ADOPTED; 3. Plaintiff’s Motion to Recuse (doc. 31) is DENIED as moot; and 4. This case is DISMISSED without prejudice. DONE and ORDERED on this the 25th day of March 2026. R. AUSTIN HUFFAKER, JR. CHIEF UNITED STATES DISTRICT JUDGE", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used fabricated or nonexistent authorities, including Lipham v. General Motors LLC and Zinnerman v. Williams, which the court found nonexistent, misquoted, or unsupported.", "outcome": "dismissal", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "michael-a-devita-v-midtown-motors-et-al", "courtlistener_url": null, "text_sha256": "4e61ba19a5a929a91e274c35c6fa06f3c192bc510d59e870df65ae27973005bf", "source_url": "https://www.damiencharlotin.com/documents/1835/Devita_v._Midtown_USA_25_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/almd-2026-michael-a-devita-v-midtown-motors", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/almd-2026-michael-a-devita-v-midtown-motors" }, { "decision_id": "flsd-2026-jorge-a-zea-v-national-association-of", "case_name": "Jorge A. Zea v. National Association of REALTORS", "court": "U.S. District Court for the Southern District of Florida", "court_code": "flsd", "court_level": "federal-district", "state": "FL", "date_filed": "2026-03-24", "citation": null, "docket_number": "25-cv-81016-DIMITROULEAS/MATTHEWMAN", "document_type": "report-and-recommendation", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The magistrate judge recommended dismissal without prejudice and admonishment after finding that the plaintiff’s quotations and legal concepts were AI-hallucinated.", "ai_passage": "Response in opposition to all of Defendants’ arguments. As noted in Defendants’ Reply, Plaintiff has cited in large part to artificial intelligence (“AI”)-hallucinated law. While the cases Plaintiff relies on do exist, the quotations, and even most of the legal concepts, are fake. Plaintiff filed a Notice of Spoliation in which he apologizes to the court, Defendants, and Defendants’ counsel for his AI-related mistakes. [DE 71 at 3]. However, Plaintiff only acknowledges that one citation was incorrectly included in his Response and that “two drafting errors in which quotation marks were mistakenly used around paraphrased statements rather than direct quotations.” Id. at 2. The hallucination issue is more prevalent than Plaintiff admits. The Court has determined that hallucinated law appears on pages 5, 9, 10, 11, 13, 14, 15, and 17 of the Response. Therefore, while Plaintiff has conceded that he made a mistake, and sanctions are likely not appropriate, the Court simply cannot trust the legal arguments of Plaintiff. And, Plaintiff is doing himself a great disfavor by relying on fake legal arguments, which further weaken his position. The Court will further discuss the hallucinated law below. ii. Plaintiff’s", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The opposition brief used multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "jorge-a-zea-v-national-association-of-realtors", "courtlistener_url": null, "text_sha256": "6f94c916a97bc8abfc4e79c2ff001809d83ab6536a666f355a3d3bbc5af361cb", "source_url": "https://www.damiencharlotin.com/documents/1926/Zea_v._National_Association_of_Realtors_USA_24_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/flsd-2026-jorge-a-zea-v-national-association-of", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flsd-2026-jorge-a-zea-v-national-association-of" }, { "decision_id": "ca10-2026-kevin-lee-biglow-v-dell-technologies", "case_name": "Kevin Lee Biglow v. Dell Technologies Inc.", "court": "U.S. Court of Appeals for the Tenth Circuit", "court_code": "ca10", "court_level": "federal-appellate", "state": null, "date_filed": "2026-03-24", "citation": null, "docket_number": "25-3007", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed dismissal and warned that further failure to check cited authority before filing could result in sanctions.", "ai_passage": "any relevance to the argument Biglow attributes to the corresponding nonexistent case is Bentley, which states that “[f]ailure to plead an affirmative defense results in a waiver of that defense,” 41 F.3d at 604. There are similar fabrications in three of Biglow’s motions and in his reply briefs in support of all four motions. 10 Biglow’s fabricated case citations and other misrepresentations appear to stem from his use of a generative artificial intelligence (“AI”) tool, such as ChatGPT, without verifying the accuracy of the results. See Wadsworth v. Walmart Inc., 348 F.R.D. 489, 497 (D. Wyo. 2025) (“It is . . . well-known in the legal community that AI resources generate fake cases.”). Such fabrications are referred to as “AI hallucinations.” See Jones v. Kankakee Cnty. Sheriff’s Dep’t, 164 F.4th 967, 969 (7th Cir. 2026) (defining “a so-called AI ‘hallucination’” as “a circumstance where an AI large language model generates an output that is fictional, inaccurate, or nonsensical”). Assuming, without deciding, there is nothing inherently wrong with the use of AI to help prepare legal materials, a litigant’s failure to verify the accuracy of the authority cited results in waste", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The reply brief used several false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Burton v. Ghosh and Iseminger v. Dist. Ct, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "kevin-lee-biglow-v-dell-technologies-inc", "courtlistener_url": null, "text_sha256": "0ed07db2a766de7b8ea7dca4ff420dfd1841e2966db471d44f2c161a6a891733", "source_url": "https://www.damiencharlotin.com/documents/1831/Biglow_v._Dell_USA_24_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ca10-2026-kevin-lee-biglow-v-dell-technologies", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca10-2026-kevin-lee-biglow-v-dell-technologies" }, { "decision_id": "azd-2026-segui-v-moniz", "case_name": "Segui v. Moniz", "court": "U.S. District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "state": "AZ", "date_filed": "2026-03-24", "citation": null, "docket_number": "CV-25-01849-PHX-SHD", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court ordered plaintiffs’ counsel to show cause why sanctions should not be imposed for citing a nonexistent Arizona RICO limitations case.", "ai_passage": "(Doc. 26 at 20.) This case does not exist. Additionally, the proposition for which it is cited is also incorrect: the four-year period established by Agency Holding Corp., 483 U.S. 143 (1987), applies to federal civil RICO claims only. Arizona’s private RICO action is governed by the three-year period set forth in A.R.S. § 13-2314.04(F). Citation to nonexistent authority is a serious matter that implicates counsel’s obligations under Federal Rule of Civil Procedure 11(b)(2) to certify that all legal citations are warranted by existing law and are the product of reasonable inquiry. The fabrication of legal citations, whether through artificial intelligence or otherwise, undermines the integrity of the judicial process. Pursuant to Federal Rule of Civil Procedure 11(c)(3), which authorizes the Court on its own initiative to “order an attorney, law firm, or party to show cause why conduct specifically described in the order has not violated Rule 11(b),” the Court will order Plaintiffs’ counsel to show cause in writing why sanctions should not be imposed for citation to a nonexistent case. For the reasons stated above, /// IT IS ORDERED that Defendant Gregg Woodnick’s Motion to Dismiss (Doc. 18)", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities, including Barker v. Brown & Brown, 210 Ariz. 321, 110 P.3d 1011, which the court found nonexistent, misquoted, or unsupported.", "outcome": "pending", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "segui-v-moniz", "courtlistener_url": null, "text_sha256": "90484b26962abdad0720945e20d12ea0b5dd00cb3839b13be2a339917aaa8455", "source_url": "https://www.damiencharlotin.com/documents/1839/Segui_v._Moniz_USA_24_march_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/azd-2026-segui-v-moniz", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-segui-v-moniz" }, { "decision_id": "utd-2026-and-barbara-moulder-v-davis-school-district", "case_name": "Nicholas and Barbara Moulder v. Davis School District (on behalf of M.M.)", "court": "U.S. District Court for the District of Utah", "court_code": "utd", "court_level": "federal-district", "state": "UT", "date_filed": "2026-03-23", "citation": null, "docket_number": "1:25-CV-00052-TS-CMR", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court required AI-related CLE and payment of $1,525.50 already agreed to reimburse fees for two nonexistent cases and a nonexistent quotation.", "ai_passage": "on an Order to Show Cause1 after Defendants’ counsel discovered two non-existent cases and one non-existent quote cited in Plaintiffs’ briefing. Prior to hearing, the Court also ordered Defendants’ counsel to provide an estimate of the legal expenses incurred in responding to the Order to Show Cause. Defendants’ counsel informed the Court that, after initially discovering the non-existent cases, they reached an agreement with Plaintiffs’ counsel whereby Mr. Ares and Ms. Martz agreed to reimburse $1,525.50 in legal fees to resolve the issue.2 However, since then, Defendants’ counsel assert that they incurred an additional $5,568.50 in legal expenses related to the Order to Show Cause.3 Docket No. 54 (the Court ordered Plaintiffs’ counsel to show cause as to why they should not be sanctioned pursuant to Fed. R. Civ P. 11(c) for violation of Rule 11(b)). Docket No. 64, at 2. Id. of 4 At the hearing, Plaintiffs’ counsel admitted to using Artificial Intelligence (AI) in preparing their arguments and that each failed to independently verify the existence and accuracy of the two non-existent cases. Plaintiffs’ counsel accepted full responsibility for their lack of oversight and conceded their actions fell", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief used two false quotations and fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "sanctions", "actor": "lawyer", "monetary_penalty": 1525, "currency": "USD", "ai_tool": null }, "tracker_slug": "nicholas-and-barbara-moulder-v-davis-school-district-on-behalf-of-m-m", "courtlistener_url": null, "text_sha256": "d0e7094ed74347567fa0e71202939325d9d494cdab520c26d8fa700521a1860f", "source_url": "https://www.damiencharlotin.com/documents/1836/Moulder_v._Davis_School_USA_23_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/utd-2026-and-barbara-moulder-v-davis-school-district", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/utd-2026-and-barbara-moulder-v-davis-school-district" }, { "decision_id": "ord-2026-stafford-v-andrew-taffet", "case_name": "Stafford v. Andrew Taffet, et al.", "court": "U.S. District Court for the District of Oregon", "court_code": "ord", "court_level": "federal-district", "state": "OR", "date_filed": "2026-03-23", "citation": null, "docket_number": "1:24-cv-01612-AA", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court declined sanctions because defendants did not request them, but warned that the plaintiffs’ false citations appeared to be unverified AI hallucinations.", "ai_passage": "Plaintiffs cite to “Schweitzer v. FHLMC, No. 3:13-cv-0181, 2013 WL 4279629 (D. Or. Aug. 29, 2013)” on pages 11 and 34 of the SAC. Once again, no such case exists and the case number Plaintiffs provide is for a Social Security appeal. Presenting false citations is a grave matter and suggests an intention to mislead or deceive the Court. The most charitable interpretation is that Plaintiffs have relied on AI to complete their pleadings and briefing and have presented the resulting “hallucinated” citations to the Court without verifying their authenticity. The use of such a defective expedient makes Plaintiffs’ repeated complaints concerning their hours spent on legal research ring especially hollow. The presentation of false citations, including AI “hallucinations,” has been found to be sanctionable conduct for attorneys and pro se parties. See United States v. Hayes, 763 F. Supp.3d 1054, 1071 (E.D. Cal. 2025) (collecting cases). Fortunately for Plaintiffs, Defendants have represented to the Court that they do not intend to seek sanctions for Plaintiffs’ conduct at this time and so the Court will leave the matter there for now. II. Shotgun Pleadings Defendants move to dismiss the claims against Defendants Bruce Rose, Andrew Taffet, Stacey Lamarre, and Carrington Holding Company, LLC on the grounds that the Complaint does not allege any specific allegations against those Defendants beyond impermissible group allegations naming either “Defendants” or “Carrington.” Page 4 –OPINION & ORDER A pleading in which a “complainant asserts claims against multiple defendants without specifying which of the defendants are responsible for which acts or", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief used multiple fabricated or nonexistent authorities, including Campbell v. MERS and Tucker v. HSBC, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "stafford-v-andrew-taffet-et-al", "courtlistener_url": null, "text_sha256": "ad50ac9bfed5f0718ad512924c8d5c95d4bf3742695b80078f2f2596ceafacf9", "source_url": "https://www.damiencharlotin.com/documents/1829/Stafford_v._Taffet_USA_23_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ord-2026-stafford-v-andrew-taffet", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ord-2026-stafford-v-andrew-taffet" }, { "decision_id": "mied-2026-jane-doe-v-lincoln-consolidated-schools", "case_name": "Jane Doe, et al. v. Lincoln Consolidated Schools, et al.", "court": "U.S. District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "state": "MI", "date_filed": "2026-03-23", "citation": null, "docket_number": "2:23-cv-11236", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted summary judgment in part and ordered plaintiffs’ counsel’s firm to reimburse the defense costs of researching the hallucinated case.", "ai_passage": "63, PageID.783. Plaintiff’s response is that they did not use AI to complete their briefing; instead, the Frankenstein citation appears to result from multiple case citations inadvertently being combined during efforts to condense their brief. ECF No. 66, PageID.984. The Court notes that it, too, could not find the case, Doe v. Univ. of Michigan, as originally cited, and the four cases Plaintiffs offer from which they believe the truncated citation formed do not appear to support their implication that Courts adopt the ELCRA or Title IX frameworks in analyzing claims under § 26, specifically. In fact, none of those cases contained any references to Article I, § 26 whatsoever. Further, the numbers and date following the original Doe v. Univ. of Mich. citation are missing from the citations for the four cases that Plaintiffs claim were part of the original string citation, which they should have included if it were a true “Frankenstein” citation. Based on this, the Court is not persuaded that Plaintiffs did not allow the inclusion of an AI hallucinated citation in their brief without checking that the citation supported the entirety of their proposition or", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief used multiple fabricated or nonexistent authorities, including Doe v. Univ. of Mich., No. 18-11914, which the court found nonexistent, misquoted, or unsupported.", "outcome": "costs-order", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "jane-doe-et-al-v-lincoln-consolidated-schools-et-al", "courtlistener_url": null, "text_sha256": "52acbaa4d3b96e1bf8e734c3aa590a7876fd1bc971b75b76efe65e72037cb8ef", "source_url": "https://www.damiencharlotin.com/documents/1828/Doe_v._Lincoln_Consolidated_Schools_USA_23_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/mied-2026-jane-doe-v-lincoln-consolidated-schools", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-jane-doe-v-lincoln-consolidated-schools" }, { "decision_id": "mied-2026-gregory-hardy-v-k-jones", "case_name": "Gregory Hardy v. K. Jones, et al.", "court": "U.S. District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "state": "MI", "date_filed": "2026-03-23", "citation": "2026 WL 801202", "docket_number": "25-12718 this Court recommended in a repo", "document_type": "report-and-recommendation", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court struck the motion and issued a final sanctions warning after the plaintiff repeated fake quotations previously attributed to AI use.", "ai_passage": "R&R). The R&R explained, “Courts and opposing counsel Gregory Hardy, Flint, MI, Pro Se. are [ ] burdened by the careless use of AI by pro se filers.” Hardy v. Whitaker, ___ F.R.D. ___ 2026 WL 575225, at *10. Bennet J. Bush, Genesee County Corporation Counsel, Flint, Hardy apologized for his “inclusion of inaccurate citations MI, for Defendants Bennett, Jay Parker, Danielle Macko, generated by an AI tool” in his objection to the R&R. Fuller. Case No. 24-cv-11270, ECF No. 213, PageID.2430. But he repeated the offense in his motion to consolidate. ORDER STRIKING PLAINTIFF'S More recently, the Sixth Circuit emphasized that the “even MOTION AND GIVING A FINAL a single fake case can be sanctionable” and that “citing WARNING OF SANCTIONS (ECF NO. 33) fake cases can harm the reputation of judges and courts whose names are falsely invoked as authors of the bogus ELIZABETH A. STAFFORD United States Magistrate Judge opinions and the reputation of a party attributed with fictional conduct.” Whiting City of Athens Tennessee, ___ F. 4th ___, *1 Plaintiff Gregory Hardy, proceeding pro se and in forma 2026 WL 710568, at *4 (6th Cir. Mar.", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion used false quotations, including Berndt v. Tennessee and United States v. Frazier, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "gregory-hardy-v-k-jones-et-al", "courtlistener_url": null, "text_sha256": "c1c268b9a1ea30284e22099d307aac593d46478dec974e9fcd3f1145be82c01b", "source_url": "https://www.damiencharlotin.com/documents/1832/Hardy_v._Jones_USA_23_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/mied-2026-gregory-hardy-v-k-jones", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-gregory-hardy-v-k-jones" }, { "decision_id": "asbca-2026-endure-industries-v-defense-health-agency", "case_name": "Endure Industries, Inc. v. Defense Health Agency", "court": "Armed Services Board of Contract Appeals", "court_code": "asbca", "court_level": "federal-specialty", "state": null, "date_filed": "2026-03-23", "citation": null, "docket_number": "ASBCA No. 64064", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The Board granted dismissal and warned the self-represented contractor that future citations to non-existent authority may lead to sanctions.", "ai_passage": "– have a tendency to hallucinate non-existent cases. Sanders v. United States, 176 Fed. Cl. 163, 169 (2025) (“It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs.”); Raven Investigations & Sec. Consulting, LLC, B-423447, 2025 CPD ¶ 81 at 3 (“[T]he use of AI programs to draft or assist in drafting legal briefs can—and seemingly often does—result in the citation of non-existent cases.”); see also Ralph Nash, Artificial Intelligence Hallucinations: Sanctions are Waiting, 39 NASH & CIBINIC REP. ¶ 44 (Aug. 2025) (“[I]t is well known that so far AI programs tend to hallucinate.”). The real decision near the hallucinated citation is Johns-Manville Corp. v. United States, 12 Cl. Ct. 1 (1987). “Fake cases generated by AI often have reporter citations that lead to cases with different names, in different courts, and about different subjects.” Sanders, 176 Fed. Cl. at 169 n.8. Endure asserts that the Johns-Manville decision supports the assertions made in its brief", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief used fabricated or nonexistent authorities and mischaracterized authorities, including LLC v. United States and Corp. v. United States, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "endure-industries-inc-v-defense-health-agency", "courtlistener_url": null, "text_sha256": "d16595032106284de4ba9743aa2c5772246bf2816fe19c8321cf64ea9ce08333", "source_url": "https://www.damiencharlotin.com/documents/1981/1776341487278.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/asbca-2026-endure-industries-v-defense-health-agency", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/asbca-2026-endure-industries-v-defense-health-agency" }, { "decision_id": "laed-2026-daniel-gentry-v-calvin-thompson", "case_name": "Daniel Gentry v. Calvin Thompson et al.", "court": "U.S. District Court for the Eastern District of Louisiana", "court_code": "laed", "court_level": "federal-district", "state": "LA", "date_filed": "2026-03-20", "citation": "2026 WL 787563", "docket_number": "25-1260 filed a motion", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": "ChatGPT", "disposition": "The court personally sanctioned counsel $1,250 and formally admonished him after he admitted using ChatGPT without checking nine hallucinated cases.", "ai_passage": "problem of attorneys’ improper use of A.I. cases on Westlaw but admitted that he eventually resorted to ChatGPT. Mr. Harris took full responsibility for his misuse Both Mr. St. Raymond and City Attorney Gipson outlined of generative A.I. and conceded that he did not check the the actions the City Attorney's Office has taken to citations that ChatGPT had provided, nor did he attempt to combat the future misuse of A.I. Specifically, the City read the nine hallucinated cases that he cited in the brief. DANIEL GENTRY v. CALVIN THOMPSON ET AL., Slip Copy (2026) Attorney's Litigation Division called a department-wide meeting immediately after the Court issued the Order to Show Cause in this matter, and Ms. Gipson and her staff CONCLUSION are currently in the process of developing a written policy concerning the use of generative A.I. in the City Attorney's Accordingly, Office. Further, Mr. Harris and Mr. Roquemore attended a Thomson Reuters seminar about proper and improper uses IT IS HEREBY ORDERED that under Federal Rule of Civil of A.I. in legal practice. Ms. Gipson also emphasized the Procedure Rule 11, Jalen Harris is personally sanctioned for importance", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The brief cited nine hallucinated cases generated through ChatGPT that counsel admitted he had not checked.", "outcome": "sanctions", "actor": "lawyer", "monetary_penalty": 1250, "currency": "USD", "ai_tool": "ChatGPT" }, "tracker_slug": "daniel-gentry-v-calvin-thompson-et-al", "courtlistener_url": null, "text_sha256": "a8b3944a1e88cc8cc6cccf09e6ba2990f76963b3d506b437e17fcfb525661fca", "source_url": "https://www.damiencharlotin.com/documents/1771/Gentry_v._Thompson_USA_20_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/laed-2026-daniel-gentry-v-calvin-thompson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/laed-2026-daniel-gentry-v-calvin-thompson" }, { "decision_id": "kyctapp-2026-pamela-blair-v-sanctuary-bluff-homeowners-association", "case_name": "Pamela Blair v. Sanctuary Bluff Homeowners Association, Inc., et al.", "court": "Kentucky Court of Appeals", "court_code": "kyctapp", "court_level": "state-appellate", "state": "KY", "date_filed": "2026-03-20", "citation": "2026 WL 784501", "docket_number": null, "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court struck the appellant’s brief and allowed refiling after repeated hallucinated precedent and deficient AI certifications.", "ai_passage": "principles. [Goodyear Tire & Rubber Co. v. Thompson, 11 to dismiss the appeal as Blair's latest brief again contained S.W.3d 575, 581 (Ky. 2000).] hallucinated precedent. Blair responded by admitting her brief contained one hallucinated case that was “erroneously ... repeated.” In an abundance of grace, this Court denied the HOA's motion to dismiss. Even so, Blair closed the appellate Consideration of a motion to dismiss under CR 41.02(1) briefing window by submitting a reply brief with yet another requires fact-specific determinations that are left to the hallucinated case12 and absent an AI certification. This sound discretion of the trial court. [Jaroszewski, 297 deliberate disregard for a Court's ruling, and her recalcitrant S.W.3d at 32.] The trial court must base its assessment on approach to litigation has become a pattern and such actions the totality of the circumstances. [See id. at 36.] have likely sabotaged her own litigation. Still, a trial court's discretion is not unfettered and is subject to an important limitation. Our courts have long recognized Nonetheless, we shall address the merits of the matter in order that CR 41.02(1) dismissal with prejudice is an “extreme to bring", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief used nine false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Co. v. Thompson, 11, which the court found nonexistent, misquoted, or unsupported.", "outcome": "strike-off", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "pamela-blair-v-sanctuary-bluff-homeowners-association-inc-et-al", "courtlistener_url": null, "text_sha256": "4aff965a786f2c1b2ce94e12c7cb7f4f71dadd45f6a4013f6c472acb6ac6b410", "source_url": "https://www.damiencharlotin.com/documents/1770/Blair_USA_20_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/kyctapp-2026-pamela-blair-v-sanctuary-bluff-homeowners-association", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/kyctapp-2026-pamela-blair-v-sanctuary-bluff-homeowners-association" }, { "decision_id": "fladistctapp6-2026-hessert-v-hessert-and-wieland-pulayya", "case_name": "Hessert v. Hessert & Wieland-Pulayya", "court": "Florida Sixth District Court of Appeal", "court_code": "fladistctapp6", "court_level": "state-appellate", "state": "FL", "date_filed": "2026-03-20", "citation": "2026 WL 785016", "docket_number": "2D2024-1772", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court ordered the petitioner to show cause why sanctions should not issue for a petition with nonexistent cases and inaccurate legal propositions.", "ai_passage": "--- So.3d ----, 2026 WL 785016 Footnotes “Generative AI[—i.e., generative artificial intelligence—]are deep-learning models that compile data to generate statistically probable outputs when prompted.... Generative AI can create original images, analyze documents, and draft briefs based on written prompts. Often, these programs rely on large language models. The datasets utilized by generative AI large language models can included billions of parameters making it virtually impossible to determine how a program came to a specific result.... [G]enerative AI can hallucinate or create inaccurate answers that sound convincing.” Fla. Bar Ethics Op. 24-1, at 1-2 (Jan. 19, 2024) (citations and internal quotation marks omitted). Government Works.", "cited_authorities": [ "Fla. Bar Ethics Op. 24-1" ], "summary": "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.", "incident": { "conduct": "The petition used fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "pending", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "hessert-v-hessert-wieland-pulayya", "courtlistener_url": null, "text_sha256": "57df6fbcb258b5fb401c5818d4b74332a81fe865e33c5509b396a291523a36ba", "source_url": "https://www.damiencharlotin.com/documents/1769/Hessert_USA_20_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/fladistctapp6-2026-hessert-v-hessert-and-wieland-pulayya", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp6-2026-hessert-v-hessert-and-wieland-pulayya" }, { "decision_id": "utahctapp-2026-prisbrey-v-prisbrey", "case_name": "Prisbrey v. Prisbrey", "court": "Utah Court of Appeals", "court_code": "utahctapp", "court_level": "state-appellate", "state": "UT", "date_filed": "2026-03-19", "citation": "2026 WL 787382", "docket_number": "20250070", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court reversed and remanded for a new trial while criticizing counsel’s incorrect Utah citations, misquotations, and authorities made out of whole cloth.", "ai_passage": "to support his propositions. Of these six citations, four are incorrect for various reasons (e.g., the cited material has nothing to do with the proposition for which the case is cited, the case name is incorrect, or the cited paragraph does not exist). (3) In the argument section, which is just over four pages long, Leona's counsel cites four Utah cases a total of seven times. Only one citation is correct. The others are deficient in various ways (e.g., wrong case name, unrelated in any way to the asserted proposition, cited paragraph of the case does not exist, or misquoted the case). Indeed, some of the citations appear to be made out of whole cloth. We realize attorneys find themselves pulled in many directions, but even in the midst of these pressures, we do expect a modicum of compliance with briefing and citation standards. In a case like this, where any similarity between the citation in the brief and the material cited appears to be purely accidental, we are left perplexed as to what happened in the composition process.", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief used seven fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "other", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "prisbrey-v-prisbrey", "courtlistener_url": null, "text_sha256": "7cff490e2defc381cc0f78bd68213a22f17e49650c521c5e2f31cf69c362135f", "source_url": "https://www.damiencharlotin.com/documents/1834/Prisbrey_v_Prisbrey_USA_19_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/utahctapp-2026-prisbrey-v-prisbrey", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/utahctapp-2026-prisbrey-v-prisbrey" }, { "decision_id": "orluba-2026-kelly-bartholomew-v-clackamas-county", "case_name": "Kelly Bartholomew v. Clackamas County", "court": "Oregon Land Use Board of Appeals", "court_code": "orluba", "court_level": "other", "state": "OR", "date_filed": "2026-03-19", "citation": null, "docket_number": "2025-073", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "LUBA struck the petition for judicial review after concluding that fabricated authorities permeated the assignments of error and consumed tribunal resources.", "ai_passage": "of law. When a party submits briefs based on invalid authorities, that party engages in conduct that jeopardizes the integrity of the LUBA appeal process. Regardless of who submits fabricated citations, or whether they originate from the use of artificial intelligence or otherwise, such citations strain LUBA's and the parties' limited resources. Ringo, 345 Or App at 304.4 The time and resources consumed for parties and LUBA to address Bartholomew's reliance on fabricated authorities would be far better used to address the merits of pending matters. See id. (\"Every hour spent addressing false citations and statements of law is an hour diverted from those matters in which attorneys have supported their arguments with precedent that exists.\"). Submitting legal citations invites LUBA to rely on them and includes an implicit certification that the authorities exist and that the citations support the party's legal assertions. Legal arguments are bolstered by citations to valid authorities. Every time a party relies on even a single false authority, LUBA must commit attention and time to check the authorities to maintain integrity in the process and public confidence that LUBA will not rely on invalid authority in resolving an appeal. While parties and legal practitioners may at times miscite or mischaracterize existing legal authority, it is significantly more egregious for a party to rely on invalid authority. The court has observed that \"generative artificial intelligence is not perceiving nonexistent law as the result of a disorder. Rather, it is generating nonexistent law in accordance with its design.\" Ringo, 345 Or App 304. Page8 LfJBA. ; :--««»z';; :—'..,.«,„,", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief used nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "strike-off", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "kelly-bartholomew-v-clackamas-county", "courtlistener_url": null, "text_sha256": "3a4ff18075ee95ea99aed19ae0f5220089672f348dade01fb26b96d6807c04d1", "source_url": "https://www.damiencharlotin.com/documents/1933/Kelly_Bartholomew_v_Public_Utility_Commission_of_Oregon_USA_19_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/orluba-2026-kelly-bartholomew-v-clackamas-county", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/orluba-2026-kelly-bartholomew-v-clackamas-county" }, { "decision_id": "oked-2026-oscar-brownfield-v-cherokee-county-school", "case_name": "Oscar Brownfield v. Cherokee County School District No. 35", "court": "U.S. District Court for the Eastern District of Oklahoma", "court_code": "oked", "court_level": "federal-district", "state": "OK", "date_filed": "2026-03-19", "citation": null, "docket_number": "d in ED/OK on 03/19/26", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court denied the plaintiff’s sanctions motion but imposed a $500 sanction for citing fictitious or inaccurate authorities generated through AI research.", "ai_passage": "AI in legal representation has increased, so have incidences of fictitious or inaccurate citations resulting from such AI tools. Presentation of inaccurate authorities in pleadings resulting from AI subject to the signing party to sanctions. See, e.g., Hill v. Oklahoma, 2025 WL 1840659, at *4 (W.D. Okla. July 3, 2025) (“[C]ourts have increasingly found the imposition of sanctions proper in response to an attorney's conduct in citing ‘fake cases’ that are ‘hallucinations’ generated by an artificial intelligence platform.”) (citing Wadsworth v. Walmart, 348 F.R.D. 489, 495-496 (D. Wyo. 2025) (citing fake cases in a signed motion violated Rule 11(b)(2) and subjected attorneys to imposition of monetary sanctions); Bunce v. Visual Technology Innovations, Inc., 2025 WL 662398 at *1 (E.D. Pa. Feb. 27, 2025) (imposing sanctions where the attorney filed two separate motions that cited two cases that could not be located “on any legal research tool . . . .”); Ramirez v. Humala, 2025 WL 1384161 at * 1 (E.D.N.Y. May 13, 2025) (collecting cases finding “the submission of nonexistent case citations in filings to the court to constitute sanctionable conduct” under Fed. R. Civ. P. 11(b)(2)). Plaintiff admits he", "cited_authorities": [ "Hill v. Oklahoma, 2025 WL 1840659", "Ramirez v. Humala, 2025 WL 1384161", "Fed. R. Civ. P. 11(b)(2)" ], "summary": "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.", "incident": { "conduct": "The motion used two false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hill v. Oklahoma and Wadsworth v. Walmart, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": 500, "currency": "USD", "ai_tool": null }, "tracker_slug": "oscar-brownfield-v-cherokee-county-school-district-no-35", "courtlistener_url": null, "text_sha256": "0b5ae5be2b107344f46799bf8e629dc165bdf3687a607ed4caa99f8959b6c2da", "source_url": "https://www.damiencharlotin.com/documents/1766/Brownfield_v._Cherokee_USA_18_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/oked-2026-oscar-brownfield-v-cherokee-county-school", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/oked-2026-oscar-brownfield-v-cherokee-county-school" }, { "decision_id": "nysupct-2026-espinoza-v-m-and-r-const-group", "case_name": "Espinoza v. M&R Const. Group Inc.", "court": "Supreme Court of the State of New York", "court_code": "nysupct", "court_level": "state-trial", "state": "NY", "date_filed": "2026-03-19", "citation": "2026 WL 880831", "docket_number": "513911/2022", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court scheduled a sanctions hearing after finding that the moving papers relied on a nonexistent Second Department case.", "ai_passage": "construction management agreement (CMA at § 1.48). Furthermore, Alma Hot, project manager for M&R, testified that Shorewood was the owner's “rep” (Hot EBT at 11). In light of the uncontroverted evidence, Shorewood's arguments are unavailing. In its moving papers, Shorewood relies on the following purported authority: “Parrelli v. Temple Beth El of Great Neck, 304 A.D.2d 788, 789 [2d Dept 2003])” (defendants' aff in supp at 14). However, as plaintiff's counsel notes, this case does not exist. The court can find no case **4 that contains this caption; the nearest Second Department case is Berger v Temple Beth El of Great Neck, a defamation action involving none of the issues at dispute in this case. The citation leads to the middle of a Second Department decision in a declaratory judgment matter involving proper land use of a parcel in the County of Westchester. In light of this apparently fabricated caselaw, a sanctions hearing will be scheduled in the decretal section of this decision. Labor Law § 240 (1) Liability under Labor Law § 240 (1) is “absolute” where the failure of a safety device enumerated by the statute is a", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used fabricated or nonexistent authorities, including Parrelli v. Temple Beth El of Great Neck, which the court found nonexistent, misquoted, or unsupported.", "outcome": "sanctions", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "espinoza-v-m-r-const-group-inc", "courtlistener_url": null, "text_sha256": "c193cf1b6aebc50ed9c09ce17c45e168a766c2e4eb9d88f1be726ad8807c9a85", "source_url": "https://www.damiencharlotin.com/documents/2331/04_-_Espinoza_v_MAndR_Const_Group_Inc.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/nysupct-2026-espinoza-v-m-and-r-const-group", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysupct-2026-espinoza-v-m-and-r-const-group" }, { "decision_id": "insd-2026-jana-james-v-national-board-of", "case_name": "Jana James v. National Board of Osteopathic Examiners, Inc.", "court": "U.S. District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "state": "IN", "date_filed": "2026-03-19", "citation": "2026 WL 772373", "docket_number": "6). As relief", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court warned that future filings with nonexistent cases or unsupported authorities would result in Rule 11 sanctions.", "ai_passage": "stating that Ms. James would not receive in the U.S. Navy. Id. at 656. The Seventh Circuit held that accommodations on the COMAT exam because NBOME \"[plaintiff's] marred record is a continuing harm for which denied her testing accommodations. Dkt. 98-2 at 9. This he [could] seek redress.\" Id. at 666. On remand, the district only shows, however, past harm. Ms. James does not explain court found that he adequately alleged standing for injunctive how ATSU's past reliance on NBOME's accommodation relief because he alleged that his career in the Navy would be determination imminently threatens her future rights—she available to him if his guilty finding was expunged. Doe v. has not designated evidence, or even alleged, that she plans Purdue Univ., No. 2:17-cv-33, 2020 WL 2542674, at *9 (N.D. to re-enroll in ATSU, or any other medical school. See Simic, Ind. May 19, 2020). 851 F.3d at 738 (\"Unlike with damages, a past injury is insufficient to establish standing for purposes of prospective Here, Ms. James does not designate any evidence that the relief.\"); Perry L. v. Milwaukee Montessori Sch., No. 22- records of her two failed COMLEX-USA Level", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The filing used fabricated or nonexistent authorities and mischaracterized authorities, including Knakmuhs v. Minneapolis Pub. Sch and Cooper v. Tokyo Elec. Power Co, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "jana-james-v-national-board-of-osteopathic-examiners-inc", "courtlistener_url": null, "text_sha256": "89caa4096882acabb3f9cdc97ba858be35e54ca820a32d78dab4a02290b4f5fe", "source_url": "https://www.damiencharlotin.com/documents/1763/James_v._Board_USA_19_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/insd-2026-jana-james-v-national-board-of", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-jana-james-v-national-board-of" }, { "decision_id": "ilnd-2026-pittman-v-hazel-and-olive", "case_name": "Pittman v. Hazel and Olive, Inc.", "court": "U.S. District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "state": "IL", "date_filed": "2026-03-19", "citation": null, "docket_number": "25 C 7791", "document_type": "order", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the case with prejudice, struck the AI-generated response brief, and ordered counsel to pay defense fees and costs.", "ai_passage": "10. 4. Reliance on AI-Generated Case Citations Defendant moved to dismiss at R. 21 and Plaintiff’s counsel responded at R. 32. Defendant then moved to strike at R. 35 on the basis that Plaintiff’s counsel’s response brief was generated by artificial intelligence and cited fake cases. At R. 38, Plaintiff’s counsel admitted that he relied on artificial intelligence, that Plaintiff’s counsel failed to cite check, and that Plaintiff’s counsel submitted fake cases to the Court. The Court finds that Plaintiff’s counsel violated Federal Rule of Civil Procedure 11 when filing his response. 5. Sanctions Given the above issues—Plaintiff’s counsel’s bad faith motion to enforce the settlement agreement, Plaintiff’s counsel’s repeated lack of candor toward the Court, Plaintiff’s counsel’s disingenuous use of discovery to generate fees, and Plaintiff’s counsel’s negligent reliance on artificial intelligence that cited fake cases—the Court orders the following sanctions. First, Plaintiff’s counsel shall cover all costs and fees incurred by Defendant in defending this lawsuit. The parties are ordered to meet and confer to determine the total costs and fees and to arrange for the payment. Any fees incurred by Defendant during this meet and confer process", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The response brief used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted.", "outcome": "costs-order", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "pittman-v-hazel-and-olive-inc", "courtlistener_url": null, "text_sha256": "a650382312029bca0d8d012345fc4178cd51fa989fd1152d128070c67b4201f9", "source_url": "https://www.damiencharlotin.com/documents/2574/Pittman_v._Hazel__Olive_USA_19_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-pittman-v-hazel-and-olive", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-pittman-v-hazel-and-olive" }, { "decision_id": "cob-2026-keirton-v-mersad-rahmanovic", "case_name": "Keirton Inc. v. Mersad Rahmanovic", "court": "U.S. Bankruptcy Court for the District of Colorado", "court_code": "cob", "court_level": "federal-bankruptcy", "state": "CO", "date_filed": "2026-03-19", "citation": "2026 WL 787397", "docket_number": "25-12622 MER are incorrect or nonexistent", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the debtor’s counterclaims with leave to amend and warned that nonexistent AI-hallucinated citations did not save deficient pleading.", "ai_passage": "for declaratory judgment is duplicative of his defenses to Keirton Inc. Plaintiff, Keirton's § 727(a)(4) claim.3 Keirton also asserts that several v. of Rahmanovic's case citations do not exist and are the result Mersad Rahmanovic Defendant. of A.I. hallucinations. In response, Rahmanovic asserts that he sufficiently pled both claims and that even if his citations Case No. 25-12622 MER are incorrect or nonexistent, his counterclaims should not be | dismissed or stricken. Additionally, Rahmanovic asserts he Adversary No. 25-01338 MER should be permitted to amend his counterclaims. | Filed:03/19/2026 ANALYSIS Chapter 7 A. Dismissal Is Warranted Under Rule 12(b)(6) Pursuant to Fed. R. Civ. P. 12(b)(6) (incorporated by Fed. R. ORDER GRANTING MOTION TO DISMISS WITH Bankr. P. 7012), a complaint may be dismissed for failure LEAVE TO AMEND to state a claim upon which relief can be granted. When considering a motion to dismiss under Rule 12(b)(6), the Michael E. Romero, Judge United States Bankruptcy Court Court accepts as true all well-pled factual allegations in the complaint and views them in the light most favorable THIS MATTER comes before the Court on the Motion to the plaintiff.4 A complaint will be dismissed unless it to Dismiss Defendant's Counterclaims (“Motion”) filed by “contains sufficient factual matter, accepted as true, to state", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The complaint used several false quotations and fabricated or nonexistent authorities, including Gullickson v. Brown, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "keirton-inc-v-mersad-rahmanovic", "courtlistener_url": null, "text_sha256": "a280aacd9a9ac49af55fdd519c8e6abe90677f44bd23acdebb92da3d27941e08", "source_url": "https://www.damiencharlotin.com/documents/1775/In_re_Mersad_Rahmanovic_Debtor_Keirton.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/cob-2026-keirton-v-mersad-rahmanovic", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cob-2026-keirton-v-mersad-rahmanovic" }, { "decision_id": "calctapp-2026-anna-sheerer-v-thomas-panas", "case_name": "Anna Sheerer v. Thomas Panas", "court": "California Court of Appeal, First District", "court_code": "calctapp", "court_level": "state-appellate", "state": "CA", "date_filed": "2026-03-19", "citation": "2026 WL 776268", "docket_number": "d 3/19/2026 to heed the warning faces san", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court reversed the child-support order but declined monetary sanctions after the self-represented respondent admitted AI-caused fake citations and quotations.", "ai_passage": "Panas cited at least two cases 1119 [“ ‘Honesty in dealing with the courts is of paramount that do not exist: “In re Marriage of Thomson (1984) 157 importance, and misleading a judge is, regardless of motives, Cal.App.3d 568, 578” and “Marriage of Mendlowitz (2019) a serious offense’ ”].) We further caution that our redress Cal.App.5th 990.” He further fabricated quotes that appear for false and missing citations is not limited to disregarding nowhere in the (real) cases cited. In his declaration “clarifying a brief. “We may impose monetary sanctions pursuant to facts” filed in this Court after Sheerer filed a motion to our own motion for unreasonable violations of the rules strike respondent's brief, Panas explained that his “error” in governing appeals.” (Keitel v. Heubel, supra, 103 Cal.App.4th providing fake quotations and citing nonexistent case law was at p. 340; Noland, supra, 114 Cal.App.5th at p. 442; Rule caused by his use of an AI tool and his failure to verify his 8.276(a)(4).) However, given Panas's admission of his error citations. He averred that he “did not knowingly submit false and considering that it would not be in the", "cited_authorities": [ "In re Marriage of Thomson (1984)" ], "summary": "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.", "incident": { "conduct": "The appellate brief used two false quotations and fabricated or nonexistent authorities, including In re Marriage of Thomson and Keitel v. Heubel, supra, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "anna-sheerer-v-thomas-panas", "courtlistener_url": null, "text_sha256": "6a91cb130a104bcc230a2a83ef4ca1a9b254a4e174bcbfa71325a93fa27e7324", "source_url": "https://www.damiencharlotin.com/documents/1767/Sheerer_v._Panas_USA_19_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/calctapp-2026-anna-sheerer-v-thomas-panas", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp-2026-anna-sheerer-v-thomas-panas" }, { "court_code": "vaed", "state": "VA", "citation": null, "docket_number": "3:23-cv-00160-RCY", "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": "https://storage.courtlistener.com/recap/gov.uscourts.vaed.535291/gov.uscourts.vaed.535291.195.0.pdf", "text_sha256": "1a22234dd72823d5deed38920862932ea90bbea708f5deffcf3c520ca70844a0", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "Court-authored public-domain PDF was read from CourtListener storage; no separate CourtListener opinion page was captured.", "decision_id": "vaed-2026-burnley-v-valentin", "case_name": "Burnley v. Valentin", "court": "U.S. District Court for the Eastern District of Virginia", "court_level": "federal-district", "date_filed": "2026-03-18", "document_type": "memorandum-opinion", "topics": [ "evidence-authentication" ], "primary_topic": "evidence-authentication", "court_used_ai": false, "disposition": "The court granted in part motions to enforce settlement after finding an audio recording authentic and identifying the caller as Burnley.", "ai_passage": "Walburn maintains that Burnley, using the pseudonym “Tyrone Jackson,” materially breached the Walburn-Burnley Settlement Agreement’s express prohibition against contacting Walburn’s employers about Walburn. In defense, Burnley denies calling Walburn’s current employer and claims that the Court cannot assume it was him based on voice comparison alone. He adds that any connection to a former neighbor named “Tyrone Jackson” is incorrect, as the man who once lived across from Burnley was named “Tyrone Miller.” He argues that the Court cannot grant the Motion to Enforce because the audio recordings have not been “authenticated prior to admission” pursuant to Federal Rule of Evidence 901(a). Instead, he argues, the recordings are either someone else entirely or are a manipulated audio made by artificial intelligence to “clone” his voice. ... Here, the Court must determine whether the Walburn produced “evidence sufficient to support a finding” that the audio recording is what the Walburn claims it is. Fed. R. Evid. 901(a). Based on the evidence presented, which included two sworn declarations, the Court is satisfied that the audio recording is authentic and has not been materially altered.", "cited_authorities": [ "Fed. R. Evid. 901(a)", "United States v. Howard-Arias, 679 F.2d 363 (4th Cir. 1982)" ], "summary": "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.", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.vaed.535291/gov.uscourts.vaed.535291.195.0.pdf", "verification": "mirror-read", "lead_source": [ "user lead", "CourtListener storage mirror" ], "url": "https://safelegalai.com/courts/opinions/vaed-2026-burnley-v-valentin", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/vaed-2026-burnley-v-valentin" }, { "decision_id": "ncctapp-2026-townhomes-of-greensboro-v-heag-pain-management", "case_name": "Forest Ridge Townhomes Corporation of Greensboro v. Heag Pain Management Center et al.", "court": "North Carolina Court of Appeals", "court_code": "ncctapp", "court_level": "state-appellate", "state": "NC", "date_filed": "2026-03-18", "citation": "2026 WL 762385", "docket_number": "COA 25-600 bankruptcy case", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": "Perplexity.AI", "disposition": "The court affirmed the surplus-funds ruling and chastised counsel for relying on Perplexity.AI material without adequately checking irrelevant authorities.", "ai_passage": "prescribed by statute”); N.C.G.S. § 45-21.32(a) (a surplus-funds proceeding is a special proceeding). Respondents’ speculation on the alleged “impact” of this matter on mechanics’ liens, as well as their inapplicable FDCPA claim, strongly resemble similar arguments in a record filing titled “Perplexity.AI Answers,” attached as an exhibit to Respondents’ “Motion for New Trial / Amendment of Judgment and Order, for Reconsideration, and Rule 60 Relief.” In the motion, Respondents’ counsel explains that he “did traditional research but supplemented it with research through Perplexity.AI, Professional Version” and provides a URL link to the same: “https://www. perplexity.ai/.” To the extent that the irrelevance of Respondents’ cited legal authorities results from the failure of Respondents’ counsel to adequately review AI-generated work product, we chastise him for this regrettable oversight. See N.C. State Bar, Formal Op. 1 (2024) (holding attorney “individually responsible for reviewing, evaluating, and ultimately relying” on AI-generated work product); accord Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341, 347 (E.D.N.Y. 2025) (noting the “panoply of sanctions against attorneys who submitted fake cases” hallucinated by AI).", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities, including Benjamin v. Costco Wholesale Corp, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": "Perplexity.AI" }, "tracker_slug": "forest-ridge-townhomes-corporation-of-greensboro-v-heag-pain-management-center-e", "courtlistener_url": null, "text_sha256": "2ef7192efad046977b947cd0191f1f25c856b05f252d518cb26aa0edc21ddc8f", "source_url": "https://www.damiencharlotin.com/documents/1761/Forest_Ridge_v._Heag_USA_18_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ncctapp-2026-townhomes-of-greensboro-v-heag-pain-management", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ncctapp-2026-townhomes-of-greensboro-v-heag-pain-management" }, { "decision_id": "fladistctapp4-2026-davos-francois-v-vive-financial", "case_name": "Davos Francois v. Vive Financial", "court": "Florida Fourth District Court of Appeal", "court_code": "fladistctapp4", "court_level": "state-appellate", "state": "FL", "date_filed": "2026-03-18", "citation": "2026 WL 758289", "docket_number": "4D2025-2088", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed and cautioned the appellant that future briefs with nonexistent authorities may result in sanctions.", "ai_passage": "[March 18, 2026] intelligence to assist in these submissions must ensure their Appeal from the County Court for the Seventeenth Judicial accuracy.” Friend v. Serpa, 425 So. 3d 51, 51 (Fla. 4th DCA Circuit, Broward County; Michele McCaul Ricca, Judge; L.T. 2025) (cautioning the pro se litigant about sanctions for citing Case No. COCE22-048202. “phantom authority”). Attorneys and Law Firms Appellant is cautioned that future filings containing nonexistent authorities may result in sanctions. Fla. R. App. Davos Francois, Miramar, pro se. P. 9.410(a). Landon Morley of Lotane & Associates, P.A., Cocoa, for Artificial intelligence may assist in research and drafting, but appellee. it cannot replace the lawyer's or litigant's duty to ensure that Opinion every authority cited is real, accurate, and applicable. The responsibility for what is filed rests with the human author, Ciklin, J. not the machine. *1 Appellant, acting pro se, seeks review of an order denying Affirmed. his motion to vacate a default final judgment under Florida Rule of Civil Procedure 1.540(b). Lack of standing cannot be raised for the first time in a rule 1.540 motion. Phadael v. Deutsche Bank Tr. Co. Ams., 83 So. 3d 893, 895 (Fla. 4th DCA Kuntz, C.J., and Gross, J., concur. 2012). Additionally, “[e]ven where a judgment is entered in favor of a plaintiff that lacks standing, the judgment is merely voidable, not void.” Id. Accordingly, we affirm. --- So.3d ----, 2026 WL 758289", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion used multiple fabricated or nonexistent authorities, including Friend v. Serpa and Phadael v. Deutsche Bank Tr. Co. Ams., 83 So. 3d 893, 895, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "davos-francois-v-vive-financial", "courtlistener_url": null, "text_sha256": "39c5d706a56ab9177c4d6b15bd8b8c8b70fb6668a1c2c86f2b7c65d93e20256e", "source_url": "https://www.damiencharlotin.com/documents/1762/Francois_v._Vive_USA_18_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-davos-francois-v-vive-financial", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp4-2026-davos-francois-v-vive-financial" }, { "decision_id": "wawd-2026-sarah-and-regina-alonso-v-jackson", "case_name": "Sarah & Regina Alonso v. Jackson", "court": "U.S. District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "state": "WA", "date_filed": "2026-03-17", "citation": "2026 WL 747745", "docket_number": "3:25-cv-05594-JHC Lucas Jackson", "document_type": "other", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court granted the motion to dismiss claims against one defendant and warned counsel that another fictitious authority would trigger a sanctions show-cause order.", "ai_passage": "(1). In Washington, a corporation (or “represented entity,” SARAH and REGINA ALONSO, Plaintiffs, v. JAMES JACKSON,..., Slip Copy (2026) to show cause relating to use of fictitious legal authority do not request any relief in connection with this potentially generated by AI). fake case. Whether or not generative AI was used, “[c]iting nonexistent case law or misrepresenting the holdings of a case is making IV CONCLUSION a false statement to a court.” United States v. Hayes, 763 F. Supp. 3d 1054, 1067 (E.D. Cal. 2025), reconsideration *5 For the reasons above, the Court GRANTS Nesiamotu's denied, 2025 WL 1067323 (E.D. Cal. Apr. 9, 2025) (citation motion, Dkt. # 239, and DISMISSES the claims against omitted). Such conduct is sanctionable. Id. at 1071. Nesiamotu without prejudice for insufficiency of process. If, notwithstanding this ruling, Plaintiffs consider seeking relief The Court agrees that the “Allen v. Bayshore Mall” case cited to keep Nesiamotu as a defendant in this matter, the Court by Plaintiffs cannot be located online and that circumstances cautions them to review (1) the requirements for service of suggest, but do not prove, the possibility of improper process; (2) any", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion used fabricated or nonexistent authorities, including Allen v. Bayshore Mall, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "lawyer", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "sarah-regina-alonso-v-jackson", "courtlistener_url": null, "text_sha256": "66cc7120233d49c2ac1aa5dbae590adfdcaee408faec00ba343f925a0b14ec3b", "source_url": "https://www.damiencharlotin.com/documents/1691/Sarah_v._Jackson_USA_17_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/wawd-2026-sarah-and-regina-alonso-v-jackson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-sarah-and-regina-alonso-v-jackson" }, { "decision_id": "washctapp-2026-and-lynne-richmond-v-city-of-newport", "case_name": "Gregory Richmond and Lynne Richmond v. City of Newport, Washington", "court": "Washington Court of Appeals, Division III", "court_code": "washctapp", "court_level": "state-appellate", "state": "WA", "date_filed": "2026-03-17", "citation": "2026 WL 746700", "docket_number": "40954-6-III", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed dismissal and warned self-represented appellants that cases cited for convenient propositions must be real and supportive.", "ai_passage": "Freedom of Information Act, 5 U.S.C. § 552. The Richmonds do not argue that the trial court erred in dismissing their intentional infliction of emotional distress or their Consumer Protection Act claims. The Richmonds likely used AI for their briefing. AI is notorious for fabricating opinions and/or quotes. Here, the Richmonds cited an actual opinion, Osborn, for a proposition that would be convenient for them but which does not appear in the case. This pattern repeats with other cases cited by the Richmonds. AI fabrications occur by prompting a generative AI for a specific holding, and AI fabricating a result. This explains other cases cited by the Richmonds—King County v. Vincent, 167 Wn.2d 671 (2009), Carlyle v. Dep't of Soc. & Health Servs., 155 Wn. App. 895, 231 P.3d 218 (2010), and State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 (2019)—none of which this court could locate. We expect all parties, including pro se litigants, to ensure that the cases cited be real cases that plausibly support the proposition for which they are cited.", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The appellate brief used 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, which the court found nonexistent, misquoted, or unsupported.", "outcome": "other", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "gregory-richmond-and-lynne-richmond-v-city-of-newport-washington", "courtlistener_url": null, "text_sha256": "79b4a2635df0b60e67d59758c9293539b0481e1fdb6f73391c6a92331469ab14", "source_url": "https://www.damiencharlotin.com/documents/1690/Richmond_USA_17_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/washctapp-2026-and-lynne-richmond-v-city-of-newport", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/washctapp-2026-and-lynne-richmond-v-city-of-newport" }, { "decision_id": "ksd-2026-zesiger-v-kansas", "case_name": "Zesiger v. Kansas et al.", "court": "U.S. District Court for the District of Kansas", "court_code": "ksd", "court_level": "federal-district", "state": "KS", "date_filed": "2026-03-17", "citation": null, "docket_number": "25-2354-EFM-RES", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the claims and recounted the magistrate judge’s fourth warning against inaccurate or nonexistent case citations.", "ai_passage": "Fed. R. Civ. P. 8; and (6) the claims are time-barred. The Court will only address Defendants’ first three arguments as they are dispositive. Because the first three arguments all relate to each other, the Court will discuss them in tandem. 1. Whether Eleventh Amendment Immunity Bars Plaintiffs’ Claims against the State and its Officials The Eleventh Amendment provides that “[t]he Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.”19 Generally, the Eleventh Amendment bars suits against states and their agencies based on sovereign immunity.20 “This immunity extends to arms of the state and to state officials who are sued for damages in their official capacity.”21 “Once effectively asserted, Eleventh Amendment immunity constitutes a bar to the exercise of federal subject matter jurisdiction.”22 “The exception established U.S. Const. Amend. XI. Levy v. Kan. Dep’t of Soc. & Rehab. Servs., 789 F.3d 1164, 1168 (10th Cir. 2015). Williams v. Utah Dep’t of Corrs., 928 F.3d 1209, 1212 (10th", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The motion used 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, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "zesiger-v-kansas-et-al", "courtlistener_url": null, "text_sha256": "eb9c5d6bb3297c0526c7ff9dc8b9079d78d01129ea975e636a1a8f0350d50625", "source_url": "https://www.damiencharlotin.com/documents/1772/Zesiger_USA_17_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ksd-2026-zesiger-v-kansas", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ksd-2026-zesiger-v-kansas" }, { "decision_id": "ca5-2026-michael-wayne-singletary-v-swbc-mortgage", "case_name": "Michael Wayne Singletary v. SWBC Mortgage Corporation et al.", "court": "U.S. Court of Appeals for the Fifth Circuit", "court_code": "ca5", "court_level": "federal-appellate", "state": null, "date_filed": "2026-03-17", "citation": null, "docket_number": "25-20441 Lyle W. Cayce", "document_type": "opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court affirmed dismissal and warned that further failure to check cited authority before filing could lead to sanctions.", "ai_passage": "is void for failure to record the transfer in county property records, vitiating his indebtedness. However, he relies heavily on AI- hallucinated case law, and his theory finds no support in our actual case law. 2 Further failure to check the accuracy of cited authority before filing with the Court may result in sanctions. 3 Singletary also raises several arguments which were not asserted below in his Amended Complaint or his opposition to Defendants’ motion to dismiss. For example, he argues that (1) he received inconsistent statements about the “active” status of his loan which violates federal statutory servicing requirements, and (2) he was deprived of his Seventh Amendment right to a jury trial. These contentions are not persuasive, and again Singletary relies predominantly on non-existent case law. Moreover, the arguments were not developed before the district court and are therefore not properly before us. 4 Finally, we see no abuse of discretion 5 in the district court’s finding that _____________________ See Cervantes v. New Century Mortg. Corp., 633 F. App’x 290, 291 (5th Cir. 2016) (per curiam) (“[T]he failure to record a transfer of a mortgage note does not", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The opposition brief used multiple fabricated or nonexistent authorities, including Cervantes v. New Century Mortg. Corp, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "michael-wayne-singletary-v-swbc-mortgage-corporation-et-al", "courtlistener_url": null, "text_sha256": "dde8a23194fead825c3bd0b262568d54f76d0fc6a419a252cea2f63a1cab023d", "source_url": "https://www.damiencharlotin.com/documents/1773/Singletary_USA_17_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/ca5-2026-michael-wayne-singletary-v-swbc-mortgage", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca5-2026-michael-wayne-singletary-v-swbc-mortgage" }, { "ai_passage": "1 Appearing pro se, Norton quotes fictitious statutory language, cites to inapplicable statutes, and relies on cases that do not exist. In the event that such fake and non-existent legal authority was generated by artificial intelligence (AI), we note this as an acknowledgment and a warning. While AI may be of assistance to parties, especially pro se litigants navigating court rules, statutes, and case law, everyone, including pro se litigants, are responsible to confirm their pleadings, motions, briefs, and other filings are accurate and do not contain any citations that are invented or hallucinated by generative AI or any other source. See RAP 10.3(a)(6); West v. Thurston County, 168 Wn. App. 162, 187, 275 P.3d 1200 (2012). We hold pro se litigants to the same standard as attorneys. In re Est. of Little, 9 Wn. App. 2d 262, 274 n.4, 444 P.3d 23 (2019). 2 The commissioner reserved as to a money judgment because Verde Esterra relied on an alternate method of service. 3 Norton does not assign error or present argument as to the denial of the motion for reconsideration. See Escude v. King County Pub. Hosp. Dist. No. 2, 117 Wn. App. 183, 190 n.4, 69 P.3d 895 (2003) (“It is well settled that a party's failure to assign error to or provide argument and citation to authority in support of an", "ai_tool_named": null, "archive_url": null, "case_name": "Esterra Commons Venture, LLC dba Verde Esterra Park v. Justin Norton", "citation": "2026 WL 734359", "cited_authorities": [ "West v. Thurston County" ], "court": "Court of Appeals of Washington, Division One", "court_code": "washctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-16", "decision_id": "washctapp-2026-esterra-commons-venture-dba-verde-esterra-park", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 87320-2-I", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellate brief contained four citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1688/Esterra_v._Norton_USA_16_March_2026.pdf", "state": "WA", "summary": "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.", "text_sha256": "fa788a6381620ae653172eb6510452790935c5f4312b5b243daa0db2d2e2efbd", "topics": [ "fabricated-citations" ], "tracker_slug": "esterra-commons-venture-llc-dba-verde-esterra-park-v-justin-norton", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/washctapp-2026-esterra-commons-venture-dba-verde-esterra-park", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/washctapp-2026-esterra-commons-venture-dba-verde-esterra-park" }, { "decision_id": "pamd-2026-domingo-beato-estrella-v-m-arviza", "case_name": "Domingo Beato-Estrella v. M. Arviza", "court": "U.S. District Court for the Middle District of Pennsylvania", "court_code": "pamd", "court_level": "federal-district", "state": "PA", "date_filed": "2026-03-16", "citation": null, "docket_number": "3:26-CV-245", "document_type": "memorandum-opinion", "topics": [ "fabricated-citations" ], "primary_topic": "fabricated-citations", "court_used_ai": false, "ai_tool_named": null, "disposition": "The court dismissed the habeas petition without prejudice and cautioned that AI programs can hallucinate fake cases that do not support jurisdiction.", "ai_passage": "irrelevant to the present dispute. Beato-Estrella is cautioned that not all resources are created equal. For example, AI programs have been known to hallucinate, or create fake cases, in response to a user’s query. Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341, 342 (E.D.N.Y. 2025). The court understands legal research is difficult for anyone, especially when considering the constraints of doing so while incarcerated. Still, even though the court affords latitude to parties who are pro se, they must still ensure to follow the rules of the court and cite to actual law. In any event, it is clear the court does not have jurisdiction over Beato- Estrella’s current petition. He has not pointed to any aspect of his original judgment being ignored by the BOP. Nor is he presently eligible for any program to which an ICE detainer is depriving access. Therefore, this matter will be dismissed without prejudice for lack of subject matter jurisdiction. /S/ KELI M. NEARY Keli M. Neary United States District Judge Middle District of Pennsylvania March 16th, 2026", "cited_authorities": [], "summary": "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.", "incident": { "conduct": "The petition used fabricated or nonexistent authorities and mischaracterized authorities, including Santos v. Warden Allenwood FCI, No. 1:17-CV-02116 and London v. Pettit, which the court found nonexistent, misquoted, or unsupported.", "outcome": "warning", "actor": "litigant-in-person", "monetary_penalty": null, "currency": null, "ai_tool": null }, "tracker_slug": "domingo-beato-estrella-v-m-arviza", "courtlistener_url": null, "text_sha256": "f02870aab3968c3b1c7304d670829d577d7121a731a33880c83b7aaf77b8e870", "source_url": "https://www.damiencharlotin.com/documents/1694/Beato_Estrella_v._Swaney_USA_16_March_2026.pdf", "archive_url": null, "fetched_at": "2026-09-07T21:38:02.279971+00:00", "verification": "mirror-read", "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "url": "https://safelegalai.com/courts/opinions/pamd-2026-domingo-beato-estrella-v-m-arviza", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pamd-2026-domingo-beato-estrella-v-m-arviza" }, { "ai_passage": "12 Pridgen nevertheless argues that “[c]ourts routinely permit pro se plaintiffs to plead class claims ....” MTD Opp'n at 7. Pridgen cites “Lewis v. City of Trenton, 2020 WL 6204330” for this proposition. Id. The case Pridgen cites, however, does not exist. This Court does not tolerate hallucinated citations. Litigants who use generative artificial intelligence must disclose such use to this Court and litigants must review the filings for accuracy. See Section I.B of the Undersigned's Judicial Preferences. This Court warns Pridgen that if future filings include hallucinated citations, this Court will strike those filings and they will not be considered. Pridgen may also be subject to other sanctions. Pridgen's citation to non-existent authority bolsters the Court's conclusion that Pridgen could not adequately represent the interests of other litigants. 13 The Court reiterates that although Amazon does not contest the existence of any EEOC notice to sue, Pridgen did not attach one to his Complaint or MTD Opposition and the Court cannot determine which charge of discrimination was exhausted, if either.", "ai_tool_named": null, "archive_url": null, "case_name": "Shaquan Pridgen v. Amazon.com Services LLC", "citation": "2026 WL 735250", "cited_authorities": [ "Lewis v. City of Trenton, 2020 WL 6204330" ], "court": "United States District Court for the District of New Jersey", "court_code": "njd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-16", "decision_id": "njd-2026-shaquan-pridgen-v-amazon-com-services", "disposition": "The court warned the self-represented party to disclose AI use when required and to verify future citations.", "docket_number": "No. 25cv7589 (EP) (JRA)", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's opposition cited Lewis v. City of Trenton, 2020 WL 6204330, a case the court found did not exist.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1692/SHAQUAN_PRIDGEN_v_AMAZONCOM_SERVICES_USA_16_March_2026.pdf", "state": "NJ", "summary": "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.", "text_sha256": "24bb3f763f0939339273efa9b07fea9c3634e851363f576144a685a94da52082", "topics": [ "fabricated-citations" ], "tracker_slug": "shaquan-pridgen-v-amazon-com-services-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/njd-2026-shaquan-pridgen-v-amazon-com-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/njd-2026-shaquan-pridgen-v-amazon-com-services" }, { "ai_passage": "(denying leave to amend where it “would unduly prolong resolution of this protracted litigation, and it would unduly prejudice Defendants by forcing them to continue to defend against meritless claims”). Plaintiff’s submissions in this case may have been prepared by using generative artificial intelligence. Plaintiff’s filings have misrepresented the Works at issue here and have mischaracterized Defendant’s conduct and the prior orders issued in this case. See Goddard v. Sares-Regis Grp. Inc.., No. 25-CV- 5882, 2025 WL 2969295, at *3 (N.D. Cal. Oct. 21, 2025) (systematic factual misrepresentations are indicia of generative artificial intelligence). Plaintiff’s unauthorized supplemental briefing contains images that appear to have been created by generative artificial intelligence. 12 See Dkt. 64. Plaintiff’s 12 The images in this brief contain nonsensical spellings that are characteristic of images generated by artificial intelligence. See Dkt. 64 at 12 (“Twombly/idqal + Three Bays”); id. (“Access need not be proven beyond doubt– only alausibly.”); id. at 11 (“Comedie Freeze”); id. at 11 (“cafeteira tone”); id. at 11 (“Misúrstranding”); see also Amanda Silberling, Why Is AI So Bad At Spelling? Because Image Generators Aren’t Actually Reading Text, Page 12 of 18 Case 8:25-cv-02091-JAK-KES Document 73 Filed 03/16/26 Page 13 of 18 Page ID #:760 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES – GENERAL Case No. 8:25-cv-02091-JAK (KESx) Date March 16, 2026 Title Meriland Keith Dillard v. CBS Studios, Inc. opposition also cites to several opinions that do not exist, 13 which is a hallmark of the “hallucinations” observed in the use of generative artificial intelligence to conduct legal research and drafting. See United States v. Hayes, 763 F. Supp. 3d 1054, 1065 (E.D. Cal. 2025) (“The citation has all the markings of a hallucinated case created by generative artificial intelligence (AI) tools such as ChatGPT and Google Bard that have been widely discussed by courts grappling with fictitious legal citations and reported by national news outlets.”). Although courts “make some allowances for the pro se Plaintiff’s failure to cite to proper legal authority,” courts may not condone actions by a party who cites to false, nonexistent, or misleading authorities. James v. Wadas, 724 F.3d 1312, 1315 (10th Cir. 2013); see also Munoz v. United States, 28 F.4th 973, 978 (9th Cir. 2022) (“[I]t is axiomatic that pro se litigants, whatever their ability level, are subject to the same procedural requirements as other litigants.”). Like every other person who appears before a federal court, Plaintiff has an obligation under Rule 11 to confirm that his arguments are supported by the facts and the law. Plaintiff failed to meet that obligation here. The unsupported theories and legal contentions advanced by Plaintiff, which appear to be the result of his use of generative artificial intelligence, further confirm that granting leave to amend will allow Plaintiff to raise additional unsupported allegations. See, Alexande", "ai_tool_named": null, "archive_url": null, "case_name": "Meriland Keith Dillard v. CBS Studios, Inc.", "citation": null, "cited_authorities": [ "Jorgensen v. CBS, Inc., 728 F.2d 958 (8th Cir. 1984)", "Lamon v. Godbolt, 2015 WL 13647670 (C.D. Cal. Mar. 30, 2015)", "Twombly/idqal + Three Bays", "Comedie Freeze", "F.2d 953 is United States v. Johns", "See United States v. Hayes", "James v. Wadas", "Munoz v. United States", "Rule 11" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-16", "decision_id": "cacd-2026-meriland-keith-dillard-v-cbs-studios", "disposition": "The court denied the stay motion, granted CBS's motion to dismiss without leave to amend, and terminated the case.", "docket_number": "Case 8:25-cv-02091-JAK-KES", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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. Cal. Mar. 30, 2015) and Twombly/idqal + Three Bays, involving nonexistent authorities, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1838/Meriland_Keith_Dillard_v._CBS_Studios_Inc._USA_16_March_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "dcf62d71701bc7aabe831d31c9c56fd395393a911113ede321609974bd885305", "topics": [ "fabricated-citations" ], "tracker_slug": "meriland-keith-dillard-v-cbs-studios-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-meriland-keith-dillard-v-cbs-studios", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-meriland-keith-dillard-v-cbs-studios" }, { "ai_passage": "day deadline; the current version, effective since October 1, 2020, does not. Compare Pa.R.C.P. 1915.5(a) (current version), with Pa.R.C.P. 1915.5(a) (prior version effective until Sept. 30, 2020). 6 Based upon our review of Stepmother's brief and the cases cited therein, we suspect she used generative artificial intelligence in drafting it. See Saber v. Navy Federal Credit Union, 2026 WL 194332, at *3 n.4 (Pa. Super. Jan. 14, 2026) (discussing generative artificial intelligence “hallucinations,” wherein program makes up cases that do not exist). While we may liberally construe materials filed by pro se litigants, they are still subject to the same rules as represented litigants. See Commonwealth v. Blakeney, 108 A.3d 739, 766 (Pa 2014). Therefore, all litigants using generative artificial intelligence must ensure that the citations in their briefs are to real cases, or they risk waiving them for failure to cite to “pertinent” authority. See Pa.R.A.P. 2119(a). 7 While we found three Pennsylvania cases decided in 2003 with the caption Commonwealth v. Lyons, none stand for the proposition Stepmother cites it for or appear at the reporter citation she provides.", "ai_tool_named": null, "archive_url": null, "case_name": "A.C. Appellant v. H.D. AND J.C.", "citation": "2026 WL 711256", "cited_authorities": [ "Brief cites a reported Commonwealth v. Lyons at a reporter citation and for a proposition the court found unsupported", "See Saber v. Navy Federal Credit Union, 2026 WL 194332", "See Commonwealth v. Blakeney", "While we found three Pennsylvania cases decided in 2003 with the caption Commonwealth v. Lyons" ], "court": "Superior Court of Pennsylvania", "court_code": "pasuperct", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-13", "decision_id": "pasuperct-2026-a-c-v-h-d-and-j-c", "disposition": "The court affirmed the order dismissing the custody petition with prejudice and did not rely on the defective authorities.", "docket_number": "No. 2364 EDA 2025", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellate brief contained three citation defects, including Commonwealth v. Lyons, involving nonexistent authorities, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1687/AC_Appellant_v_HD_AND_JC_13_March_2026.pdf", "state": "PA", "summary": "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.", "text_sha256": "2e87c5502d9e7cd19994ad1c6cf2ab00ae0a5ef58acf081bc8a2c9c0964d6215", "topics": [ "fabricated-citations" ], "tracker_slug": "a-c-appellant-v-h-d-and-j-c", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/pasuperct-2026-a-c-v-h-d-and-j-c", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/pasuperct-2026-a-c-v-h-d-and-j-c" }, { "ai_passage": "19 / / / / 20 / / / / 21 22 5 Taylor opposes this motion with hallucinogenic citations to non-existent cases. To the extent Taylor has relied on artificial intelligence to write his papers, I caution him that it is his 23 responsibility to check his case citations to ensure they are accurate and say what he claims they do. The failure to do so may expose him to sanctions under Federal Rule of Civil Procedure 11. 4 Case 2:25-cv-00840-APG-NJK Document 53 Filed 03/13/26 Page 5 of 5 1 IV. CONCLUSION", "ai_tool_named": null, "archive_url": null, "case_name": "Albert Taylor v. Las Vegas Metropolitan Police Department, et al.", "citation": null, "cited_authorities": [ "s filings contained citations to non-existent cases; the court described them as", "Rule 11" ], "court": "United States District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-13", "decision_id": "nvd-2026-albert-taylor-v-las-vegas-metropolitan-police-department", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 2:25-cv-00840-APG-NJK", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's opposition used hallucinogenic citations to nonexistent cases while opposing dismissal motions.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1695/Taylor_v._Las_Vegas_Metro_USA_13_March_2026.pdf", "state": "NV", "summary": "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.", "text_sha256": "ab83f83e41808d294118151599afcd0a0eabff7abe71396a5c3035fd3aa6cf7f", "topics": [ "fabricated-citations" ], "tracker_slug": "albert-taylor-v-las-vegas-metropolitan-police-department-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nvd-2026-albert-taylor-v-las-vegas-metropolitan-police-department", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-albert-taylor-v-las-vegas-metropolitan-police-department" }, { "ai_passage": "2 Adding these concededly erroneous case citations to the 30 false case citations and four fictitious [Federal Acquisition Regulation] cites that appellant included in its Rule 11 Surreply, to date appellant has admitted to including 39 total cites across these three briefs that cite to cases that do not exist. 9 In response, on March 5, 2026, appellant denied that its briefing cites 39 non-existent cases, but admitted that appellant “made references to ten (10) non-existing cases; one (1) in the Opening Brief, one (1) in its January 9, 2026 brief on the vitiation issue, and eight (8) in its Rule 11 Surreply.” 10 Appellant’s March 5, 2026 brief states further that those ten citations of non-existent cases “represent an unintentional lapse in providing inaccurate citation rather than a fraud upon the Board.” 11 That brief does not mention AI, or otherwise explain with any specificity how it happened that appellant cited ten cases that do not exist. DECISION Filing briefs without taking the necessary care in their preparation, including reliance upon fictitious opinions or incorrect citations (whether AI-generated or not) risks sanctions; we have recently sanctioned a party for such behavior by striking an offending brief, guided by Rule 11 of the Federal Rules of Civil Procedure. See Huffman Constr., LLC, ASBCA Nos. 62591, 62873, 25-1 BCA ¶ 38,932 at 189,484-86. Without addressing whether it used AI to prepare its surreply, appellant admits that its original surreply includes “incorrect case names, erroneous reporter citations, and the misapplication of certain regulatory provisions.” 12 Having originally requested only that we strike that surreply, the government now requests (and not in the alternative) that we dismiss the appeal altogether, with prejudice. 13 We decline to do so. The government fails even to address whether appellant’s behavior is the kind of contumacious or contemptuous conduct sufficient to justify the drastic sanction of dismissal, “the severest sanction the Board can issue.” See Utility Constr. Co., ASBCA No. 57224, 12-2 BCA ¶ 35,128 at 172,467; Sykes Commc’ns, Inc., ASBCA Nos. 53842, 54077, 04-2 BCA ¶ 32,743 at 161,936. Nevertheless, in view of appellant’s admission that its December 1,", "ai_tool_named": null, "archive_url": null, "case_name": "DSME Construction Co., Ltd.", "citation": null, "cited_authorities": [ "Rule 11" ], "court": "Armed Services Board of Contract Appeals", "court_code": null, "court_level": "federal-specialty", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-13", "decision_id": "asbca-2026-dsme-construction", "disposition": "The court struck the defective filing and warned counsel to verify cited authorities before filing again.", "docket_number": "No. 63878", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's surreply contained five citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1875/dsme_construction_co._ltd._63878.pdf", "state": null, "summary": "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.", "text_sha256": "4712f88eb898002fd50ee1b197f05119accc6bbd0373354d8fcadee77070795b", "topics": [ "fabricated-citations" ], "tracker_slug": "dsme-construction-co-ltd", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/asbca-2026-dsme-construction", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/asbca-2026-dsme-construction" }, { "ai_passage": "along with many other cases cited in Suiter’s filings—are mischaracterized. Suiter includes numerous quotes that do not exist in the cited cases, and his briefs contain characteristics that the court has observed in filings made with generative artificial intelligence programs. Regardless of whether Suiter used these tools, submitting a filing containing fabricated authority or nonexistent quotes is unacceptable and “causes an enormous waste of judicial resources.” Powhatan Cnty. Sch. Bd. v. Skinger, No. 3:24-cv-00874, 2025 WL 1559593, at *10 (E.D. Va. June 2, 2025). Such a filing could also constitute a violation of Federal Rule of Civil Procedure 11, for which the court may impose sanctions. See Fed. R. Civ. P. 11(b)–(c). The court is sympathetic to the challenges associated with navigating the court system as a pro se litigant and concludes that a warning is appropriate at this time. However, Suiter is advised that if any of his future filings fabricate or misrepresent authorities, the court may order him to show cause why he should not face sanctions under Rule 11. See Fed. R. Civ. P. 11(c)(3). Sanctions could include the striking of filings, filing restrictions, monetary penalties, or the dismissal of his action. Overall, Suiter does not offer any legal authority requiring the tolling or restarting of a manufacturer’s warranty period simply because a vehicle is sold as", "ai_tool_named": null, "archive_url": null, "case_name": "Suiter v. GM - General Motors, LLC", "citation": null, "cited_authorities": [ "Powhatan Cnty. Sch. Bd. v. Skinger, No. 3:24-cv-00874, 2025 WL 1559593", "Fed. R. Civ. P. 11(b)", "Fed. R. Civ. P. 11(c)(3)", "Rule 11" ], "court": "United States District Court for the Western District of Virginia", "court_code": "vawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-12", "decision_id": "vawd-2026-suiter-v-gm-general-motors", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 5:24-cv-00054-JHY-JCH", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1650/Suiter_v._General_Motors_March_12_2026.pdf", "state": "VA", "summary": "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.", "text_sha256": "c58ae06d8b768a9abb5a294c2a28e8fcb374dd864477e755d2456e362d12e144", "topics": [ "fabricated-citations" ], "tracker_slug": "suiter-v-gm-general-motors-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/vawd-2026-suiter-v-gm-general-motors", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/vawd-2026-suiter-v-gm-general-motors" }, { "ai_passage": "2 The inaccuracies in Hartmann’s brief are typical of unverified, AI-generated filings, which have become an increasing concern for courts in recent years. While no federal or local rule explicitly prohibits the use of artificial intelligence in litigation, and Hartmann disclosed his use of generative AI in preparing his brief, see Pl.’s Resp. at 1 (acknowledging that Hartmann “used generative AI”), all parties—including those proceeding pro se—must fulfill their obligations under Federal Rule of Civil Procedure 11(b), which requires lawyers and unrepresented parties alike to certify that, after a reasonable inquiry, their legal contentions are warranted by existing law. Consequently, this duty necessitates a careful review of AI-generated statements and citations to ensure accuracy. 8 Case 3:24-cv-02317-BT Document 47 Filed 03/12/26 Page 9 of 15 PageID 2735 decision not to renew his employment contract. Board of Regents v. Roth, 408", "ai_tool_named": null, "archive_url": null, "case_name": "Hartmann v. Davidson", "citation": null, "cited_authorities": [ "Page 9 of 15 PageID 2735 decision not to renew his employment contract. Board of Regents v. Roth" ], "court": "United States District Court for the Northern District of Texas", "court_code": "txnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-12", "decision_id": "txnd-2026-hartmann-v-davidson", "disposition": "The court dismissed claims or denied relief after identifying the defective authorities.", "docket_number": "Case 3:24-cv-02317-BT", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained one citation defect involving incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1661/Hartmann_v._Jadou_USA_12_March_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "44d8aa44d33778a20524ad07882651b4c1bc3f93559d6dd3f85b5c108588270d", "topics": [ "fabricated-citations" ], "tracker_slug": "hartmann-v-davidson", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txnd-2026-hartmann-v-davidson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txnd-2026-hartmann-v-davidson" }, { "ai_passage": "have made clear that public comment should have been allowed, at least on the new evidence. 2 Although the Court does not address these arguments, it observes with great concern that Appellant's briefing on the definition of an “accessory” includes quotations of nonexistent law. Appellant cites two Rhode Island Supreme Court cases in support of her argument: Town of Smithfield v. Fanning, 602 A.2d 939 (R.I. 1992) and Duffy v. Milder, 896 A.2d 27 (R.I. 2006). These cases exist, but have nothing to do with the question presented. In Smithfield, our high court did not discuss accessory uses or the need for such uses to be consistent with the principle use. Even more disturbing – the sentence quoted from page 942 of Smithfield does not appear anywhere else in the case. Likewise, the Duffy case does not address a photography business in a residential area, it concerns a horse stable and equestrian center. The citations are inaccurate and misleading. Whether it is a short deadline, the rise of artificial intelligence, or a simple error, this leaves the Court doubting all that is said by counsel. Courts depend on memoranda from counsel to guide them through the issues raised in our adversary system. An attorney's work, in the noble profession of the practice of law, is his or her bond. The Court reserves its right to take further action but goes no further today other than to express its dissatisfaction at the presentation of an argument which appears to be the product of, at best, recklessness. “Justice is built on language, and language draws its power from the hearts and minds that create it. Words alone are empty until filled with human conviction. The same is true of every pleading filed before this Court. Generative technology can produce words, but it cannot give them belief. It cannot attach courage, sincerity, truth, or responsibility to what it writes. That remains the sacred duty of the lawyer who signs the page.” Mattox v. Product Innovations Research, LLC, No. 6:24-cv-235-JAR, 2025 WL 3012828, at *1 (E.D. Okla. Oct. 22, 2025).", "ai_tool_named": null, "archive_url": null, "case_name": "Donaghy v. Zoning Bd. of Review of the Town of North Kingstown", "citation": "2026 WL 771127", "cited_authorities": [ "Appellant's brief attributes a sentence to Town of Smithfield v. Fanning", "Town of Smithfield v. Fanning", "Duffy v. Milder", "Mattox v. Product Innovations Research" ], "court": "Rhode Island Superior Court", "court_code": "risuperct", "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-12", "decision_id": "risuperct-2026-donaghy-v-zoning-bd-of-review-of-the-town-of-north-kingstown", "disposition": "The court remanded the zoning appeal to the board for a continued public hearing and cautioned counsel about likely AI-generated citations.", "docket_number": "No. WC-2024-0649", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's appellate brief contained two citation defects, including Smithfield v. Fanning and Duffy v. Milder, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2332/05_-_Donaghy_v_Zoning_Bd_of_Review_of_the_Town_of_North_Kingstown.pdf", "state": "RI", "summary": "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.", "text_sha256": "4055be23f66645308994bf43a1305adef6b8793f4792ec3d85c1aa2a2584b6f1", "topics": [ "fabricated-citations" ], "tracker_slug": "donaghy-v-zoning-bd-of-review-of-the-town-of-north-kingstown", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/risuperct-2026-donaghy-v-zoning-bd-of-review-of-the-town-of-north-kingstown", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/risuperct-2026-donaghy-v-zoning-bd-of-review-of-the-town-of-north-kingstown" }, { "ai_passage": "subsequently directed counsel for the Plaintiffs and School District to state “whether or not they used generative AI in connection with their filings in the action.” Order [Doc. No. 14] at 3. The Court also referenced the Court’s Chambers Rules regarding the use of generative AI. Id. at 2. Plaintiffs’ counsel represented to the Court that “AI was not used to generate any content” and that reliance on an AI research assistant “did not supplant counsel’s independent review of [ ] cases.” Notice [Doc. No. 16]. Upon review of Plaintiffs’ Response brief [Doc. No. 10], the Court found three additional incorrect citations associated with Plaintiffs’ briefing on compliance with the Oklahoma Governmental Tort Claims Act (GTCA): (1) Lane v. Buchanan, 2021 OK CIV APP 8, ¶ 11, 489 P.3d 498, 502 (case does not exist and citations are not related to the GTCA); (2) Hall v. GEO Group, Inc., 2021 OK CIV APP 36, ¶ 15, 497 P.3d 136, 1241 (an Oklahoma Supreme Court case with the same name exists, but the indicated reporter citations are incorrect and the case does not support Plaintiffs’ proposition); and (3) Conley v. Board of Regents, 2002 OK CIV APP 84, ¶ 9, 55 P.3d 567, 570 (the case does not exist and citations are not related to the GTCA). Such incorrect citations may have been the result of reliance on a generative- AI program. “By presenting to the court a . . . written motion . . . an attorney . . . certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . the claims, defenses, and other legal contentions are warranted by existing law . . . .” Fed. R. Civ. P. 11(b)(2) (emphasis added). 12", "ai_tool_named": null, "archive_url": null, "case_name": "Dillon v. Myles Stephenson, et al.", "citation": null, "cited_authorities": [ "Lane v. Buchanan", "Hall v. GEO Group", "Conley v. Board of Regents", "Fed. R. Civ. P. 11(b)(2)" ], "court": "United States District Court for the Western District of Oklahoma", "court_code": "okwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-11", "decision_id": "okwd-2026-dillon-v-myles-stephenson", "disposition": "The court admonished counsel to verify cited authorities and avoid repeating the citation defects.", "docket_number": "Case 5:25-cv-00484-SLP", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained three citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1660/Dillon_v._Stephenson_USA_11_March_2026.pdf", "state": "OK", "summary": "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.", "text_sha256": "5d6cd750a23c661ab1492cf45b7e5607e97294c65ed92dea3097e2d3a94d802d", "topics": [ "fabricated-citations" ], "tracker_slug": "dillon-v-myles-stephenson-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/okwd-2026-dillon-v-myles-stephenson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/okwd-2026-dillon-v-myles-stephenson" }, { "ai_passage": "ultimately are not real.” Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341, 342 (E.D.N.Y. 2025). Courts in this circuit have repeatedly found that presenting AI-generated hallucinations as valid caselaw constitutes subjective bad faith. See Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 448–49 (S.D.N.Y. 2023); Benjamin, 779 F. Supp. 3d at 349–50; Ramirez v. Humala, No. 24-CV-242, 2025 WL 1384161, at *2 (E.D.N.Y. May 13, 2025); Kaur v. Desso, No. 25-CV-726, 2025 WL 1895859, at *3 (N.D.N.Y. July 9, 2025). “This conduct undermines the integrity of the judicial process and disrespects and wastes the Court’s and parties’ time and resources.” Andre v. Warden, FCI Danbury, No. 24-CV-01295, 2025 WL 3281732, at *10 (D. Conn. Nov. 25, 2025). “Without question, it is improper and unacceptable for litigants— including pro se litigants—to submit non-existent judicial opinions with fake quotes and citations.” Anonymous v. New York City Dep’t of Educ., No. 24-CV-04232, 2024 WL 3460049, at *7 (S.D.N.Y. July 18, 2024) (internal quotation marks omitted). In order to address the increase in generative AI use and hallucinations, many of my colleagues and I have adopted individual rules requiring all litigants, whether pro se or represented by counsel, to “disclose that AI has been used.” See, e.g., Individual R. & Prac. in Civ. Cases 4(J). In my rules, I also require the party to “further certify in the document that it has independently reviewed and verified the accuracy of any portion of the document drafted by generative AI” and “[f]ailure to comply with this rule may result in sanctions, the document being stricken, or other remedies that the Court deems appropriate.” Id. This obligation requires litigants to carefully review every statement and citation drafted by AI to ensure that it is legally and factually correct, particularly given that AI tools make it much easier for pro se litigants to submit “voluminous” briefing. See Thornock v. Corp. of the Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints, No. 25-CV-56, 2025 WL 1900314, at *4 n.5 (E.D. Va. July 9, 19", "ai_tool_named": null, "archive_url": null, "case_name": "Donte McClellon v. E. Rickard, Warden of FCI Otisville, et al.", "citation": null, "cited_authorities": [ "fake quotes and citations", "Benjamin v. Costco Wholesale Corp", "Courts in this circuit have repeatedly found that presenting AI-generated hallucinations as valid caselaw constitutes subjective bad faith. See Mata v. Avianca", "Ramirez v. Humala, No. 24-CV-242, 2025 WL 1384161", "Kaur v. Desso, No. 25-CV-726, 2025 WL 1895859", "Andre v. Warden", "Anonymous v. New York City Dep’t of Educ., No. 24-CV-04232, 2024 WL 3460049", "See Thornock v. Corp. of the Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints, No. 25-CV-56, 2025 WL 1900314" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-11", "decision_id": "nysd-2026-donte-mcclellon-v-e-rickard-warden-of-fci-otisville", "disposition": "The court warned the self-represented party to disclose AI use when required and to verify future citations.", "docket_number": "Case 1:24-cv-10053-VSB-BCM", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1647/McClennon_v._Rickard_USA_11_March_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "38a01f9ae0c0b0babd238ba23a45e31f2521f51554d0e19897c65f4bdd4ca212", "topics": [ "fabricated-citations" ], "tracker_slug": "donte-mcclellon-v-e-rickard-warden-of-fci-otisville-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-donte-mcclellon-v-e-rickard-warden-of-fci-otisville", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-donte-mcclellon-v-e-rickard-warden-of-fci-otisville" }, { "ai_passage": "See, e.g., Lothamer Tax Resolution v. Kimmel, Case No. 1:25-cv-579, ECF No. 184 (W.D. Mich. December 1, 2025) (imposing Rule 11 sanctions to address “briefs . . . riddled with incorrect citations”); United States v. Hayes, 763 F. Supp. 3d 1054, 1067 (E.D. Cal. 2025) (“Citing nonexistent case law or misrepresenting the holdings of a case is making a false statement to a court.”); Dehghani v. Castro, 782 F. Supp. 3d 1051, 1057 (D.N.M. 2025) (concluding that the submission of fabricated authorities violates Rule 11); Ferris v. Amazon.com, 778 F. Supp. 3d 879, 881 (N.D. Miss. 2025) (“Mr. Ferris violated Rule 11 by submitting false citations to the Court— first, in his complaint; then, after being put on notice by Defendant, in his subsequent filings.”). Case 1:24-cv-00666-JMB-SJB ECF No. 147, PageID.882 Filed 03/11/26 Page 4 of 4 “isolated incident.” See id. As to whether Defendant NAM or its counsel have “engaged in similar conduct in other litigation,” the Court has searched for the names “National Asset Mortgage” and counsel “Matthew R. Reinhardt,” in combination with the word “sanction,” and the Court has not identified other similar sanctions proceedings. See id. The Court notes that the fabricated quotation—although material as to the applicable statute of limitations—did not “infect” the remainder of Defendant NAM’s briefing. See id. The Court further notes that both parties offered only a brief discussion of the statute of limitations, and thus Defendant NAM’s fabricated quotation did not result in the expenditure of significant “time or expense” by the parties. See id. That said, Defendant NAM and its counsel have rendered the question of whether to impose sanctions a close one by failing to correct the quotations at issue even after Plaintiff Nai expressly informed them that they had misrepresented controlling authority to the Court. The Court is also", "ai_tool_named": null, "archive_url": null, "case_name": "Checks Aciek Ateny Nai v. National Asset Mortgage, LLC, et al.", "citation": null, "cited_authorities": [ "s Brief in Support of its Motion for Summary Judgment (ECF No. 117); quotation materially changed statute", "s Response in Opposition to Plaintiff", "Lothamer Tax Resolution v. Kimmel", "United States v. Hayes", "Dehghani v. Castro", "Ferris v. Amazon.com", "Rule 11" ], "court": "United States District Court for the Western District of Michigan", "court_code": "miwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-11", "decision_id": "miwd-2026-checks-aciek-ateny-nai-v-national-asset-mortgage", "disposition": "The court discharged the show-cause issue and declined Rule 11 sanctions after reviewing the explanation for the defective authorities.", "docket_number": "No. 1:24-cv-666", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1649/Nai_v._National_Asset_Mortgage_USA_11_March_2025.pdf", "state": "MI", "summary": "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.", "text_sha256": "af45b4e3fd81b8b481932abcd91a74c870d31d805238983719b9fbd8685e12ef", "topics": [ "fabricated-citations" ], "tracker_slug": "checks-aciek-ateny-nai-v-national-asset-mortgage-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/miwd-2026-checks-aciek-ateny-nai-v-national-asset-mortgage", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/miwd-2026-checks-aciek-ateny-nai-v-national-asset-mortgage" }, { "ai_passage": "Rule 15(a) to correct a misnomer.”). 3. Nonexistent Case Citations Defendants bring to the Court’s attention that Plaintiffs’ Opposition cites cases that do not exist and contain mischaracterizations of legal precedent and rules of law. The Court has conducted its own research into Plaintiffs’ citations and concludes that they are indeed nonexistent. [See Dkt. 74 at 2-3, 5 (citing, inter alia, nonexistent cases such as Schuh v. Weltman, Weinberg & Reis Co., LPA, 602 F. Supp. 2d 832 (S.D. Ohio 2009); Barbosa v. Target Corp., 2013 WL 6336093 (D. Mass. 2013); and Fleet Nat’l Bank v. Hunt, 385 Mass. 307 (1982)]. Although courts construe pro se filings liberally, there are “reasonable limits.” United States v. Valdez. 88 F.4th 334, 344 n. 7 (1st Cir. 2023) (quoting Dutil v. Murphy, 550 F.3d 154, 158 (1st Cir. 2008)). Pro se litigants “must be held generally to the same standards as an attorney.” Doe v. Solvay Pharms., Inc., 350 F. Supp. 2d 257, 260 n.3 (D. Me. 2004). Here, if an attorney had made a filing “rife with miscitations and AI hallucinations, that attorney would likely be subject to sanctions.” Everett J. Prescott, Inc. v. Beall, No. 25-CV-00071, 2025 WL 2084353, at *2 (D. Me. July 24, 2025). The Court does not take this lightly and reminds 6 Case 1:25-cv-11890-AK Document 87 Filed 03/11/26 Page 7 of 11 Plaintiffs that they may not make false or fictitious representations to the Court. Plaintiffs are ordered to certify in any future filings that they have reviewed the filings to confirm that citations are not hallucinated or falsely represented. See id. (imposing similar warnings for AI- hallucinated cases filed by pro se litigant). Plaintiffs are warned that if they make further false or fictitious filings, they may be subject to more severe sanctions, including dismissal of the case. 4. Facts and Arguments Outside Pleadings In their Opposition, Plaintiffs allege facts that are not in the Amended Complaint. For example, they assert that “Defendants knowingly retained Eastern Recovery, which was not properly licensed in Massachusetts or Rhode Island.” [Dkt. 55 at 3]. Plaintiffs have not moved", "ai_tool_named": null, "archive_url": null, "case_name": "Traver v. General Motors Financial Company Inc., et al.", "citation": null, "cited_authorities": [ "Opposition cited this case; the Court", "Schuh v. Weltman", "Barbosa v. Target Corp., 2013 WL 6336093", "Fleet Nat’l Bank v. Hunt", "United States v. Valdez. 88 F.4th 334", "Dutil v. Murphy", "Doe v. Solvay Pharms", "Inc. v. Beall, No. 25-CV-00071, 2025 WL 2084353" ], "court": "United States District Court for the District of Massachusetts", "court_code": "mad", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-11", "decision_id": "mad-2026-traver-v-general-motors-financial", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 1:25-cv-11890-AK", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's complaint contained three citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1677/Traver_v._General_Motors_USA_11_March_2026.pdf", "state": "MA", "summary": "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.", "text_sha256": "f7ef93e81fb3c6ae4db0f8f0e1a5a52cd004da42e94f364e6aef525b4c974195", "topics": [ "fabricated-citations" ], "tracker_slug": "traver-v-general-motors-financial-company-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mad-2026-traver-v-general-motors-financial", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mad-2026-traver-v-general-motors-financial" }, { "ai_passage": "App. 3d 677, 682 (1993). true ‘when the judgment order states that the court is fully advised in the premises.’ ” Id. (quoting Dell'Armi Builders, ¶ 13 The parties’ briefs also appear to violate the supreme Inc. v. Johnston, 172 Ill. App. 3d 144, 149 (1988)). court's guidance concerning the use of generative artificial intelligence (AI). See Ill. S. Ct. Policy on AI (eff. Jan. 1, *3 ¶ 17 As noted, the common law record lacks a report 2025). They contain in total six references styled as citations of proceedings or an adequate substitute. This court has no to legal authority—four from defendant and two from plaintiff knowledge of the evidence or arguments presented at trial —that do not support the propositions for which they are and the basis for the court's order, which was entered “after cited or that do not exist at all. We caution the parties to trial,” with all parties present, and the court “being fully comply with the supreme court's policy, which applies to advised.” Because we do not have an adequate record, we pro se litigants. See Ill. S. Ct. Policy on AI (eff. Jan. 1, must therefore presume that the court's decision complied 2025) (“self-represented litigants are accountable for their with the law and had a sufficient factual basis. Foutch, 99 Ill. final work product. All users must thoroughly review AI- 2d at 392. generated content before submitting it in any court proceeding to ensure accuracy ***.”). ¶ 18 For these reasons, we affirm the circuit court's decision. ¶ 14 This court has the discretion to strike noncompliant briefs ¶ 19 Affirmed. and dismiss an appeal for failure to adhere to the supreme Hospital, 2019 IL App (1st) 182348, ¶ 45. However, we will", "ai_tool_named": null, "archive_url": null, "case_name": "Kateryna Maslovska v. Ekaterina Shigabetdinova", "citation": "2026 IL App (1st) 250702-U", "cited_authorities": [ "The parties’ briefs also appear to violate the supreme Inc. v. Johnston" ], "court": "Appellate Court of Illinois", "court_code": "illappct", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-11", "decision_id": "illappct-2026-kateryna-maslovska-v-ekaterina-shigabetdinova", "disposition": "The court warned both sides to verify authorities and quotations before filing future papers.", "docket_number": "No. 1-25-0702", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained two citation defects involving mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1655/MASLOVSKA_v_EKATERINA_SHIGABETDINOVA_USA_11_March_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "498c47d6acc940ac9cd2950a94c85023076af3eab901422f975de5ceaa0dc0ed", "topics": [ "fabricated-citations" ], "tracker_slug": "kateryna-maslovska-v-ekaterina-shigabetdinova", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/illappct-2026-kateryna-maslovska-v-ekaterina-shigabetdinova", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illappct-2026-kateryna-maslovska-v-ekaterina-shigabetdinova" }, { "ai_passage": "FOR PUBLICATION IN THE PERMANENT record, we affirm on the merits without discussion. We write, LAW REPORTS. UNTIL RELEASED, IT IS however, to address our concerns with the purported legal SUBJECT TO REVISION OR WITHDRAWAL. authority upon which the appellant relied in her brief. The appellant cited thirteen different cases that do not exist. We District Court of Appeal of Florida, Fourth District. expressly disregard these hallucinated cases. Furthermore, the appellant cited nine different cases that do exist, but do SAMANTHA ROUSSELL, Appellant, not stand for the proposition described by the appellant. A v. party, whether represented by counsel or proceeding pro se, THE BANK OF NEW YORK is responsible for the content of any submission to the court. MELLON, ETC., et al., Appellees. If a party chooses to use artificial intelligence to assist in the preparation of a brief, it must do so with care and take No. 4D2025-1309 steps to ensure the accuracy of any submissions to the court. | “While we decline to do so here, this court has the authority to [March 11, 2026] sanction appellant under Florida Rule of Appellate Procedure Appeal from the Circuit Court for the Seventeenth Judicial 9.410(a) for failure to comply with Florida Rule of Appellate Circuit, Broward County; Gary Michael Farmer, Jr., Judge; Procedure 9.210(c).” Friend v. Serpa, 425 So. 3d 51 (Fla. 4th", "ai_tool_named": null, "archive_url": null, "case_name": "Samantha Roussell v. The Bank of New York Mellon", "citation": "2026 WL 681054", "cited_authorities": [ "Friend v. Serpa" ], "court": "District Court of Appeal of Florida", "court_code": "fladistctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-11", "decision_id": "fladistctapp-2026-samantha-roussell-v-the-bank-of-new-york-mellon", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 4D2025-1309", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellee brief contained two citation defects involving mischaracterized authority, incorrect statutory or rule text, defective exhibits or submissions.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1657/SAMANTHA_ROUSSELL_v_THE_BANK_OF_NEW_YORK_MELLON_USA_11_March_2026.pdf", "state": "FL", "summary": "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.", "text_sha256": "7b9f68fe83b791fbad3a6ddd193512cdce09c1d9edf114b09aee5eea68aed385", "topics": [ "fabricated-citations" ], "tracker_slug": "samantha-roussell-v-the-bank-of-new-york-mellon", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp-2026-samantha-roussell-v-the-bank-of-new-york-mellon", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp-2026-samantha-roussell-v-the-bank-of-new-york-mellon" }, { "ai_passage": "I. Hallucinated Cases Before this Court begins its analysis, it must address Blackburn’s pervasive citations to non-existent authority in his briefing in support of Defendants’ motion to dismiss. As Plaintiff points out, Defendants’ brief contains several fake authorities and misrepresentations of the law. Opp. at 10-11; see also Dkt. 57. Blackburn does not dispute this and instead states that the miscited cases resulted from using the AI legal research platform Protégé in LexisNexis. Dkt. 58. LexisNexis, however, provided a letter to the Court refuting that Blackburn had a subscription to its AI tools, “Lexis+ AI” or “Protege.” Dkt. 96-1. Thus, the Court is not only concerned with Blackburn’s submission of hallucinated cases and misstatements of the law in his brief, but also with his misrepresentations to the Court regarding the source of his research. Sanctions may be imposed for submitting false or nonexistent legal authority to the Court. See, e.g., Flycatcher Corp. v. Affable Ave. LLC, No. 24-cv-09429 (KPF), 2026 WL 306683, at *12-13 (S.D.N.Y. Feb. 5, 2026) (sanctioning attorney that submitted documents containing fake cases and misattributed quotes hallucinated by AI); Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 459-66 (S.D.N.Y. 2023) (same). Alternatively, the Court may refer an attorney to the Grievance Committee for filing such non-existent authority. See, e.g., Park v. Kim, 91 F.4th 610, 613-16 (2d Cir. 2024) (per curiam) (referring to Second Circuit’s Committee on Admissions and Grievances an attorney whose brief, drafted in reliance on ChatGPT, included fake opinions). Blackburn has been sanctioned and warned in the past for litigation misconduct. For example, in Zunzurovski v. Fisher, No. 23-cv-10881 (DLC), 2024 WL 1434076 (S.D.N.Y. Apr. 3, 2024), appeal dismissed, (July 30, 2024), Judge Denise Cote referred Blackburn to the Court’s Grievance Committee for failing to conduct a reasonable inquiry to support his assertion of", "ai_tool_named": "Protégé (LexisNexis)", "archive_url": null, "case_name": "Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law (1)", "citation": null, "cited_authorities": [ "s counsel contained multiple non-existent case citations and misstatements of law; court found pervasive", "cases and noted counsel attributed errors to use of", "Flycatcher Corp. v. Affable Ave. LLC, No. 24-cv-09429", "Mata v. Avianca", "Park v. Kim", "Zunzurovski v. Fisher, No. 23-cv-10881" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "nysd-2026-cartagena-v-dixon-blackburn-and-t-a-blackburn-law", "disposition": "The court referred counsel to disciplinary authorities for the defective citations.", "docket_number": "Case 1:25-cv-03552-JLR", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": "Protégé (LexisNexis)", "conduct": "Counsel's brief contained one citation defect, including Protégé, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1665/Cartagena_v._Dixon_USA_10_March_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "2859a48d96020d4c58f9d4e9beb9a5e0427aea050e01dba9bde9269826fb6468", "topics": [ "fabricated-citations" ], "tracker_slug": "cartagena-v-dixon-blackburn", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-cartagena-v-dixon-blackburn-and-t-a-blackburn-law", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-cartagena-v-dixon-blackburn-and-t-a-blackburn-law" }, { "ai_passage": "3 Brown does not assert that his statutory right to a speedy trial was violated. See Miss. Code Ann. § 99-17-1 (Rev. 2020). 4 In the State's appellate brief, the State asserts that regarding this issue, Brown cites three cases that do not exist and five others that his brief misattributes false facts, analyses, quotations, and holdings to otherwise genuine citations. Brown also cites seven cases for quotations that do not appear in those opinions. In the reply brief, Brown's counsel acknowledged these errors, which included “phantom cases” and incorrect citations. 5 Miranda v. Arizona, 384 U.S. 436 (1966).", "ai_tool_named": null, "archive_url": null, "case_name": "Brown v. State of Mississippi", "citation": "2026 WL 670733", "cited_authorities": [ "s brief cited three cases that do not exist (", "Miranda v. Arizona" ], "court": "Court of Appeals of Mississippi", "court_code": "missctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "missctapp-2026-brown-v-state-of-mississippi", "disposition": "The court warned counsel to verify legal authorities before future filings.", "docket_number": "NO. 2024-KA-00489-COA", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's reply brief contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1652/Brown_v._STA_USA_10_March_2026.pdf", "state": "MS", "summary": "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.", "text_sha256": "e137d4cf25e414c3a128ec07859ddebe9aacf4c6836fe293178ff300ebf90790", "topics": [ "fabricated-citations" ], "tracker_slug": "brown-v-state-of-mississippi", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/missctapp-2026-brown-v-state-of-mississippi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/missctapp-2026-brown-v-state-of-mississippi" }, { "ai_passage": "U.S. Dist. LEXIS 100748, at *1–4 (adopting in part a report and recommendation and imposing a $6,000 personal sanction where counsel admitted to filing briefs containing fictitious AI-generated citations); Virgil, 2026 U.S. Dist. LEXIS 29090, at *11 (recommending a $10,000 personal sanction for counsel filing five briefs that contained citations to non-existent cases); Salahuddin v. Coughlin, 999 F. Supp. 526, 529 (S.D.N.Y. 1998); Brown v. Lincoln Towing Serv., Inc., No. 88C0831, 1988 WL 93950 (N.D. Ill. 1988); Pravic v. U.S. Indus.-Clearing, 109 F.R.D. 620, 623 (E.D. Mich. 1986). While these cited cases involve attorneys failing to check the treatment and soundness of case citations, many of the principles on which those decisions are based also apply to pro se parties. See, e.g., Tsupko v. Kinetic Advantage, LLC, 2025 WL 2677157, at *5 (S.D. Ind. Sept. 17, 2025) (admonishing pro se plaintiff for citing non-existent caselaw and warning that \"any further non-compliance with all applicable Federal Rules of Civil Procedure and the Local Rules of this Court will result in sanctions against him which may include dismissal of this case . . . .\"). In consideration of Mr. Platt's pro se status, the Court will not at this time order him to show cause why the fictitious citations identified did not violate Rule 11(b) and why he should not 3 Case 1:25-cv-01866-SEB-KMB Document 27 Filed 03/10/26 Page 4 of 4 PageID #: 112", "ai_tool_named": null, "archive_url": null, "case_name": "Michael Platt v. Volunteers of America Ohio & Indiana", "citation": null, "cited_authorities": [ "Salahuddin v. Coughlin", "Brown v. Lincoln Towing Serv", "Pravic v. U.S. Indus.-Clearing", "Tsupko v. Kinetic Advantage", "Rule 11(b)" ], "court": "United States District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "insd-2026-michael-platt-v-volunteers-of-america-ohio-and-indiana", "disposition": "The court struck the defective filing and warned the self-represented party to verify cited authorities before filing again.", "docket_number": "Case 1:25-cv-01866-SEB-KMB", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1666/Platt_v._Volunteers_USA_10_MArch_2026.pdf", "state": "IN", "summary": "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.", "text_sha256": "53b9ef2bd5b2371d10c20e6c97799a60bda55ce201d37b7d05704ee3275c1f8a", "topics": [ "fabricated-citations" ], "tracker_slug": "michael-platt-v-volunteers-of-america-ohio-indiana", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/insd-2026-michael-platt-v-volunteers-of-america-ohio-and-indiana", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-michael-platt-v-volunteers-of-america-ohio-and-indiana" }, { "ai_passage": "the vulgar language used by M.R. in her signs, her conduct fails to rise to the level of a “credible threat” to establish names stated in the brief. 8 These errors could be chalked up harassment for the purposes of issuing a protection order. to mere carelessness, but we think it more likely that they are a The camera on M.R.’s house is situated in a place common result of legal research using generative artificial intelligence for a homeowner to be able to see who may be entering (“AI”). upon their property. A.K. did not prove by a preponderance of the evidence that the camera is meant to harass the victim [7] We recently observed that “[c]itations to fictitious, AI- or his family. generated authority is a growing problem nationwide” and that “[c]ourts have sanctioned both attorneys and pro se IT IS THEREFORE ORDERED, ADJUDGED AND litigants for including them in briefs.” Williams v. Kirch, DECREEED by the Court that the Petition for Order for 268 N.E.3d 284, 288 (Ind. Ct. App. 2025). “Judges must be Protection is hereby DENIED. able to rely on the authenticity of the authorities cited by the parties to make just decisions.” Id. Because M.R. does Appealed Order at 1-3. A.K. now appeals, pro se. not request any sanction or relief for this conduct, we deem it sufficient to admonish A.K. for his problematic citations shall grant relief necessary to bring about a cessation of the and caution him “against using AI to conduct legal research violence or threat of violence.” Id. 10 without independently verifying the citations generated.” Id. [11] In reviewing a trial court's judgment regarding a [8] A.K.’s overarching argument is that the trial court erred protective order, “we neither reweigh the evidence nor resolve in denying his petition for a civil protective order against questions of credibility.” N.E. v. L.W., 130 N.E.3d 102, M.R. Civil protective orders are governed by the Civil 107 (Ind. Ct. App. 2019). “We consider only the probative Protection Order Act (“the Act”), Indiana Code Chapter evidence and reasonable inferences that support the trial 34-26-5, which we construe to promote the “protection and court's judgment.” Id. We will reverse the judgment only if safety of all victims of harassment in a fair, prompt, and it is clearly erroneous. Id. “A judgment is clearly erroneous effective manner” and the prevention of future harassment. when a review of the record leaves us with a firm conviction", "ai_tool_named": null, "archive_url": null, "case_name": "A.K. v. M.R.", "citation": "2026 WL 672475", "cited_authorities": [ "994 N.E.2d 228", "106 N.E.3d 400", "212 N.E.3d 768", "Williams v. Kirch", "N.E. v. L.W" ], "court": "Indiana Court of Appeals", "court_code": "indctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "indctapp-2026-a-k-v-m-r", "disposition": "The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.", "docket_number": "No. 25A-PO-2249", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1681/AK_v._MR_USA_10_March_2026.pdf", "state": "IN", "summary": "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.", "text_sha256": "2d71829adb488bab10ef056417dbb45d57c1abded569ff31bc3263f9e3d940cc", "topics": [ "fabricated-citations" ], "tracker_slug": "a-k-v-m-r", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/indctapp-2026-a-k-v-m-r", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/indctapp-2026-a-k-v-m-r" }, { "ai_passage": "“A person commits a hate crime when, by reason of the actual or perceived . . . physical or mental disability . . . of another individual or group of individuals, regardless of the existence 3 The Court believes that Plaintiff may be using generative AI platforms, such as ChatGPT, to draft her filings. Plaintiff should be cautious when using these platforms. They are known to create fictitious citations and to misrepresent case holdings. Federal Rule of Civil Procedure 11 imposes a duty on pro se plaintiffs to ensure that all legal contentions are supported by existing law or a nonfrivolous argument for extending the law. Even if Plaintiff uses AI to draft her filings, she remains responsible for ensuring that they are accurate and do not include fabricated caselaw, citations, or quotations. The Court warns Plaintiff that failure to comply with Rule 11’s obligations may result in appropriate sanctions. 19 Case 3:25-cv-00845-JPG Document 75 Filed 03/10/26 Page 20 of 21 Page ID #589 of any other motivating factor or factors, he or she commits . . . intimidation . . . .” 720 ILCS 5/12-7.1(a). Intimidation occurs when a person, “with intent to cause another to perform or to", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Tina Rose v. City of West Frankfort et al.", "citation": null, "cited_authorities": [ "Rule 11" ], "court": "United States District Court for the Southern District of Illinois", "court_code": "ilsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "ilsd-2026-tina-rose-v-city-of-west-frankfort", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 3:25-cv-00845-JPG", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": "ChatGPT", "conduct": "The self-represented party's filing contained one citation defect involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1662/Rose_v._City_of_West_Frankfort_USA_10_March_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "02788bc6fd2637bf49e1af4f3ca168756711b78c908e35c9b179bc131e1f99d1", "topics": [ "fabricated-citations" ], "tracker_slug": "tina-rose-v-city-of-west-frankfort-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilsd-2026-tina-rose-v-city-of-west-frankfort", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilsd-2026-tina-rose-v-city-of-west-frankfort" }, { "ai_passage": "that she is representing herself does not relieve her of that duty. Filing a document that contains citations to nonexistent cases, quotes language that comes from no real case, or that contains arguments wholly unsupported by the record violates Rule 11. Allen did just that. This demonstrates that Allen failed to make a reasonable inquiry into the supporting law or facts. This wastes both the parties’ and the Court’s time attempting to locate nonexistent cases and unpack made up factual assertions. The Court sanctions Allen $1,500 for filing false cases and arguments to the Court in violation of Rule 11. See, e.g. Seth Cameron Virgil v. Experian Information Solutions Inc, et al., 2026 WL 401066, at *5 (S.D. Ind. Feb. 12, 2026) (recommending $10,000 sanction for submitting a brief with hallucinated cases); Mid Cent. Operating Eng’rs Health & Welfare Fund v. HoosierVac LLC, 2025 WL 1511211 (S.D. Ind. May 28, 2025) (imposing $6,000 sanctions for briefs containing hallucinated citations); Davis v. Marion Cnty. Superior Ct. Juv. Det. Ctr., 2025 WL 2502308 (S.D. Ind. Sept. 2, 2025) (recommending $7,500 sanction for a brief containing hallucinated citations). 21 Case: 1:25-cv-10438 Document #: 32 Filed: 03/10/26 Page 22 of 22 PageID #:386", "ai_tool_named": null, "archive_url": null, "case_name": "Helen Allen v. Cass Casper and Disparti Law Group", "citation": null, "cited_authorities": [ "Krause v. Meyers", "Krause", "Governmental Interinsurance Exchange v. Judge, 221 Ill. App. 3d 586", "Seth Cameron Virgil v. Experian Information Solutions Inc", "Mid Cent. Operating Eng’rs Health & Welfare Fund v. HoosierVac LLC, 2025 WL 1511211", "Davis v. Marion Cnty. Superior Ct. Juv. Det. Ctr., 2025 WL 2502308", "Rule 11" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "ilnd-2026-helen-allen-v-cass-casper-and-disparti-law-group", "disposition": "The court ordered the self-represented party to pay $1,500 for the defective authorities.", "docket_number": "No. 25 C 10438", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": "USD", "monetary_penalty": 1500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1663/Allen_v._Casper_USA_10_March_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "7e85e203b60fac24f9cf3f5df1c14d359d3feebf246e094bf036d725e11e0355", "topics": [ "fabricated-citations" ], "tracker_slug": "helen-allen-v-cass-casper-and-disparti-law-group", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-helen-allen-v-cass-casper-and-disparti-law-group", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-helen-allen-v-cass-casper-and-disparti-law-group" }, { "ai_passage": "after the 150-day deadline. service plans and did not involve a finding of unfitness. ¶ 47 On appeal, respondent, proceeding pro se, argues that: *10 ¶ 50 Further, respondent cites a case, In re K.B., 2019 (1) the trial court's fitness finding was against the manifest IL App (3d) 180086, which does not exist. The citation is weight of the evidence because the State relied on insufficient, therefore erroneous, which could be due to a transcription contradictory, and unreliable testimony; (2) the court erred error (see, e.g., In re K.B., 2019 IL App (4th) 190496) in relying on subjective assertions by CASA and the foster or reliance on an artificial intelligence (AI) research tool. parents that were not based on firsthand knowledge or Although the use of AI is not prohibited, litigants remain observations; (3) the court failed to consider agency-caused responsible for ensuring the accuracy of their filings. In re delays and deficiencies in services; (4) she was denied due Baby Boy, 2025 IL App (4th) 241427, ¶ 131. Citation to process; and (5) the trial court's best interests determination a nonexistent authority is grounds for striking a brief and was against the manifest weight of the evidence. dismissing an appeal. Pletcher v. Village of Libertyville Police Pension Board, 2025 IL App (2d) 240416-U, ¶ 29. Despite ¶ 48 We first address the State's argument that respondent's respondent's failure to comply with Rule 341(h) and her statement of facts should be stricken and her arguments erroneous citations, we will address her arguments on the deemed forfeited for failure to comply with Illinois Supreme merits because a biological parent's right to raise his or her Court Rule 341(h) (eff. Oct. 1, 2020). Rule 341(h) governs child is a fundamental liberty interest, and the involuntary the contents and requirements of an appellant's brief. Rule termination of parental rights is a drastic measure (In re 341(h)(6) provides that the statement of facts “shall contain Gwynne P., 215 Ill. 2d 340, 353 (2005)). In re C.R., 2024 the facts necessary to an understanding of the case, stated IL App (4th) 231441-U, ¶ 20 (addressing termination on the", "ai_tool_named": null, "archive_url": null, "case_name": "In re A.R. and N.R., Minors", "citation": "2026 IL App (2d) 250299-U", "cited_authorities": [ "s brief cited a non-existent authority", "Pletcher v. Village of Libertyville Police Pension Board" ], "court": "Appellate Court of Illinois", "court_code": "illappct", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "illappct-2026-in-re-a-r-and-n-r-minors", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellate brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1654/In_re_AR_and_NR_Minors_USA_10_March_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "87eb32809f1bf10b48df4a32638f94f599ec021cdfb382e0d289eb664f1f7b0b", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-a-r-and-n-r-minors", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/illappct-2026-in-re-a-r-and-n-r-minors", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illappct-2026-in-re-a-r-and-n-r-minors" }, { "ai_passage": "motions for reconsideration are reviewable as part of this appeal. (Ibid.) All further unattributed statutory references are to the Code of Civil Procedure. 2 The settlement agreement was referenced as “Exhibit A” to respondent's opposition but was not attached to the opposition. Instead, a note read, “Redacted due to confidentiality clause will release by court order as necessary.” 3 As respondent points out, appellant has cited three apparently nonexistent or miscited cases in his opening brief. While this court is permitted to impose sanctions for relying on nonexistent legal authority (Noland v. Land of the Free, L.P. (2025) 114 Cal.App.5th 426, 436), we decline to do so as appellant's opening brief was otherwise comprehensible. However, we caution appellant that any subsequent cases containing miscites will likely result in sanctions. Government Works.", "ai_tool_named": null, "archive_url": null, "case_name": "Arno Kuigoua v. Adam Michael Sacks", "citation": "2026 WL 673409", "cited_authorities": [ "s opening brief identified by respondent and noted by the court. || Fabricated: Case Law | Third apparently nonexistent or miscited case citation in appellant", "Noland v. Land of the Free" ], "court": "California Court of Appeal, Second District", "court_code": "calctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "calctapp-2026-arno-kuigoua-v-adam-michael-sacks", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 20STCV19534)", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's opening brief contained three citation defects involving nonexistent authorities, defective exhibits or submissions.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1678/Kouigoua_v._Sacks_USA_10_March_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "fc77f80ad3921d5bb50fd5c01c893f84b6de68eb10052ab43bd587caad6011c3", "topics": [ "fabricated-citations" ], "tracker_slug": "arno-kuigoua-v-adam-michael-sacks", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp-2026-arno-kuigoua-v-adam-michael-sacks", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp-2026-arno-kuigoua-v-adam-michael-sacks" }, { "ai_passage": "10 Arizona law recognizes for a viable wrongful termination claim. And he must identify 11 when the defamatory statement was made, who made it, and how it was conveyed to a third 12 party. 13 Finally, some of Hunter’s filings suggest he may be using generative artificial 14 intelligence (“generative AI”).3 The court has a general policy that requires any party that 15 uses generative AI in connection with filings to attach to the subject filing a separate 16 declaration disclosing the use of generative AI and certifying that the filer, in the exercise 17 of the filer’s independent judgment, has personally reviewed and verified the content of 18 the filing as accurate and in compliance with Federal Rule of Civil Procedure 11. The 19 declaration must identify which, if any, portion of the filing incorporates Generative AI 20 outputs. Any party who presents to the court a pleading, written motion, or other paper 21 incorporating inaccurate or undeclared generative AI outputs, including but not limited to 22 inaccurate or non-existent case citations, may be subject to sanctions including dismissal 23 without further warning. In preparing his amended complaint, Hunter must comply with 24 the court’s procedures regarding generative AI. 25 Accordingly, 26 IT IS ORDERED the amended complaint (Doc. 20) is DISMISSED WITH 27 3 “Generative AI” as used in this order refers to large language models that accept user 28 input and generate new content. Generative AI includes, but is not limited to, the tools available through ChatGPT, Claude, Copilot, DeepSeek, Google Gemini, and Grok. -6- Case 2:26-cv-00122-KML Document 22 Filed 03/10/26 Page 7 of 7 1 LEAVE TO AMEND. No later than March 25, 2026, plaintiff shall file an amended 2 complaint. The Clerk of Court is directed to enter a judgment of dismissal with prejudice", "ai_tool_named": null, "archive_url": null, "case_name": "Hunter v. TForce Freight Incorporated", "citation": null, "cited_authorities": [], "court": "United States District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-10", "decision_id": "azd-2026-hunter-v-tforce-freight-incorporated", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 2:26-cv-00122-KML", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1648/Hunter_v_TForce_Freight_Incorporated_USA_10_March_2026.pdf", "state": "AZ", "summary": "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.", "text_sha256": "931fa0aa11fe09ed6bdde0c6fe4c235089cdd056dff42131e673a322d38886a1", "topics": [ "fabricated-citations" ], "tracker_slug": "hunter-v-tforce-freight-incorporated", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azd-2026-hunter-v-tforce-freight-incorporated", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-hunter-v-tforce-freight-incorporated" }, { "ai_passage": "their cause to be just.” Int’l Railways of Cent. Am. v. United Brands Co., 532 F.2d 231, 239 (2d Cir. 1976). [ECF 23 at 16] Why is there a “need” for the Order? Because if fake quotes are not dealt with appropriately, they will proliferate. Tolerating them or ignoring them is a luxury the American judicial system cannot afford. Why is it “distressing”? Because of the widespread reporting on such phenomena since the spring of 2023, one would think that serious lawyers would be on their guard against fabrications, hallucinations and bogus material. See Mata v. Avianca, Inc, 678 F. Supp. 3d 443 (S.D.N.Y. 2023). It raises in the mind of the prudent jurist questions of what else the judge ought not trust in the lawyer’s brief. The distrust it breeds has the potential to hurt clients. Within fourteen days of this Order, counsel signing the brief, Michael Stanton, shall file a declaration fully, truthfully and with complete candor explaining how this happened.", "ai_tool_named": null, "archive_url": null, "case_name": "M7 Indústria e Comércio de Compensados e Laminados v. U.S. Structural Plywood Integrity Coalition, et al.", "citation": null, "cited_authorities": [ "Plaintiffs' memorandum attributed this quoted passage to NYNEX Corp. v. Discon", "Plaintiffs' memorandum attributed this quoted passage to Int’l Railways of Cent. Am. v. United Brands Co", "Int’l Railways of Cent. Am. v. United Brands Co", "See Mata v. Avianca" ], "court": "United States District Court for the Southern District of New York", "court_code": "nysd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-09", "decision_id": "nysd-2026-m7-industria-e-comercio-de-compensados-e", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "Case 1:25-cv-04568-PKC", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained two citation defects, including NYNEX Corp. v. Discon, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1664/M7_v._Plywood_USA_9_March_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "4bb1c45a213b3a48017f70e2fbaf580a398f1abda9866f1958f5b0f3ff105f00", "topics": [ "fabricated-citations" ], "tracker_slug": "m7-ind-stria-e-com-rcio-de-compensados-e-laminados-v-u-s-structural-plywood-inte", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nysd-2026-m7-industria-e-comercio-de-compensados-e", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-m7-industria-e-comercio-de-compensados-e" }, { "ai_passage": "Before addressing the merits of the case, we are troubled by *2 Pertaining to the case at hand, in 2022, Slay moved for a certain irregularities in the brief filed on Slay's behalf by his downward modification of his child support payments. Slay attorney, Loletha Hale. We note that several of the cases cited then amended his petition, seeking to increase the amount of therein appear to be fictitious.2 Such “hallucinated” cases are his visitation time during spring break and certain holidays. typically a hallmark of the irresponsible use of regenerative In response, Ross requested a reduction in Slay's visitation artificial intelligence (A.I.) in legal drafting. See Shahid v. time. Following a hearing, the trial court denied Slay's petition Esaam, 376 Ga. App. 145, 146(1) (918 SE2d 198) (2025). for modification of his child support payments and visitation Although we can only surmise that the brief was drafted with time, while granting Ross's request to reduce Slay's summer the use of unchecked generative A.I., we are aware that Hale visitation time. The trial court awarded Ross attorney fees has submitted a brief with seemingly similar defects in federal under OCGA §§ 19-6-15(k)(5) and 19-9-3(g) as to these district court. See Boston v. Williams, No. 1:23-CV-00752- claims. WMR (ND Ga. Dec. 5, 2025) (2025 WL 3895555). However, Ross has not complained, nor does it appear that the fictitious Contemporaneous with his petition to modify child support cases impeded her ability to respond to Slay's arguments. and visitation, Slay filed a petition for contempt, alleging Compare Shahid, 376 Ga. App. at 147(1) (finding the use Ross had failed to reimburse him for his summer child of bogus cases and citations in appellate brief “deprived the support payments, as previously ordered. This petition was opposing party of the opportunity to appropriately respond”). consolidated and addressed at the same hearing as the And, we are unaware of the imposition of any sanctions preceding petition. The trial court denied Slay's petition for against Hale for similar conduct in this Court. We thus caution contempt. Ross moved for attorney fees under OCGA § Hale that any future filings in this Court containing fictitious 9-15-14(b), which the trial court granted, concluding that the SLAY v. ROSS., --- S.E.2d ---- (2026) petition lacked substantial justification because Slay had not Mendoza, 303 Ga. App. 758, 763(2) (695 SE2d 47) (2010)", "ai_tool_named": null, "archive_url": null, "case_name": "Slay v. Ross", "citation": "2026 WL 656355", "cited_authorities": [ "Appellant's brief cited Waller v. Waller", "Appellant's brief cited Johnson v. Johnson", "Appellant's brief cited Durden v. Barron", "See Boston v. Williams, No. 1:23-CV-00752", "SLAY v. ROSS" ], "court": "Court of Appeals of Georgia", "court_code": "gactapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-09", "decision_id": "gactapp-2026-slay-v-ross", "disposition": "The court warned counsel to verify legal authorities before future filings.", "docket_number": "No. 1:23-CV-00752-", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's appellate brief cited four fictitious Georgia authorities, including Waller v. Waller, Johnson v. Johnson, Durden v. Barron, and In re Waitz.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1619/Slay_v._Ross_9_March_2026.pdf", "state": "GA", "summary": "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.", "text_sha256": "3b394a371d090c434462b8ee3e5e2ec54543aed63106846bedf692d3fd82ce98", "topics": [ "fabricated-citations" ], "tracker_slug": "slay-v-ross", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gactapp-2026-slay-v-ross", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gactapp-2026-slay-v-ross" }, { "ai_passage": "about the types of errors found in Plaintiff’s briefs: There is nothing inherently problematic with the use of artificial intelligence to help prepare legal materials, but its careless use can waste both judicial resources and the opposing party’s time and money, and it can damage the credibility of the legal system. . . . We warn [the plaintiff]—and all pro se litigants and counsel appearing before this court—of the responsibility to ensure that citations to legal authority are not fabrications but instead point to real cases that at least arguably stand for the propositions for which they are cited. Dodds v. Bridges, No. 25-7021, 2026 WL 380194, at *6 (10th Cir. Feb. 11, 2026) (citation modified). VII. Recommendation and Notice of Right to Object", "ai_tool_named": null, "archive_url": null, "case_name": "Dewayne Clark v. CoreCivic", "citation": null, "cited_authorities": [ "drastic remedy", "with caution", "so sick", "Plaintiff's citation to Lemons v. Portfolio Recovery Assocs. in his Surreply was incorrect per the court", "Dodds v. Bridges, No. 25-7021, 2026 WL 380194" ], "court": "United States District Court for the Western District of Oklahoma", "court_code": "okwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-06", "decision_id": "okwd-2026-dewayne-clark-v-corecivic", "disposition": "The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.", "docket_number": "Case 5:25-cv-00775-SLP", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1646/Clark_v._Corecivic_USA_6_March_2026.pdf", "state": "OK", "summary": "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.", "text_sha256": "66b962c0105e0f3da2aef3b938881c18caa58c90471896e6bc731705ed8d9415", "topics": [ "fabricated-citations" ], "tracker_slug": "dewayne-clark-v-corecivic", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/okwd-2026-dewayne-clark-v-corecivic", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/okwd-2026-dewayne-clark-v-corecivic" }, { "ai_passage": "extends to attorneys and pro se litigants alike. FRCP 11(b). However, the complaint is unclear about which There has been a rise in fake authority cited in briefs, usually defendants Harwell is suing for negligence. In different as the result of using generative AI software, like ChatGPT, parts of her complaint, she alleges that the “[d]efendants,” to draft pleadings or other court filings. Johnson v. MINI of WestCare, Davisson, or unnamed WestCare staff had or Las Vegas, No. 2:25-cv-00725-APG-EJY, 2025 WL 2718525, breached a duty to her. ECF No. 11 at 6, 11. The defendants at *3 (D. Nev. Sept. 24, 2025). Generative AI often invents defendants she is suing for each claim. She is not given leave fake cases and legal precedent in its drafting, and using it is to add any additional claims. no excuse to not verify the veracity of citations. Having to research fake authority and spend time chasing down that it is in fact not a real case wastes the time and resources of IV. CONCLUSION opposing parties and the court. Going forward, the parties are *8 I THEREFORE ORDER that the defendants’ motion reminded of their duty under FRCP 11(b)(2) and that citing to dismiss and for a more definite statement (ECF No. fake cases drafted by generative AI may violate this rule. 15) is GRANTED in part. I dismiss Harwell's § 504 Failure to comply in the future may result in sanctions, such discrimination claim against all defendants and dismiss her as an order to pay a penalty into court or to the other side, or § 504 retaliation claim against WestCare, Irma Magrdichian, nonmonetary directives. FRCP 11(c)(4). Leo Magrdichian, and Melinda Minor. I FURTHER ORDER that plaintiff Harwell may file an III. LEAVE TO AMEND COMPLAINT amended complaint asserting her § 504 discrimination, § I should freely give leave to amend a complaint “if it appears at all possible that the plaintiff can correct the 504 retaliation, and negligence claims and specifically stating", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Kim Elizabeth Harwell v. WestCare Nevada, Inc.", "citation": "2026 WL 658913", "cited_authorities": [ "Estate of Saila v. Circle K Corp", "Johnson v. MINI of WestCare" ], "court": "United States District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-06", "decision_id": "nvd-2026-kim-elizabeth-harwell-v-westcare-nevada", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 2:25-cv-00689-APG-BNW", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": "ChatGPT", "conduct": "The self-represented party's brief contained one citation defect, including Saila v. Circle, involving nonexistent authorities, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1623/Harwell_v._Westcare_Nevada.pdf", "state": "NV", "summary": "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.", "text_sha256": "60c62a064f1750282a16767492919ca79cf156cbd3c95759fbf98de2da1d9526", "topics": [ "fabricated-citations" ], "tracker_slug": "kim-elizabeth-harwell-v-westcare-nevada-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nvd-2026-kim-elizabeth-harwell-v-westcare-nevada", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-kim-elizabeth-harwell-v-westcare-nevada" }, { "ai_passage": "[ECF No. 139 at 2]. This objection reflects a fundamental misunderstanding of the statutory framework governing reports and recommendations and is without merit. 1 Under 28 U.S.C. § 1 It appears to the Court that Plaintiff relies on generative AI to make statements of law. However, the Court warns Plaintiff that generative AI does not necessarily generate accurate findings of law, can create incorrect or made-up citations, and should not be relied upon without review as a source 5 Case 4:24-cv-40113-MRG Document 149 Filed 03/06/26 Page 6 of 19 636(b)(1)(B) (“§ 636”), a district judge may refer dispositive matters, including motions to dismiss, to a magistrate judge for a report and recommendation, regardless of the parties’ consent Id.; see also Fed. R. Civ. P. 72(b)(1) (discussing magistrates judges’ ability to issue R&R’s “without", "ai_tool_named": null, "archive_url": null, "case_name": "Gregory J. Van Etten v. Stephanie K. Fattman, et al.", "citation": null, "cited_authorities": [ "s use of 28 U.S.C. § 636(b)(1)(B) to support the incorrect proposition that a magistrate", "Fed. R. Civ. P. 72", "Fed. R. Civ. P. 72(b)(1)" ], "court": "United States District Court for the District of Massachusetts", "court_code": "mad", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-06", "decision_id": "mad-2026-gregory-j-van-etten-v-stephanie-k-fattman", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 4:24-cv-40113-MRG", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1659/Van_Etten_v._Fattman_USA_6_March_2026.pdf", "state": "MA", "summary": "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.", "text_sha256": "e69e94ed7550d8891df7318150be027aa0a3519f43f255f5df9a2c331aec29e7", "topics": [ "fabricated-citations" ], "tracker_slug": "gregory-j-van-etten-v-stephanie-k-fattman-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mad-2026-gregory-j-van-etten-v-stephanie-k-fattman", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mad-2026-gregory-j-van-etten-v-stephanie-k-fattman" }, { "ai_passage": "by Friday, April 3, 2026, at 5:00 p.m. to: 1 Specifically, Mayeaux assets that “[h]e has undertaken concrete remedial measures, including enrolling in CLEs on AI- assisted legal practice, review of governing ethical guidance, and developing strengthened verification protocols to ensure that all authorities are independently confirmed before filing ....” See id. at 12. 2 Rule 11(b) provides that an attorney's signature on a written motion represents that the attorney's claims or legal contentions were warranted by existing law. See Fed. R. Civ. P. 11(b)(2). Upon a violation of Rule 11(b), Rule 11(c) provides discretion to the Court to issue an appropriate sanction on the attorney. See Fed. R. Civ. P. 11(c)(1). Government Works.", "ai_tool_named": "ChatGPT", "archive_url": null, "case_name": "Kattom v. Bondi", "citation": "2026 WL 637419", "cited_authorities": [ "Fed. R. Civ. P. 11(b)(2)", "Fed. R. Civ. P. 11(c)(1)", "Rule 11(b)", "Rule 11(c)" ], "court": "United States District Court for the Western District of Louisiana", "court_code": "lawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-06", "decision_id": "lawd-2026-kattom-v-bondi", "disposition": "The court ordered counsel to pay $1,000 for the defective authorities and complete corrective CLE.", "docket_number": "CIVIL ACTION NO. 25-1497 SEC P", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": "ChatGPT", "conduct": "Counsel's motion contained two citation defects involving fabricated or misattributed quotations, incorrect statutory or rule text.", "currency": "USD", "monetary_penalty": 1000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1622/Kattom_v._Bondi_USA_March_2026.pdf", "state": "LA", "summary": "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.", "text_sha256": "a823801a2e4a8be042e9aee27541992e7925452ff1e6246eba3564564d9eb104", "topics": [ "fabricated-citations" ], "tracker_slug": "kattom-v-bondi", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/lawd-2026-kattom-v-bondi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/lawd-2026-kattom-v-bondi" }, { "ai_passage": "question regarding the application of section 523(a)(8)(A) 1681i(a)), IV (willful violation of 15 U.S.C. § 1681i(a)), (i)”. Mader v. Equifax Info. Sols., Inc., 56 F.4th 264, 270 V (negligent violation of 15 U.S.C. § 1681e(b)), and VI (2d Cir. 2023) (plaintiff failed to allege an inaccuracy within (willful violation of 15 U.S.C. § 1681e(b)) are dismissed with the plain meaning of section 1681(e)(b) and the unresolved prejudice. Separately, the Court orders Plaintiff's counsel, legal question rendered his claim non-cognizable under the Attorney Heather Hersh, to show cause on April 9, 2026 at FCRA). This determination about Plaintiff's student loan 1:30 p.m. on why she should not be sanctioned pursuant to debt is outside the purview of Equifax. Chuluunbat, 4 (1) Rule 11(b)(2), (2) 28 U.S.C. § 1927, and (3) the inherent F.4th at 568; see also Denan, 959 F.3d at 297; Williams v. power of the Court, for citing potentially non-existent cases Equifax, 2025 WL 1733183, at *5 (N.D. Ga. June 17, 2025), to the Court in her opposition brief [29] and sur-reply [31]. report and recommendation adopted, No. 1:24-CV-04152- Indeed, the Court is concerned that counsel has misled the LMM-RDC, 2025 WL 2146367 (N.D. Ga. July 15, 2025) Court in citing cases that are nonexistent, or at a minimum, (granting defendant's motion to dismiss because the purported has failed to diligently cite check her submissions. In the event inaccuracy regarding the status of the plaintiff's student that the Court has simply been unable to find the cited cases loan debts would require the CRA to “step into the court's in its research, Plaintiff's counsel shall provide the Court with shoes to interpret section 523(a)(8)(A)(i))”); Johnson v. a true and accurate copy of Horan v. Equifax Info. Servs., TransUnion, No. 122CV02533JPBJKL, 2023 WL 6035573, LLC, No. 8:20-cv-02187-PWG, 2022 WL 2190906 (D. Md. at *4 (N.D. Ga. Aug. 11, 2023), report and recommendation June 17, 2022) and Jones v. TransUnion, LLC, No. 1:15- adopted, No. 1:22-CV-02533-JPB, 2023 WL 9315262 (N.D. cv-00489, 2015 WL 7566685 (N.D. Ill. Nov. 24, 2015). If Ga. Nov. 30, 2023) (“[T]he problem for Plaintiff is the counsel is unable to do so, Plaintiff's counsel shall submit a accuracy of the [disputed student loan debt] hinges entirely sworn declaration explaining to the Court how the opposition on whether the debt was discharged in bankruptcy, which, brief and sur-reply were generated and how counsel came under the circumstances of his case, presents a legal issue to locate Horan and Jones, by April 3, 2026. Show-cause and, therefore, is not actionable under either § 1681e(b) or § hearing set for April 9, 2026, at 1:30 pm via Webex (https:// 1681i.”). us-courts.webex.com/join/mary_rowlandilnd.uscourts.gov).", "ai_tool_named": null, "archive_url": null, "case_name": "Hatch v. College Ave Student Loans", "citation": "2026 WL 636816", "cited_authorities": [ "Plaintiff's counsel cited Jones v. TransUnion", "Plaintiff's counsel cited Horan v. Equifax Info. Servs", "Mader v. Equifax Info. Sols", "Johnson v. a true and accurate copy of Horan v. Equifax Info. Servs", "Jones v. TransUnion", "Rule 11(b)(2)" ], "court": "United States District Court for the Northern District of Illinois", "court_code": "ilnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-06", "decision_id": "ilnd-2026-hatch-v-college-ave-student-loans", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "No. 25-cv-05710", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1621/Hatch_v._Equifax_USA_6_March_2026.pdf", "state": "IL", "summary": "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.", "text_sha256": "cc370c9fac88010ebaa69ca8772622d997a7a05b7de7894a7a1400748ee7d03f", "topics": [ "fabricated-citations" ], "tracker_slug": "hatch-v-college-ave-student-loans", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ilnd-2026-hatch-v-college-ave-student-loans", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ilnd-2026-hatch-v-college-ave-student-loans" }, { "ai_passage": "includes citation to several cases that do not appear to exist. 8 The cases bear the stamp of having been invented by artificial intelligence, given that they resemble authentic case citations, but when the reporter numbers are searched, turn up entirely unrelated cases that do not match the same name, date, or jurisdiction cited in the complaint, let alone support the propositions for which they are cited. Acknowledging that Plaintiff is a pro se litigant, Plaintiff is reminded that they have an obligation to comply with Rule 11, which imposes an affirmative duty to conduct a “‘reasonable [inquiry]’ into the substance of a filing before it is presented to the Court, including verifying that every citation is real.” Rubio v. District of Columbia, No. 23-cv-719, 2024 WL 4957373, at *4 (D.D.C. Dec. 3, 2024) (quoting Fed. R. Civ. P. 11(b)(2)). The failure to do so has led some courts to impose Rule 11 sanctions for the improper use of AI assistance. See id. The Court finds this admonition to abide by Rule 11 highly relevant given that Plaintiff has represented that they are a law student set to graduate this spring. ECF 1-2 at 6. Accordingly, it is hereby ORDERED that Defendant’s partial motion to dismiss, ECF 6, is DENIED as to Plaintiff’s CPPA claim, and GRANTED as to Plaintiff’s claims for (1) breach", "ai_tool_named": null, "archive_url": null, "case_name": "Andre Lamont Goddard, Jr. v. City University of Seattle", "citation": null, "cited_authorities": [ "s proposition. || Fabricated: Case Law | Court could not locate the cited case and found it likely fabricated; citation does not support plaintiff", "Rubio v. District of Columbia, No. 23-cv-719, 2024 WL 4957373", "Fed. R. Civ. P. 11(b)(2)", "Rule 11" ], "court": "United States District Court for the District of Columbia", "court_code": "dcd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-06", "decision_id": "dcd-2026-andre-lamont-goddard-jr-v-city-university-of-seattle", "disposition": "The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.", "docket_number": "Case 1:25-cv-01881-JMC", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained five citation defects involving mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1651/Lamont_v._City_U_of_Seattle_USA_6_March_2026.pdf", "state": "DC", "summary": "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.", "text_sha256": "99b5bdbc7ff673a3e08eecb307d84afc1b3ec9ab56a7c34a4ae91f1cc3295b2b", "topics": [ "fabricated-citations" ], "tracker_slug": "andre-lamont-goddard-jr-v-city-university-of-seattle", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/dcd-2026-andre-lamont-goddard-jr-v-city-university-of-seattle", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/dcd-2026-andre-lamont-goddard-jr-v-city-university-of-seattle" }, { "ai_passage": "now or heretofore owing or accrued. (Settlement Agreement ¶ 2.) To the extent Plaintiff used artificial intelligence in drafting her papers, the Court reminds Plaintiff “[w]hile courts afford pro se litigants considerable leeway, that leeway does not relieve pro se litigants of their obligation under Rule 11 to confirm the validity of any cited legal authority.” Robinson v. Oglala Sioux Tribe, Civ. A. No. 25-289, 2025 WL 2609573, at *4 (W.D. Okla. Sept. 9, 2025) (quoting Sanders v. United States, 176 Fed. Cl. 163, 169 (2025)); see also DeAngelo v. Freedom Mortg., Civ. A. No. 25-cv-13099, 2025 WL 4275514, at *3 n.4 (D.N.J. Nov. 12, 2025) (“Plaintiff is reminded that her pro se status does not shield her from sanctions under Federal Rule of Civil Procedure 11, which provides that any pleading, written motion or other paper submitted to the court must certify to the best of that person's knowledge, information and belief and formed after an inquiry reasonable under the circumstances that it is not being presented for an improper purpose, such as to harass, and that the claims and legal contentions are warranted by existing law or by a nonfrivolous argument that existing law should [not] apply.”). Therefore, in any future filings with the Court, Plaintiff is directed to read the cases she cites with greater care to ensure she is not only citing real cases but also accurately characterizing what those cases say.", "ai_tool_named": null, "archive_url": null, "case_name": "Lawand Hill v. Sloppy Vinyl, LLC, et al.", "citation": null, "cited_authorities": [ "never becomes binding", "may not consider matters extraneous to the pleadings", "Robinson v. Oglala Sioux Tribe", "Sanders v. United States", "DeAngelo v. Freedom Mortg", "Rule 11" ], "court": "United States District Court for the District of New Jersey", "court_code": "njd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-05", "decision_id": "njd-2026-lawand-hill-v-sloppy-vinyl", "disposition": "The court granted defendants' motion to dismiss, dismissed the complaint without prejudice, and reminded the plaintiff that false authorities may draw Rule 11 sanctions.", "docket_number": "Case 2:25-cv-15238-BRM-AME", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1616/Hill_v._Sloppy_Vinyl_USA_5_March_2026.pdf", "state": "NJ", "summary": "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.", "text_sha256": "7df0b42a90cc6e4e42fc2225a5929f188045a38d3b5a003f25f97a6d3f7694d4", "topics": [ "fabricated-citations" ], "tracker_slug": "lawand-hill-v-sloppy-vinyl-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/njd-2026-lawand-hill-v-sloppy-vinyl", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/njd-2026-lawand-hill-v-sloppy-vinyl" }, { "ai_passage": "III. ANALYSIS The problem of AI-fabricated case citations is well-documented throughout the judiciary, including in this circuit. See, e.g., Fletcher v. Experian Info. Sols., Inc., 2026 WL 456842, at *2 (5th Cir. Feb. 18, 2026) (“Regrettably, despite numerous news stories, CLE presentations, scholarly articles, and judicial entreaties, AI-hallucinated case citations have increasingly become an even greater problem in our courts, and the problem shows no sign of abating.”) (collecting cases). “To ethically use generative AI in the practice of law—which we do not dispute can be helpful if done properly and carefully—a lawyer must ‘ensure that the legal propositions and authority generated are trustworthy.’” Id. (citation omitted). “Failure to do so ‘abdicate[s] one’s duty, waste[s] legal resources, and lower[s] the public’s respect for the legal profession and judicial proceedings.’” Id. (citation omitted) (alteration in original). In this case, one attorney has candidly admitted to the Court that he alone was responsible for using generative AI technology to draft the opposition motion without verifying the accuracy of the citations.15 In doing so, Mr. Walker failed in his obligation to conduct a reasonable inquiry into the law and facts underlying Plaintiff’s brief. See City of Bogalusa, 168 F.3d at 241. The Court thus finds that Mr. Walker violated Rule 11(b)(2) by citing to fabricated AI-generated cases and by “fail[ing] to 15 ECF No. 104-1. 5 Case 2:23-cv-05824-BSL-EJD Document 117 Filed 03/05/26 Page 6 of 8", "ai_tool_named": null, "archive_url": null, "case_name": "Woodward Harbor L.L.C., et al. v. City of Mandeville", "citation": null, "cited_authorities": [ "Wood v. City of Utica", "Qutb v. Ramsey", "Plaintiffs cited a non-existent case 'Wood v. City of Utica' to support a legal proposition", "Plaintiffs cited 'Qutb v. Ramsey' with an incorrect reporter and circuit", "Fletcher v. Experian Info. Sols", "Rule 11(b)(2)" ], "court": "United States District Court for the Eastern District of Louisiana", "court_code": "laed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-05", "decision_id": "laed-2026-woodward-harbor-v-city-of-mandeville", "disposition": "The court ordered counsel to pay $1,000 for the defective authorities and complete corrective CLE.", "docket_number": "Case 2:23-cv-05824-BSL-EJD", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "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.", "currency": "USD", "monetary_penalty": 1000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1600/Woodward_Harbor_LLC_et_al_v_City_of_Mandeville_et_al__laedce-23-05824__0117.0.pdf", "state": "LA", "summary": "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.", "text_sha256": "4689311badcfa082f676e0b6a6eae027dd95de9cab333df21e86096dd92fa295", "topics": [ "fabricated-citations" ], "tracker_slug": "woodward-harbor-l-l-c-et-al-v-city-of-mandeville", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/laed-2026-woodward-harbor-v-city-of-mandeville", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/laed-2026-woodward-harbor-v-city-of-mandeville" }, { "ai_passage": "therefore affirm the family court’s order. III We next consider whether to impose sanctions against Bonar for citing and relying on fictitious legal authorities in her oppositions to the motions to reinstate this appeal. Business and Professions Code section 6068, subdivision (d), states it is the duty of an attorney “[t]o employ . . . those means only as are consistent with truth, and never to seek to mislead the judge or any judicial officer by an artifice or false statement of fact or law.” California Rules of Professional Conduct, rule 3.3(a)(1) and (2), prohibit an attorney from “knowingly mak[ing] a false statement of fact or law to a tribunal or fail[ing] to correct a false statement of material fact or law previously made to the tribunal by the lawyer” or “knowingly misquot[ing] to a tribunal the language of a book, statute, decision or other authority.” A person’s knowledge may be inferred from the circumstances. (Cal. Rules Prof. Conduct, rule 1.0.1(f).) We may impose sanctions against appellate counsel for committing any unreasonable violation of the California Rules of Court. (Cal. Rules of Court, 17 rule 8.276(a)(4).) Relying on fictitious legal authority is sanctionable conduct because it constitutes an unreasonable violation of the rules requiring that each point be supported by actual legal authority (id., rule 8.204(a)(1)) and prohibiting citation of unpublished authorities (id., rule 8.1115(a)). (Shayan v. Shakib (2025) 116 Cal.App.5th 619, 624–625 (Shayan); Schlichter v. Kennedy (2025) 116 Cal.App.5th 24, 31–34 (Schlichter); People v. Alvarez (2025) 114 Cal.App.5th 1115, 1118–1120 (Alvarez); Noland, supra, 114 Cal.App.5th at pp. 443–447.) Bonar admits that she cited fictitious authority to the court, including the fictional Teegarden case apparently generated by AI and the nonexistent Twigg case discussed in the Reddit article that was authored by a non- attorney blogger. She also admits she did not verify this authority. For an attorney to cite and rely on a fictional case obtained from a Reddit article or an AI prompt without verifying and reading the case itself is an unreasonable violation of the Rules of Court. “[I]t is a fundamental duty of attorneys to read the legal authorities they cite in appellate briefs or any other court filings to determine that the authorities stand for the propositions for which they are cited.” (Noland, supra, 114 Cal.App.5th at p. 445.) “[T]he rules of this court impose on attorneys the obligation to assure that filings they sign do not falsely represent the holdings of cases.” (Shayan, supra, 116 Cal.App.5th at p. 624.) Making matters worse, even after counsel for Torres pointed out that Twigg was an invented case in his second motion to reinstate the appeal, Bonar doubled down. She continued to insist it was a “valid, published precedent[]” and a “legitimate California Supreme Court case, reported at 34 Cal.3d 926, 195 Cal.R", "ai_tool_named": null, "archive_url": null, "case_name": "Joan Pablo Torres Campos v. Leslie Ann Munoz", "citation": null, "cited_authorities": [ "Marriage of Twigg", "emotional well‑being in custody; Twigg does not exist and the citation", "In re Marriage of Teegarden", "Shayan v. Shakib", "Schlichter v. Kennedy", "People v. Alvarez" ], "court": "California Court of Appeal", "court_code": "calctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-05", "decision_id": "calctapp-2026-joan-pablo-torres-campos-v-leslie-ann-munoz", "disposition": "The court ordered counsel to pay $5,000 for the defective authorities and referred the matter for discipline and complete corrective CLE.", "docket_number": "No. 19FL010817C)", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "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.", "currency": "USD", "monetary_penalty": 5000, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1599/D085584.pdf", "state": "CA", "summary": "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.", "text_sha256": "87ec3058732455a9f5da8a1e91b1f65e0bec5a19571090cc5219a9f2c21f5770", "topics": [ "fabricated-citations" ], "tracker_slug": "joan-pablo-torres-campos-v-leslie-ann-munoz", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp-2026-joan-pablo-torres-campos-v-leslie-ann-munoz", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp-2026-joan-pablo-torres-campos-v-leslie-ann-munoz" }, { "ai_passage": "1,200 documents, many of which are over a hundred pages result. long and were submitted after briefing was completed. We need not assume the duties of an advocate to search the record and support Stefanie's claims. See Adams v. Valley Nat'l Bank CONCLUSION of Ariz., 139 Ariz. 340, 343 (App. 1984). ¶14 We dismiss Stefanie's appeal under ARCAP 25 because ¶11 On top of that, Stefanie's briefs contain 25 citations that she continues to fabricate citations and omit record references are made up or contain substantial errors like fake quotes or despite our prior warning. unsupported propositions. For example: ¶15 Because counsel for James spent time and resources • Stefanie cites “Orlandini v. Crawford (Arizona Court of identifying Stefanie's violations, we award James his Appeals).” After diligent efforts, we cannot locate a case reasonable attorney fees and costs under ARCAP 25 upon bearing this name. compliance with ARCAP 21. See also A.R.S. § 12-349. • Stefanie quotes “Wallace v. Hon. Smith/Miller, 254 Ariz. 59, 61 ¶ 1 (2023)” as saying Rule 7 and § 12-2108 “together provide the exclusive framework for", "ai_tool_named": null, "archive_url": null, "case_name": "In the Matter of the Estate of Kuerschner", "citation": "2026 WL 619894", "cited_authorities": [ "Orlandini v. Crawford (Arizona Court of Appeals)", "Meara vacated sanctions; the court noted Takieh actually upheld sanctions and appellant", "Orlandini v. Crawford", "We need not assume the duties of an advocate to search the record and support Stefanie's claims. See Adams v. Valley Nat'l Bank CONCLUSION of Ariz", "Wallace v. Hon. Smith" ], "court": "Court of Appeals of Arizona", "court_code": "arizctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-05", "decision_id": "arizctapp-2026-in-the-matter-of-the-estate-of-kuerschner", "disposition": "The court dismissed the appeal under ARCAP 25 and awarded appellee reasonable attorney fees and costs for repeated fabricated citations.", "docket_number": "No. 1 CA-CV 25-0491 PB", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellate briefs contained 25 made-up or substantially erroneous citations, including fake quotes and unsupported propositions.", "currency": null, "monetary_penalty": null, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1611/In_the_Matter_of_the_Estate_of_KUERSCHNER_USA_5_March_2026.pdf", "state": "AZ", "summary": "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.", "text_sha256": "30c375c68efa9cfc3d5ab9db5b3faeb9b4e28016ce22b65aa662b42593e5779c", "topics": [ "fabricated-citations" ], "tracker_slug": "in-the-matter-of-the-estate-of-kuerschner", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/arizctapp-2026-in-the-matter-of-the-estate-of-kuerschner", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arizctapp-2026-in-the-matter-of-the-estate-of-kuerschner" }, { "ai_passage": "Dixon's ERISA claims is DENIED. However, MultiCare's treated more favorably than parties with attorneys of record. request to compel arbitration on those claims is GRANTED. Jacobsen v. Filler, 790 F.2d 1362, 1364 (9th Cir. 1986). Dixon's ERISA claims are STAYED pending arbitration. The parties shall file a Joint Status Report within 30 days of the Dixon repeatedly cites to nonexistent cases 9 and to other completion of any arbitration. cases 10 that do not support the proposition for which they were offered. The Court has no formal rule against the use Dixon's RCW 49.52.050 wage withholding claim is of generative artificial intelligence to write pleadings and DISMISSED with prejudice. Dixon's retaliation claim is briefs. However, parties are bound by Rule 11, which requires DISMISSED without prejudice. parties to certify that their “legal contentions are warranted by existing law or by a nonfrivolous argument for extending, Dixon's motion to compel production of plan documents, Dkt. modifying, or reversing existing law or for establishing new 19, is DENIED. Dixon's motion for an extension of time, law.” Fed. R. Civ. P. 11(b)(2). Dkt. 26; and MultiCare's motion for a status or scheduling conference, Dkt. 33, are DENIED as moot. Dixon's repeated and presumably intentional failure to verify cited authority supports an award of sanctions. If, in the Dated this 4th day of March, 2026. future, Dixon repeats this behavior, monetary sanctions may be awarded. A", "ai_tool_named": null, "archive_url": null, "case_name": "Ryan Adam Dixon v. MultiCare Health System (1)", "citation": "2026 WL 607769", "cited_authorities": [ "MultiCare's treated more favorably than parties with attorneys of record. request to compel arbitration on those claims is GRANTED. Jacobsen v. Filler", "Fed. R. Civ. P. 11(b)(2)", "Rule 11" ], "court": "United States District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-04", "decision_id": "wawd-2026-ryan-adam-dixon-v-multicare-health-system", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "NO. CV25-5414", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1614/RYAN_ADAM_DIXON_v_MULTICARE_HEALTH_SYSTEM_USA_4_March_2026.pdf", "state": "WA", "summary": "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.", "text_sha256": "5fc97787468044b4c1dc4d424af2b57df9b25cd4a0561b00a59ce416ed379c4f", "topics": [ "fabricated-citations" ], "tracker_slug": "ryan-adam-dixon-v-multicare-health-system-1", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wawd-2026-ryan-adam-dixon-v-multicare-health-system", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-ryan-adam-dixon-v-multicare-health-system" }, { "ai_passage": "3 GRANTS the Motion and ORDERS Plaintiffs’ counsel to explain: (1) each signatory’s role in 4 the use of the “juxtaposed” language and accompanying false citation in Plaintiffs’ Opposition to 5 Defendant’s Motion to Stay (Dkt. No. 122) (“Opposition”); (2) whether and how the drafting or 6 research for the Opposition was aided by the use of generative AI; and (3) what verification 7 mechanisms were in place for use of generative AI. This explanation must be filed on or before 8 March 18, 2026. 9 IT IS SO ORDERED. 10 DATED this 4th day of March, 2026. 11 12 _ 13 JOHN H. CHUN UNITED STATES DISTRICT JUDGE", "ai_tool_named": null, "archive_url": null, "case_name": "Medal v. Amazon.com Services, LLC", "citation": null, "cited_authorities": [ "21 U.S.C. § 343(r)(6)(D)" ], "court": "United States District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-04", "decision_id": "wawd-2026-medal-v-amazon-com-services", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "Case 2:23-cv-01975-JHC", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's opening brief included erroneous citations generated by AI-based search engines, combining captions, unrelated citations, and unsupported principles.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1629/2026-03-04_-_Amazon_-_Order_re_OSC.pdf", "state": "WA", "summary": "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.", "text_sha256": "90fd0a66a502973372e2880b86d3a5a081b52fab14405a0ab40408c26fa08a35", "topics": [ "fabricated-citations" ], "tracker_slug": "medal-v-amazon-com-services-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wawd-2026-medal-v-amazon-com-services", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-medal-v-amazon-com-services" }, { "ai_passage": "rely. Indeed, we can think of no other way to ensure that the arguments made based on those authorities are “warranted by existing law,” Fed. R. Civ. P. 11(b)(2), or otherwise “legally tenable.” Cooter & Gell, 496 U.S. at 393[ ]. As a District Judge of this Circuit recently held when presented with non-existent precedent generated by ChatGPT: “A fake opinion is not ‘existing law’ and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law. An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” Mata v. Avianca, Inc., [678 F. Supp. 3d 443, 461 (S.D.N.Y. 2023)]. Park, 91 F.4th at 615 (additional citation omitted). A court may “initiate sanctions sua sponte by issuing an order ‘to show cause why conduct specifically described in the order has not violated Rule 11(b).’” Kyros Law, 78 F.4th at 543 (quoting Fed. R. Civ. P. 11(c)(3)). As such, Mr. Mills is hereby ordered to show cause, in writing by March 20, 2026, why he should not be sanctioned pursuant to Rule 11(b) for including and relying on fabricated caselaw in the Response. Dkt. No. 20 at ¶¶ 62-63. Mr. Mills is directed to address whether he used artificial intelligence in drafting the Response and what steps he took to confirm the existence and validity of the caselaw. V. CONCLUSION", "ai_tool_named": null, "archive_url": null, "case_name": "Jeri'yah Ford v. Troy City School District, et al.", "citation": null, "cited_authorities": [ "Mata v. Avianca", "Fed. R. Civ. P. 11(b)(2)", "Fed. R. Civ. P. 11(c)(3)", "Rule 11(b)" ], "court": "United States District Court for the Northern District of New York", "court_code": "nynd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-04", "decision_id": "nynd-2026-jeri-yah-ford-v-troy-city-school-district", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "Case 1:25-cv-00364-AMN-DJS", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's response contained two citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1615/Ford_v._Troy_USA_4_March_2026.pdf", "state": "NY", "summary": "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.", "text_sha256": "b5f28b0515cacb7fcbb4cd6ccca55a5e526ea38c25fd4a9616cf41f0884381ab", "topics": [ "fabricated-citations" ], "tracker_slug": "jeriyah-ford-v-troy-city-school-district-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nynd-2026-jeri-yah-ford-v-troy-city-school-district", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nynd-2026-jeri-yah-ford-v-troy-city-school-district" }, { "ai_passage": "concerns the TEDRA Agreement. ORDER ON MS. WHITMAN’S AND MR. MAY’S MOTION FOR SUMMARY JUDGMENT Ms. Whitman also requests sanctions against Todd for filing Todd argues the court's order on summary judgment this frivolous appeal, his failure to comply with the RAPs, in favor of Ms. Whitman and Mr. May was inappropriate. and his multiple citations to fictious cases and authority. Ms. Whitman responds that Todd consented to summary RAP 18.9(a). Indeed, Todd cited to incorrect, chimerical, or judgment and may not now appeal that order. We agree with inapplicable case law throughout his briefing to support his Ms. Whitman. At the hearing on the motion for summary arguments. Where the case itself was not fabricated, Todd judgment, Todd's counsel confirmed he did not oppose the often misquoted or misrepresented the holdings. We decline motion. Consequently, the court entered an order granting to sanction Todd for his use of fictitious case law and failure summary judgment in favor of Ms. Whitman and Mr. May. to comply with the RAPs but order sanctions for the filing this Todd cannot be heard objecting in this court to that which he frivolous appeal. assented to in the superior court. Port v. Parfit, 4 Wash. 369, 375, 30 P. 328 (1892). CONCLUSION ATTORNEY FEES We affirm the trial court's order on summary judgment All parties request their attorney fees on appeal. Because Todd and decline review of Todd's purported errors that he was has not prevailed, he is not entitled to attorney fees. Ms. wrongly removed as PR, was afforded ineffective assistance Whitman and Mr. May request their fees pursuant to RAP of counsel, and that the Agreement was signed by him under 18.1, RCW 11.96A.150, RCW 4.84.185, and the Agreement. duress and should be invalidated. We award Ms. Whitman and We grant Ms. Whitman's and Mr. May's requests. Mr. May attorney fees and costs and sanction Todd for filing this frivolous appeal.", "ai_tool_named": null, "archive_url": null, "case_name": "In the Matter of the Estate of CAROL M. CAREY", "citation": "2026 WL 586674", "cited_authorities": [ "In re Estate of Stoler, 113 Wn. App. 104 (2002)", "Estate of Wallace v. Palmer, 103 Wn. App. 1064 (2000)", "In re Estate of Powers, 255 Ill. App. 3d 1006 (1994)", "McIntosh v. McIntosh, 282 Ga. 610, 652 S.E.2d 546 (2007)", "In re Estate of Griffith, 327 P.3d 612 (Colo. 2014)", "Perez v. Pappas, 98 Wn.2d 835, 659 P.2d 475 (1983)", "State v. Neely" ], "court": "Court of Appeals of Washington", "court_code": "washctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-03", "decision_id": "washctapp-2026-in-the-matter-of-the-estate-of-carol-m-carey", "disposition": "The court ordered the self-represented party to pay or reimburse $1 in fees or costs for the defective filing.", "docket_number": "No. 40344-1-III", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellate brief contained six citation defects, including Perez v. Pappas, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": "USD", "monetary_penalty": 1, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1610/In_the_Matter_of_the_Estate_of_CAREY_USA_3_March_2026.pdf", "state": "WA", "summary": "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.", "text_sha256": "12fb4982cf4d82a6c2735506d34764b71e74aab85bf8f35f2213f1e2b56a28ba", "topics": [ "fabricated-citations" ], "tracker_slug": "in-the-matter-of-the-estate-of-carol-m-carey", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/washctapp-2026-in-the-matter-of-the-estate-of-carol-m-carey", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/washctapp-2026-in-the-matter-of-the-estate-of-carol-m-carey" }, { "ai_passage": "21 3. FRCP 60(b)(4) – Orders Void for Lack of Jurisdiction 22 23 Under FRCP 60(b)(4), a judgement or order may be set aside as void for lack of 24 2 25 In these motions, Debtor occasionally refers to inaccurate or nonexistent case citations. For example, in the First Relief Motion, Debtor cites “Whittaker v. Otto, 2014 WL 37845 (9th Cir.),” with the description “Counsel lacks Probation and Parole, 83 A.3d 293 (Commonwealth Court of Pennsylvania 2014), which does not discuss the 27 authority of counsel. Also in the First Relief Motion, Debtor cites to “In re Chionis, 531 B.R. 52 (coercive litigation threats violate bankruptcy protection.)” Chionis is not in 531 B.R. 52; it is an unpublished decision of the Ninth 28 Circuit Bankruptcy Appellate Panel which can be found at In re Chionis, 2013 WL 6840485 (9th Cir. BAP December 27, 2013) (concerning action for violation of discharge injunction; this decision is inapposite to Debtor’s FRCP 60 Motions). -16-", "ai_tool_named": null, "archive_url": null, "case_name": "In re Lusine Hakhverdyan", "citation": null, "cited_authorities": [ "Whittaker v. Otto, 2014 WL 37845 (9th Cir.)", "In re Chionis, 531 B.R. 52", "Whittaker v. Otto, 2014 WL 37845", "B.R. 52" ], "court": "United States Bankruptcy Court for the Central District of California", "court_code": "cacb", "court_level": "federal-bankruptcy", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-03", "decision_id": "cacb-2026-in-re-lusine-hakhverdyan", "disposition": "The court denied the debtor's Rule 60 motions after noting an inaccurate or nonexistent Whittaker citation in the debtor's papers.", "docket_number": "Case 1:25-bk-11049-VK", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's motion cited Whittaker v. Otto, 2014 WL 37845 (9th Cir.), which the court described as inaccurate or nonexistent.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1618/In_re_Lusine_Hackverdyan_USA_3_March_2026.pdf", "state": "CA", "summary": "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.", "text_sha256": "d6a30cf75e39e5f8f8986fec5d8b107aa8fe82d7495ccf15220fe0816782379d", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-lusine-hakhverdyan", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacb-2026-in-re-lusine-hakhverdyan", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacb-2026-in-re-lusine-hakhverdyan" }, { "ai_passage": "2 While not germane to our substantive analysis, the court notes that appellant's opening brief included several erroneous citations that the responsible attorneys at Corr|Downs PLLC have since indicated were generated by “AI-based search engines.” The citations for these cases appear to be a compilation of (a) a real or fictitious caption, (b) citations to other entirely different cases, and (c) legal principles that cannot reasonably be found in the cited cases. The conduct leading to these citations falls below our expectations of counsel, particularly since it is now well known in the legal community that AI resources can generate erroneous citations and false quotations. Understanding the gravity of this conduct, the responsible attorneys have taken steps to remediate the situation, have apologized to the court, and have represented that they are implementing additional quality-control protocols (as all lawyers should) to ensure this does not happen again.", "ai_tool_named": null, "archive_url": null, "case_name": "Put A Bird On It, LLC v. Seattle Arena Holdings, LLC", "citation": "2026 WL 579399", "cited_authorities": [ "AI-based search engines" ], "court": "Court of Appeals of Washington", "court_code": "washctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-02", "decision_id": "washctapp-2026-put-a-bird-on-it-v-seattle-arena", "disposition": "The court affirmed dismissal of the contract claims with prejudice and noted counsel's AI-based erroneous citations and false quotations.", "docket_number": "No. 87756-9-I", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's opening brief included several AI-generated erroneous citations and false quotations with mismatched captions, citations, and legal principles.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1613/PUT_A_BIRD_ON_IT_USA_2_March_2026.pdf", "state": "WA", "summary": "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.", "text_sha256": "9576e3297014de2ff4375cb6c227b9490bf72d438520c0a63cc2085f6714a5a6", "topics": [ "fabricated-citations" ], "tracker_slug": "put-a-bird-on-it-llc-v-seattle-arena-holdings-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/washctapp-2026-put-a-bird-on-it-v-seattle-arena", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/washctapp-2026-put-a-bird-on-it-v-seattle-arena" }, { "ai_passage": "opportunity to amend his complaint in response to the motion (Docket No. 23), which was addressed in the Report. Judge Love considered that the amended complaint did 1 Plaintiff’s citation in support of one of these objections, United States v. Lopez, 817 F.3d 541, 545 (5th Cir. 2016), appears to be a phantom case that does not exist. 3 Case 4:25-cv-01207-JDK-JDL Document 26 Filed 03/02/26 Page 4 of 4 PageID #: 169 not change the viability of the asserted claims and found that further amendment was futile in light of the affidavit of arrest. Docket No. 24 at 16 (citing Wilson v.", "ai_tool_named": null, "archive_url": null, "case_name": "Fabian Antonio Thomas v. Officer Skylar Sillivent, et al.", "citation": null, "cited_authorities": [ "United States v. Lopez" ], "court": "United States District Court for the Eastern District of Texas", "court_code": "txed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-02", "decision_id": "txed-2026-fabian-antonio-thomas-v-officer-skylar-sillivent", "disposition": "The court adopted the report and recommendation, granted defendants' motions to dismiss, and dismissed the action with prejudice.", "docket_number": "Case 4:25-cv-01207-JDK-JDL", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1617/Thomas_v._Sillivent_USA_3_March_2026.pdf", "state": "TX", "summary": "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.", "text_sha256": "e61738cca80ac6411837548bd131a73ac47e7b6f34ef0fc1b4a9fd3fa9c85160", "topics": [ "fabricated-citations" ], "tracker_slug": "fabian-antonio-thomas-v-officer-skylar-sillivent-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txed-2026-fabian-antonio-thomas-v-officer-skylar-sillivent", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txed-2026-fabian-antonio-thomas-v-officer-skylar-sillivent" }, { "ai_passage": "v. Sullivan, 915 F.2d 129, 130 (4th Cir. 1990). 4. The inclusion of a fabricated quotation from 32 C.F.R. § 199.21(d) in Defendants’ response opposing Fivehouse’s motion for a preliminary injunction (D.E. 39). 5. The inclusion of a fabricated quotation from 32 C.F.R. § 199.21(d) in Defendants’ response opposing Fivehouse’s motion for summary judgment (D.E. 90). 2 Case 2:25-cv-00041-M-RN Document 119 Filed 03/02/26 Page 2 of 4 6. Making false or misleading statements regarding how and why the fabricated quotations and misstatements appeared in D.E. 86. If established, such conduct may implicate North Carolina Rules of Professional Conduct 3.3(a)(1), 8.4(c), and 8.4(d). If a violation is established, the court may impose any sanction authorized by Rule 11, its", "ai_tool_named": null, "archive_url": null, "case_name": "Derence V. Fivehouse v. United States Department of Defense et al.", "citation": null, "cited_authorities": [ "n v. Sullivan in Defendants", "D.E.86 attributing holdings to Ohio Valley Environmental Coalition v. Aracoma Coal Co", "LLC v. National Marine Fisheries Service", "D.E.86 attributing holdings to Sierra Club v. United States Dept. of the Interior", "Rule 11", "32 C.F.R. § 199.21(d)" ], "court": "United States District Court for the Eastern District of North Carolina", "court_code": "nced", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-02", "decision_id": "nced-2026-derence-v-fivehouse-v-united-states-department-of-defense", "disposition": "The court admonished counsel to verify cited authorities and avoid repeating the citation defects.", "docket_number": "No. 2:25-CV-00041-M", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's motion contained seven citation defects involving fabricated or misattributed quotations, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1601/gov.uscourts.nced.221403.119.0_1.pdf", "state": "NC", "summary": "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.", "text_sha256": "a89bd47a05c1c2e25b2e317a6a9b1297bf7d73da24eda7a61d43f7466d45ee94", "topics": [ "fabricated-citations" ], "tracker_slug": "derence-v-fivehouse-v-united-states-department-of-defense-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nced-2026-derence-v-fivehouse-v-united-states-department-of-defense", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nced-2026-derence-v-fivehouse-v-united-states-department-of-defense" }, { "ai_passage": "cases and to avoid congestion in the calendars of the District 100% 100% Courts.” Link v. Wabash R. Co., 370 U.S. 626, 629–30 (1962). Exercising that power is increasingly important in the wake The office of the Eastern District of Michigan's Court of the exploding use of generative AI. Damien Charlotin, a Administrator provided the data in the above charts. The legal analyst, has tracked more than 500 legal decisions about “filings” in the charts reflect the number of complaints rather AI-generated hallucinated content in the United States. 7 than the number of documents filed by pro se plaintiffs. But The hallucinated content is “typically fake citations, but also the Court has observed that non-prisoner pro se plaintiffs other types of AI-generated arguments.” Id.; see also Sanders are increasingly likely to clog dockets with frivolous and v. United States, 176 Fed. Cl. 163, 169 (2025) (“It is no improper documents. secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen The sharp increase in frivolous pro se filings burdens a rash of cases in which both counsel and pro se litigants have the Court. See In re McDonald, 489 U.S. 180, 184-185 cited such fake, hallucinated cases in their briefs.”). (1989) (“Every paper filed with the Clerk of this Court, no matter how repetitious or frivolous, requires some portion Likely because of the availability of AI, non-prisoner pro se of the institution's limited resources. A part of the Court's filings have skyrocketed in this district and circuit, and such responsibility is to see that these resources are allocated in Hardy v. Whitaker, --- F.R.D. ---- (2026)", "ai_tool_named": null, "archive_url": null, "case_name": "Hardy v. Whitaker", "citation": "2026 WL 575225", "cited_authorities": [ "s MSJ included the citation", "the court identified it as a fabricated/phantom case likely produced by generative AI and flagged it as a hallucination. || Fabricated: Case Law | Plaintiff", "Thompson v. City of Lebanon, 813 F.3d 318, 323 (6th Cir. 2016)", "the court listed this as one of several fake citations and suspected AI-generated hallucination. || Fabricated: Case Law | Plaintiff", "Wesley v. Rigney, 860 F.3d 931 (6th Cir. 2017)", "phantom cases", "Plaintiff's MSJ included the citation 'Patel v. City of Ferndale", "Plaintiff's MSJ included the citation 'Thompson v. City of Lebanon", "Plaintiff's MSJ included the citation 'Spurlock v. Satterfield", "Plaintiff's MSJ included the citation 'Wesley v. Rigney", "Link v. Wabash R. Co", "Sanders are increasingly likely to clog dockets with frivolous and v. United States" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-03-02", "decision_id": "mied-2026-hardy-v-whitaker", "disposition": "The court adopted the report and recommendation, dismissed the amended complaint with prejudice, and entered a filing injunction.", "docket_number": "No. 1:24-cv-11270", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "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 318, 323 (6th Cir. 2016) and Spurlock v. Satterfield, 167 F.3d 915 (5th Cir. 1999), involving nonexistent...", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1605/Hardy_v_Whitaker_USA_2_February_2026.pdf", "state": "MI", "summary": "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.", "text_sha256": "92a6d6d41068d50e9aad0f42af95acbd8acc3c769e7393b332193bec2857a562", "topics": [ "fabricated-citations" ], "tracker_slug": "hardy-v-whitaker", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-hardy-v-whitaker", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-hardy-v-whitaker" }, { "ai_passage": "influence. See Rosenberg, 256 Ariz. at 364 ¶ 26. her amended opening brief, Sister-in-law does not specify which fees were excessive. Thus, the superior court's award ¶24 Sister-in-law cites no legal authority to support her of attorney fees is affirmed. position that expert testimony is required for a finding of unsound mind. Her argument is thus waived. See Sholes, 228 Ariz. at 460 ¶ 14, n.3; Ariz. R. Civ. App. P. 13(a) VII. Sister-in-Law's Appellate Briefs. (7) (each contention must contain “citation to supporting ¶29 Sister asserts “Appellant's Amended Opening Brief legal authority”). Similarly, Sister-in-law's argument that the appears to be copied and pasted from Artificial Intelligence superior court improperly characterized her prior conviction software, resulting in a seventy-two-page brief that is difficult for felony escape as a crimen falsi, a crime attributed to to understand.” This Court's review reveals that several dishonesty, is waived because she did not object at the of Sister-in-law's legal citations contain substantial defects, hearing. See Manner v. Raskin, 113 Ariz. 3, 4 (1976) (“failure including unsupported premises and fabricated quotations. to object” to alleged improper remarks “is deemed a waiver Thus, this Court finds Sister-in-law's opening brief and reply of the issue on appeal”). brief violate Arizona Rule of Civil Appellate Procedure 13(a) (7), which requires that arguments contain citations to legal ¶25 As to Sister-in-law's argument that Sister was not authority. credible, “it is not the function of this court ... to second- guess the credibility determinations of the judge who had the ¶30 Compliance with this Court's rules is not optional. The opportunity to evaluate the witnesses’ demeanor and make integrity of the appellate process depends on accurate and informed credibility determinations.” In re Est. of Newman, honest advocacy. In the future, failure to provide accurate 219 Ariz. 260, 271 ¶ 40 (App. 2008). legal authority may result in sanctions. See Ariz. R. Civ. App. P. 13(a)(7). VI. The Superior Court Did Not Err in Awarding Attorney Fees. VIII. Attorney Fees on Appeal.", "ai_tool_named": null, "archive_url": null, "case_name": "In the Matter of the Estate of Arturo Lopez", "citation": "2026 WL 555638", "cited_authorities": [ "See Manner v. Raskin" ], "court": "Court of Appeals of Arizona", "court_code": "arizctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-27", "decision_id": "arizctapp-2026-in-the-matter-of-the-estate-of-arturo-lopez", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 1 CA-CV 25-0041 PB", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's opening brief contained two citation defects involving fabricated or misattributed quotations, mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1586/Lopez_v._Dominguez_USA_27_February_2026.pdf", "state": "AZ", "summary": "Arizona Court of Appeals on 2026-02-27 in In the Matter of the Estate of Arturo Lopez found the self-represented party's opening brief contained two citation defects involving fabricated or misattributed quotations, mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "39b3decce8089236c651e290b61197d91851f590c8eacc2612b85daf2966aabe", "topics": [ "fabricated-citations" ], "tracker_slug": "in-the-matter-of-the-estate-of-arturo-lopez", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/arizctapp-2026-in-the-matter-of-the-estate-of-arturo-lopez", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arizctapp-2026-in-the-matter-of-the-estate-of-arturo-lopez" }, { "ai_passage": "3 Plaintiffs cite Ash throughout their briefing as standing for the proposition that bread products stored in local warehouses for various lengths of time were not in a continuous stream of interstate commerce because they were held in storage “without a fixed and persisting intent to ship to a particular customer.” (See, e.g., Resp. [#99], at 10.) Ash held precisely the opposite. In Ash, the Fifth Circuit affirmed the district court's grant of summary judgment in favor of the shipper based on the MCA exemption, finding that the totality of the circumstances supported a finding that there was a fixed intent to move the bread products in interstate commerce. Not only do Plaintiffs blatantly misrepresent the Fifth Circuit's holding in Ash, but they also manufacture or cite hallucinated quotations not appearing in the opinion.", "ai_tool_named": null, "archive_url": null, "case_name": "David Thomas v. The Quikrete Companies, LLC", "citation": "2026 WL 594760", "cited_authorities": [ "briefing allegedly", "attributed to the Fifth Circuit", "Fifth Circuit's decision in Ash v. Flowers Foods" ], "court": "United States District Court for the Western District of Texas", "court_code": "txwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-26", "decision_id": "txwd-2026-david-thomas-v-the-quikrete-companies", "disposition": "The magistrate judge recommended granting Quikrete summary judgment and denying plaintiffs' summary-judgment motion despite the hallucinated quotation.", "docket_number": null, "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's summary-judgment briefing misrepresented Ash v. Flowers Foods and used hallucinated quotations that do not appear in that opinion.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1607/Thomas_v._Quikrete_Company_USA_26_February_2026.pdf", "state": "TX", "summary": "Western District of Texas on 2026-02-26 in David Thomas v. The Quikrete Companies, LLC found counsel's summary-judgment briefing misrepresented Ash v. Flowers Foods and used hallucinated quotations that do not appear in that opinion. The magistrate judge recommended granting Quikrete summary judgment and denying plaintiffs' summary-judgment motion despite the hallucinated quotation.", "text_sha256": "e827992844fc65f99b6ed628dab676386f5851d8f6ff069945e1829eb35b6fb5", "topics": [ "fabricated-citations" ], "tracker_slug": "david-thomas-v-the-quikrete-companies-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txwd-2026-david-thomas-v-the-quikrete-companies", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txwd-2026-david-thomas-v-the-quikrete-companies" }, { "ai_passage": "1 Both of Ponce's motions and replies are filled with hallucinogenic citations to non-existent cases. To the extent Ponce has relied on artificial intelligence to write his papers, I caution him that it is his responsibility to check his case citations to ensure they are accurate and say what he claims they do. The failure to do so may expose him to sanctions under Federal Rule of Civil Procedure 11.", "ai_tool_named": null, "archive_url": null, "case_name": "United States v. Robert Ponce, Jr.", "citation": "2026 WL 540272", "cited_authorities": [ "s motions and replies cited non-existent cases; the court described them as" ], "court": "United States District Court for the District of Nevada", "court_code": "nvd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-26", "decision_id": "nvd-2026-united-states-v-robert-ponce-jr", "disposition": "The court warned counsel to verify legal authorities before future filings.", "docket_number": "No. 2:16-cr-00368-APG-PAL", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1589/USA_v._Ponce_USA_26_February_2026.pdf", "state": "NV", "summary": "District of Nevada on 2026-02-26 in United States v. Robert Ponce, Jr. found counsel's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned counsel to verify legal authorities before future filings in the challenged filing before resolving the pending matter.", "text_sha256": "32124e1d7d4011c19a6bbcd71f1afe22424913164df97baf1d6f68cac780b392", "topics": [ "fabricated-citations" ], "tracker_slug": "united-states-v-robert-ponce-jr", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nvd-2026-united-states-v-robert-ponce-jr", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2026-united-states-v-robert-ponce-jr" }, { "ai_passage": "II [¶1] Scott Volker appeals from a district court judgment dismissing his claims with prejudice as a Rule 11, [¶6] This Court must have jurisdiction to consider the merits N.D.R.Civ.P., sanction for repeatedly submitting fictitious, of an appeal. Desert Partners IV, L.P. v. Benson, 2014 ND AI-generated case citations. Danielle Hough, formerly known 192, ¶ 6, 855 N.W.2d 608. “The time limit for filing a notice as Danielle Nygaard, and Ahlaina Mohler moved to dismiss of appeal is jurisdictional.” Id. If this Court lacks jurisdiction, the appeal as untimely. We dismiss the appeal. the appeal must be dismissed. Holverson v. Lundberg, 2015 ND 225, ¶ 6, 869 N.W.2d 146. I III [¶2] Volker commenced this action against Hough and Mohler, who moved to dismiss the complaint at the district [¶7] Under N.D.R.App.P. 4(a)(1), a notice of appeal in a court. During the hearing on the motion, the court warned civil case “must be filed with the clerk of the supreme court Volker that his filings contained fictitious legal citations. within 60 days from service of notice of entry of the judgment Despite this warning, Volker filed additional briefs containing or order being appealed.” After the 60-day period expires, fictitious citations. The district court then issued an Order to this Court may extend the deadline for an additional 30 Show Cause. days upon a showing of excusable neglect or good cause. N.D.R.App.P. 4(a)(4). The “90-day limit, not the 60-day limit [¶3] At the Order to Show Cause hearing, the district court for filing notice of appeal, is jurisdictional.” City of Grand found that Volker had willfully defied the court and dismissed Forks v. Henderson, 297 N.W.2d 450, 451 (N.D. 1980). This the action with prejudice as a Rule 11 sanction. On May Court may not extend the time for appeal beyond the 90- 20, 2025, the district court entered an Order for Judgment day jurisdictional deadline. Id. Accordingly, the dispositive and Judgment dismissing Volker's claims with prejudice and", "ai_tool_named": null, "archive_url": null, "case_name": "Volker v. Nygaard", "citation": "2026 WL 533638", "cited_authorities": [ "L.P. v. Benson", "We dismiss the appeal. the appeal must be dismissed. Holverson v. Lundberg", "City of Grand found that Volker had willfully defied the court and dismissed Forks v. Henderson", "Rule 11" ], "court": "Supreme Court of North Dakota", "court_code": "nd", "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-26", "decision_id": "nd-2026-volker-v-nygaard", "disposition": "The court dismissed the appeal with prejudice as a Rule 11 sanction for repeated fictitious AI-generated citations.", "docket_number": "No. 20250309", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1590/Volker_v_Nygaard_USA_26_February_2026.pdf", "state": "ND", "summary": "Supreme Court of North Dakota on 2026-02-26 in Volker v. Nygaard found the self-represented party's brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court dismissed the appeal with prejudice as a Rule 11 sanction for repeated fictitious AI-generated citations.", "text_sha256": "e6a48b6f7a2ffac87a24df57d3d80e36163df2a52ccf767d6aac512e45fc2472", "topics": [ "fabricated-citations" ], "tracker_slug": "volker-v-nygaard", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nd-2026-volker-v-nygaard", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nd-2026-volker-v-nygaard" }, { "ai_passage": "1 The notice states that photographs of the stormwater drainage intake are attached, but no such photographs are included in the appellate record. 2 In his initial brief on appeal, Hicks cited two cases we could not locate, either by case name or citation. Those cases are Knight v. Pierson, Inc., 206 Ga. App. 514 (1992), and City of LaGrange v. Bolden, 261 Ga. 77 (1991). Although the City pointed out the inaccurate citation to the Knight case in its response brief, Hicks did not provide an explanation as to the cause of these fake case citations until this Court issued an order requiring Hicks to do so. Because counsel for Hicks has now taken responsibility and apologized for her actions in citing to nonexistent cases, which she believes came from an AI platform, we decline to issue sanctions. We recognize, however, that this troubling practice has become far too common and caution the bar that the failure to ensure the accuracy of filings in this Court may subject counsel to sanctions. See, e.g., Shahid v. Esaam, 376 Ga. App. 145, 149-50(1), 918 S.E.2d 198 (2025); Court of Appeals Rule 7.", "ai_tool_named": null, "archive_url": null, "case_name": "Hicks v. City of Albany", "citation": "2026 WL 537755", "cited_authorities": [ "Counsel cited Knight v. Pierson", "Counsel cited City of LaGrange v. Bolden", "Those cases are Knight v. Pierson", "City of LaGrange v. Bolden", "Shahid v. Esaam" ], "court": "Court of Appeals of Georgia", "court_code": "gactapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-26", "decision_id": "gactapp-2026-hicks-v-city-of-albany", "disposition": "The court warned counsel to verify legal authorities before future filings.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained two citation defects, including Knight v. Pierson, involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1582/Hicks_v_City_of_Albany_USA_26_February_2026.pdf", "state": "GA", "summary": "Court of Appeals of Georgia on 2026-02-26 in Hicks v. City of Albany found counsel's brief contained two citation defects, including Knight v. Pierson, involving nonexistent authorities, incorrect statutory or rule text. The court warned counsel to verify legal authorities before future filings.", "text_sha256": "f2c132d0ca3f6d83c5d475ef9c5831322db2ffabddbae36daf2d205012bd2473", "topics": [ "fabricated-citations" ], "tracker_slug": "hicks-v-city-of-albany", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gactapp-2026-hicks-v-city-of-albany", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gactapp-2026-hicks-v-city-of-albany" }, { "ai_passage": "authorities necessarily dooms her appeal. (Id. at p. 436.) v. Frederickson (2020) 8 Cal.5th 963, 1000 [“Self-represented [parties] are ‘held to the same standard of knowledge of law In total, Focia's opening brief contains 12 quotations, 11 and procedure as is an attorney[.]’ ”]; Rappleyea v. Campbell of which are fabrications. Several of these fake quotations (1994) 8 Cal.4th 975, 985 [“A doctrine generally requiring are attributed to nonexistent cases. For example, Focia cites or permitting exceptional treatment of parties who represent Medical Board v. Superior Court (2022) 88 Cal.App.5th 459, themselves would lead to a quagmire in the trial courts, and 475 (Medical Board) for the propositions that “ ‘[i]n high- would be unfair to the other parties to litigation.”].) stakes civil hearings, due process requires confrontation of the actual evidence[ ]’ ”; “ ‘[i]n liberty-depriving hearings, “[E]xtensive reliance on nonexistent legal authority ... due process requires advisement of the dangers of self- justif[ies] striking appellant's opening brief or dismissing the representation[ ]’ ”; and “ ‘[c]ross-examination of adverse appeal. [Citations.]” 3 (Noland, supra, 114 Cal.App.5th at p. witnesses is constitutionally required in high-stakes civil 436.) Because Focia's opening brief relies almost completely proceedings.’ ” (Bolding omitted.) No case titled “Medical on fabricated and inapposite legal authority, we dismiss her Board v. Superior Court” was published in 2022; the appeal. reporter citations given by Focia correspond to two inapposite criminal cases published the following year (People v. Venable (2023) 88 Cal.App.5th 445, People v. Sedano (2023) DISPOSITION 88 Cal.App.5th 474); and the above quotations do not appear in any case, published or nonpublished. “Medical Board,” and The appeal is dismissed. Focia to bear her own costs on the quotes taken from it, appear to be “AI ‘hallucinations[.]’ appeal. ” (Noland, supra, 114 Cal.App.5th at p. 431.) Furthermore, Focia's “brief[ ] [is] peppered with inaccurate NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS citations that do not support the propositions for which they are cited.” (Noland, supra, 114 Cal.App.5th at p. 436.) In one instance, Focia cites People v. Panah (2005) 35 Cal.4th 395, We concur: 475, as holding that “ ‘[a]dmitting a transcript without the original recording is reversible error.’ ” (Bolding omitted.) CHAVEZ, Acting P. J.", "ai_tool_named": null, "archive_url": null, "case_name": "Samuel K. v. Winsley Focia", "citation": "2026 WL 539183", "cited_authorities": [ "Medical Board v. Superior Court (2022) 88 Cal.App.5th 459, 475", "hallucinations", "Admitting a transcript without the original recording is reversible error", "peppered with inaccurate citations", "Opening brief cited a nonexistent case 'Medical Board v. Superior Court", "Brief quoted 'Admitting a transcript without the original recording is reversible error.' and cited People v. Panah", "Rappleyea v. Campbell of which are fabrications. Several of these fake quotations", "Focia cites or permitting exceptional treatment of parties who represent Medical Board v. Superior Court", "Board v. Superior Court", "People v. Venable", "People v. Sedano", "Focia cites People v. Panah" ], "court": "California Court of Appeal", "court_code": "calctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-26", "decision_id": "calctapp-2026-samuel-k-v-winsley-focia", "disposition": "The court dismissed the appeal, assessed appellate costs, and addressed the defective authorities.", "docket_number": "No. 24STRO08015)", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's opening brief contained three citation defects, including Medical Board v. Superior Court and People v. Panah, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "costs-order" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1587/Samuel_K._v._Focia_USA_26_February_2026.pdf", "state": "CA", "summary": "California Court of Appeal on 2026-02-26 in Samuel K. v. Winsley Focia found the self-represented party's opening brief contained three citation defects, including Medical Board v. Superior Court and People v. Panah, involving nonexistent authorities, fabricated or misattributed quotations. The court dismissed the appeal, assessed appellate costs, and addressed the defective authorities.", "text_sha256": "498d5c3519903063b6f39b16864474026d78d79ffe4c2237844b134fc9eff2db", "topics": [ "fabricated-citations" ], "tracker_slug": "samuel-k-v-winsley-focia", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp-2026-samuel-k-v-winsley-focia", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp-2026-samuel-k-v-winsley-focia" }, { "ai_passage": "CIVIL MINUTES – GENERAL Case No. 2:25-cv-02540-JLS-JPR Date: February 26, 2026 Title: Estate of Khallid Muhammad et al v. Tupac Shakur Estate et al Having reviewed Plaintiffs’ response, the Court finds it both vague and deficient. Plaintiffs are ORDERED TO APPEAR on March 6, 2026 at 10:30am in Courtroom 8A to show cause as to why they should not be sanctioned for providing non-existent case citations to the Court. Defendants may, but are not required to, appear at the hearing. Initials of Deputy Clerk: kd ______________________________________________________________________________ CIVIL MINUTES – GENERAL 2", "ai_tool_named": null, "archive_url": null, "case_name": "Estate of Khallid Muhammad et al v. Tupac Shakur Estate et al", "citation": null, "cited_authorities": [ "denied intervention where movants lacked legal title", "does not correspond to any publicly-retrievable decision", "Estate of Khallid Muhammad et al v. Tupac Shakur Estate et al Having reviewed Plaintiffs’ response" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-26", "decision_id": "cacd-2026-estate-of-khallid-muhammad-v-tupac-shakur-estate", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "Case 2:25-cv-02540-JLS-JPR", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's response contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1596/Khallid_v._Tupac_Estate_USA_26_February_2026.pdf", "state": "CA", "summary": "Central District of California on 2026-02-26 in Estate of Khallid Muhammad et al v. Tupac Shakur Estate et al found counsel's response contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "text_sha256": "5f69d283248b3462f3469d311b91ab5e6c9cdd109112e77df47f5685fd9096a1", "topics": [ "fabricated-citations" ], "tracker_slug": "estate-of-khallid-muhammad-et-al-v-tupac-shakur-estate-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-estate-of-khallid-muhammad-v-tupac-shakur-estate", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-estate-of-khallid-muhammad-v-tupac-shakur-estate" }, { "ai_passage": "for at least two cases cited in Plaintiff’s opposition—Anderson v. Dean Witter Reynolds, 24 Inc., 306 F.3d 726 (9th Cir. 2002), and Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014)—the citation provided does not return the case identified. Furthermore, Plaintiff’s 25 opposition misattributes apparently fake quotations to real cases. (See, e.g., Doc. 21 at 12, citing Matterhorn, Inc. v. NCR Corp., 763 F.2d 866, 868 (7th Cir. 1985)). “It appears the 26 incorrect citations may be the result of [Plaintiff] using artificial intelligence to draft [her] filings.” Ghadimi, 2025 WL 2928933 at *4. “But whether [Plaintiff] used artificial 27 intelligence or simply imagined the cases [her]self, filing documents that contain such cases results in confusion and unnecessary work for opposing parties and the court. In the 28 future, filing documents with fictitious cases will subject [Plaintiff] to sanctions under Rule 11.” Id. - 11 - Case 2:25-cv-01552-DWL Document 24 Filed 02/26/26 Page 12 of 28", "ai_tool_named": null, "archive_url": null, "case_name": "Perry v. Exeter Finance LLC", "citation": null, "cited_authorities": [ "Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014)", "Matterhorn, Inc. v. NCR Corp., 763 F.2d 866, 868 (7th Cir. 1985)", "Anderson v. Dean Witter Reynolds, Inc., 306 F.3d 726 (9th Cir. 2002)", "Inc. v. NCR Corp", "Anderson v. Dean Witter Reynolds", "Chavez v. Bank of Am., 2014 WL 2159382", "Rule 11" ], "court": "United States District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-26", "decision_id": "azd-2026-perry-v-exeter-finance", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 2:25-cv-01552-DWL", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's filing contained three citation defects, including Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014), Matterhorn, Inc. v. NCR Corp., 763 F.2d 866, 868 (7th Cir. 1985) and Anderson v. Dean Witter Reynolds, Inc., 306 F.3d 726 (9th Cir. 2002), involving...", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1580/Perry_v._Exeter_Finance_USA_26_February_2026.pdf", "state": "AZ", "summary": "District of Arizona on 2026-02-26 found the self-represented party's filing contained three citation defects, including Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014), Matterhorn, Inc. v. NCR Corp., 763 F.2d.... The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "fec6801fe6e546276235b5b350df3f6630128d59f94b7777e0650773d9c133fe", "topics": [ "fabricated-citations" ], "tracker_slug": "perry-v-exeter-finance-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azd-2026-perry-v-exeter-finance", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-perry-v-exeter-finance" }, { "ai_passage": "defective. On January 16, 2025, Moses filed a motion seeking argues that Moses failed to properly cite the record or to additional time to file an amended complaint in the event legal authority as required by Tennessee Rule of Appellate the Claims Commission found she needed leave to do so. Procedure 27(a)(7). Moses’ brief contains several errors in Moses asked the Claims Commission to deem her amended legal citation and at least one fictitious case. In addition, complaint as having been properly filed on November 25, Moses fails to cite to the appellate record. We disregard 2024, or at least by January 16, 2025, when she filed her any legal authorities cited by Moses that we cannot verify motion to amend. Additional procedural history unfolded, and as authentic. However, in view of Moses’ pro se status, neither party requested oral argument. the straightforwardness of the issues on appeal, the relative brevity of the record, and our general preference to resolve In February 2025, the Commissioner entered his final cases on their merits, we decline to dismiss Moses’ appeal for order in which he granted the State's motion to dismiss and noncompliance with the rules of briefing.", "ai_tool_named": null, "archive_url": null, "case_name": "Moses v. State", "citation": "2026 WL 518478", "cited_authorities": [], "court": "Court of Criminal Appeals of Tennessee", "court_code": "tenncrimapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-25", "decision_id": "tenncrimapp-2026-moses-v-state", "disposition": "The court dismissed claims or denied relief after identifying the defective authorities.", "docket_number": "No. W2025-00386-COA-R3-CV", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellate brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1625/Moses_V_State_USA_25_February_2026.pdf", "state": "TN", "summary": "Court of Criminal Appeals of Tennessee on 2026-02-25 in Moses v. State found the self-represented party's appellate brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court dismissed claims or denied relief after identifying the defective authorities.", "text_sha256": "dcd9f6e1ceb01dc9eb51cc9f035d13f2e05f40090006d5f68abdf7bee008269f", "topics": [ "fabricated-citations" ], "tracker_slug": "moses-v-state", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/tenncrimapp-2026-moses-v-state", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tenncrimapp-2026-moses-v-state" }, { "ai_passage": "before the successor judge with accurate citations. The imposition of sanctions for misuse of generative Al is relatively new; for instance, Mata v. Avianca, Inc., one of the first significant federal cases on the topic, was not published until June 22, 2023. 678 F. Supp. 3d 443 (S. D. N. Y. 2023). reflects the proliferation of generative Al, its infiltration into legal writing, and its repeated misuse by attorneys. The Mata court aptly explains the harm perpetrated by Scott and Hewitt, and why sanctions are appropriate: Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 8 of 14 PAGEID #: 2096 Many harms flow from the submission of fake opinions. The opposing party wastes time and money in exposing the deception. The Court's time is taken from other important endeavors. The client may be deprived of arguments based on authentic judicial precedents. There is potential harm to the reputation of judges and courts whose names are falsely invoked as authors of the bogus opinions and to the reputation of a party attributed with fictional conduct. It promotes cynicism about the legal profession and the American judicial system. And a future litigant may be tempted to defy a judicial ruling by disingenuously claiming doubt about its authenticity. 678 F. Supp. 3d at 448-49 (footnote omitted). The court in Wac/swoth v. Walmart, in imposing monetary sanctions against the attorneys who submitted Al-hallucinated caselaw, noted that, by February 24, 2025, the date of publication, \"[i]t is .. . well-known in the legal community that Al resources generate fake cases. \" 348 F. R. D. 489, 497 (D. Wyo. 2025). As evidenced by Wadsworth being cited in 61 cases since publication, by the time Collier and Scott filed the Motion to Dismiss in August 2025, every licensed attorney knew or should have reasonably known that relying on generative Al for research would likely result in a filing containing Al hallucinations. The volume of subsequent cases citing Mata and Wadsworth reinforce this Court's conclusion: that the problem of attorneys submitting hallucinated citations is rapidly worsening, and is one of the biggest threats currently facing federal civil litigation. Importantly, the January 2, 2026, Decision made clear that the Court's expectation of accurate citations has no exception for generative Al. Courts have imposed monetary sanctions for attorneys filing Al- hallucinated citations ranging between $1, 000 and $5, 000. Wadsworth, 348 F. R. D. 8 Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 9 of 14 PAGEID #: 2097 at 497 (collecting cases), 498. In imposing $3, 000 and $1, 000 fines on the drafting", "ai_tool_named": null, "archive_url": null, "case_name": "Kettering Adventist Healthcare v. Sandra Collier, et al.", "citation": null, "cited_authorities": [ "State v. Carter, 72 Ohio App. 3d 553 (2d Dist. 1991)", "s review found no such opinion supporting that proposition (case appears non-existent/mislinked). || Fabricated: Case Law | Counsel relied on", "in briefing; the Court", "Dart Indus. Co. v. Hurd, 66 Ohio St. 2d 280 (1981)", "State ex rel. Ellis v. Cleveland Mun. Sch. Dist., 2015-Ohio-760", "State v. Milam, 2022-Ohio-3965 (10th Dist.)", "Counsel cited United States v. Pendergraft", "Counsel cited 'State v. Carter", "Counsel cited 'Dart Indus. Co. v. Hurd", "Counsel cited Kenty v. Transamerica Premium Ins. Co", "Inc. v. Impact Office Prods", "Counsel cited 'State ex rel. Ellis v. Cleveland Mun. Sch. Dist" ], "court": "United States District Court for the Southern District of Ohio", "court_code": "ohsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-25", "decision_id": "ohsd-2026-kettering-adventist-healthcare-v-sandra-collier", "disposition": "The court found contempt, struck the defective filing, and ordered counsel to pay $7,500.", "docket_number": "No. 3:25-cv-273", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained nine citation defects, including In re Protech, 51 F.4th 714 (6th Cir. 2022), United States v. Pendergraft and Inc. v. Impact Office Prods, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": "USD", "monetary_penalty": 7500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1574/Kettering_USA_25_February_2026.pdf", "state": "OH", "summary": "Southern District of Ohio on 2026-02-25 found counsel's brief contained nine citation defects, including In re Protech, 51 F.4th 714 (6th Cir. 2022), United States v. Pendergraft and Inc. v. Impact Office Prods, involving nonexistent authorities, fabricated or misattributed quotations. The court found contempt, struck the defective filing, and ordered counsel to pay $7,500.", "text_sha256": "3a3a4786b406a42c39cd90b15f451fb2ca33152b4b71d7fc8978991773837c31", "topics": [ "fabricated-citations" ], "tracker_slug": "kettering-adventist-healthcare-v-sandra-collier-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohsd-2026-kettering-adventist-healthcare-v-sandra-collier", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohsd-2026-kettering-adventist-healthcare-v-sandra-collier" }, { "ai_passage": "2 Although Plaintiff's argument section is titled “Plaintiff's contract claims are properly pled,” Plaintiff only addresses his claim of breach of the implied duty of good faith. (Doc. 20 at 3.) 3 Plaintiff also cites to a non-existent case in support of his arguments on the FCRA claim. (Doc. 20 at 1) (citing to Howard v. CitiMortgage, Inc., 2019 WL 1401348 (D. Kan. Mar. 28, 2019)). There is no case with such a Since the filing of Plaintiff's brief, this court has entered a standing order on the use of Artificial Intelligence (“AI”) in court filings. Standing Order 26-01 (In Re: Use of Artificial Intelligence In Preparing Court Filings). This order requires a litigant to review and verify the accuracy of all content filed with the court that was drafted or assisted using an AI tool. Should Plaintiff violate this standing order in subsequent filings, he can be subject to sanctions as set forth in the standing order.", "ai_tool_named": null, "archive_url": null, "case_name": "Roosevelt Hunt, Jr. v. True Sky Federal Credit Union", "citation": "2026 WL 516955", "cited_authorities": [ "Howard v. CitiMortgage, Inc., 2019 WL 1401348 (D. Kan. Mar. 28, 2019)", "Howard v. CitiMortgage" ], "court": "United States District Court for the District of Kansas", "court_code": "ksd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-25", "decision_id": "ksd-2026-roosevelt-hunt-jr-v-true-sky-federal-credit", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 25-1209-JWB", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained one citation defect, including Howard v. CitiMortgage, Inc., 2019 WL 1401348 (D. Kan. Mar. 28, 2019) and Howard v. CitiMortgage, involving nonexistent authorities.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1583/Hunt_v._True_Sky_USA_25_February_2026.pdf", "state": "KS", "summary": "District of Kansas on 2026-02-25 in Roosevelt Hunt, Jr. v. True Sky Federal Credit Union found the self-represented party's brief contained one citation defect, including Howard v. CitiMortgage, Inc., 2019 WL 1401348 (D. Kan. Mar. 28, 2019) and Howard v. CitiMortgage, involving nonexistent authorities. The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "9b7b6628ad415654a3d363bfffd4ff4e9d84571bcc38b7aee604f5a65b8b1523", "topics": [ "fabricated-citations" ], "tracker_slug": "roosevelt-hunt-jr-v-true-sky-federal-credit-union", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ksd-2026-roosevelt-hunt-jr-v-true-sky-federal-credit", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ksd-2026-roosevelt-hunt-jr-v-true-sky-federal-credit" }, { "ai_passage": "NOTICE: THIS OPINION HAS NOT BEEN RELEASED *1 Affirmed. See Clerk of Ct. & Comptroller for 13th Jud. FOR PUBLICATION IN THE PERMANENT Cir., Hillsborough Cnty. v. Rangel, No. 2D2024-1772, 2025 LAW REPORTS. UNTIL RELEASED, IT IS WL 2486314, at *2 (Fla. 2d DCA Aug. 29, 2025) (“[T]he SUBJECT TO REVISION OR WITHDRAWAL. dangers of relying on generative artificial intelligence have been discussed in the media, in legal publications, and in District Court of Appeal of Florida, Second District. court opinions.”); Takefman v. Pickleball Club, LLC, 418 So. 3d 826, 827 (Fla. 3d DCA 2025) (“We write, however, to CHRISTOPHER STRAUB, Appellant, address an issue of growing concern—the proliferation of v. fake or hallucinated case citations in court filings.... Opposing MELISSA HENDERSON, as Successor counsel, and the court, should not have to parse case citations Trustee of the Margaret McShane Revocable and parentheticals to discern whether cases exist, and if so, Trust Dated March 24, 2016, Appellee. if they stand for the propositions asserted.”), reh'g denied (Sept. 11, 2025); Goya v. Hayashida, 418 So. 3d 652, 655 No. 2D2025-1787 (Fla. 4th DCA 2025) (“An attempt to persuade a court or | oppose an adversary by relying on fake opinions is an abuse February 25, 2026 of the adversary system.” (quoting Park v. Kim, 91 F.4th 610, Appeal from the Circuit Court for Hillsborough County; 615 (2d Cir. 2024))); see also Gutierrez v. Gutierrez, 399 So. Emily A. Peacock, Judge. 3d 1185, 1187-88 (Fla. 3d DCA 2024) (dismissing pro se appellant's appeal and imposing sanctions for filing briefs that Attorneys and Law Firms contained “fictitious and nonexistent case law”). Christopher Straub, pro se. Marc C. Mann of Berlin Patten Ebling PLLC, Tampa, for LUCAS, C.J., and NORTHCUTT and ATKINSON, JJ., Appellee. Concur. --- So.3d ----, 2026 WL 516317 (Mem)", "ai_tool_named": null, "archive_url": null, "case_name": "Straub v. Henderson", "citation": "2026 WL 516317", "cited_authorities": [ "Hillsborough Cnty. v. Rangel, No. 2D2024-1772, 2025", "Takefman v. Pickleball Club", "Goya v. Hayashida", "Park v. Kim", "Gutierrez v. Gutierrez" ], "court": "District Court of Appeal of Florida", "court_code": "fladistctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-25", "decision_id": "fladistctapp-2026-straub-v-henderson", "disposition": "The court affirmed the judgment while identifying the defective authorities in the appellate briefing.", "docket_number": "No. 2D2024-1772, 2025", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellee brief contained one citation defect involving nonexistent authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1588/Straub_v._Henderson_USA_25_February_2026.pdf", "state": "FL", "summary": "Florida District Court of Appeal on 2026-02-25 in Straub v. Henderson found the self-represented party's appellee brief contained one citation defect involving nonexistent authorities. The court affirmed the judgment while identifying the defective authorities in the appellate briefing in the challenged filing before resolving the pending matter.", "text_sha256": "615b005f0e7e51b8419e2d45e0233ba596e72c12ea68c79add53259ab7396da6", "topics": [ "fabricated-citations" ], "tracker_slug": "straub-v-henderson", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/fladistctapp-2026-straub-v-henderson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/fladistctapp-2026-straub-v-henderson" }, { "ai_passage": "appeal or forever lose the opportunity to obtain appellate v. Alvarez (2025) 114 Cal.App.5th 1115, 1119.) Appellant review’ ”]; People v. Ramirez (2008) 159 Cal.App.4th 1412, is warned that by using fabricated legal authorities in legal 1420-1421 [“ ‘A timely notice of appeal, as a general matter, filings, his filings may be stricken (Cal. Rules of Court, is “essential to appellate jurisdiction” ’ ”].) The scope of our rule 8.204(e)(2)(B)), and he could be subject to sanctions. review is therefore limited to whether the trial court properly (Noland, at p. 445 [“relying on fabricated legal authority is denied appellant's petition for writ of mandate to review its sanctionable”].) prior order in appellant's government tort claim case. For the reasons stated above, we conclude it did. We finally address appellant's citations to several nonexistent DISPOSITION sources. For example, appellant argues, “[T]he trial court's refusal to consider attachments to a late claim petition The judgment is affirmed. Real party in interest shall recover [is] a violation of due process rights and an abuse of its costs on appeal. (Cal. Rules of Court, rule 8.278(a)(1)-(2).) discretion, as provided under Government Code section 911.5[, subdivision ](b) and contrary to the holding in County of Sacramento v. Superior Court (2014) 232 Cal.App.4th We concur: 305.” (Boldface omitted, italics added.) Neither of these legal authorities exist. Real party in interest identifies appellant's EARL, P. J. fabricated legal authorities but appellant persists, stating in his reply, “The authorities cited by [a]ppellant in the [o]pening MESIWALA, J. [b]rief are accurate, controlling, and properly cited, and each supports the legal propositions advanced.” (Boldface authorities cited in appellant's briefs are either nonexistent or wholly inaccurate for the propositions asserted. 1 We deny appellant's request for judicial notice because he failed to attach the documents in his request.", "ai_tool_named": null, "archive_url": null, "case_name": "Anthony Jama Hall v. Superior Court of Sacramento County", "citation": "2026 WL 521913", "cited_authorities": [ "County of Sacramento v. Superior Court (2014) 232 Cal.App.4th 305", "s proposition. || Fabricated: Legal Norm | Appellant cited", "People v. Ramirez", "County of Sacramento v. Superior Court" ], "court": "California Court of Appeal", "court_code": "calctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-25", "decision_id": "calctapp-2026-anthony-jama-hall-v-superior-court-of-sacramento-county", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 34-2023-80004085-CU-WM-GDS)", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellate brief contained three citation defects, including Sacramento v. Superior Court, involving nonexistent authorities, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1585/Jama_Hall_v._Superior_Court_USA_February_2026.pdf", "state": "CA", "summary": "California Court of Appeal on 2026-02-25 in Anthony Jama Hall v. Superior Court of Sacramento County found the self-represented party's appellate brief contained three citation defects, including Sacramento v. Superior Court, involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "029ca10dfae143d29eab990e4562d30399f50a392b53a828daeb499783937807", "topics": [ "fabricated-citations" ], "tracker_slug": "anthony-jama-hall-v-superior-court-of-sacramento-county", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp-2026-anthony-jama-hall-v-superior-court-of-sacramento-county", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp-2026-anthony-jama-hall-v-superior-court-of-sacramento-county" }, { "ai_passage": "required before a creditor can enforce a debt. That may be true, but this is not an 4 Nelnet points out in its response to this motion that none of Ms. Dunn’s cited case law actually exists, and Nelnet believes the citations to be AI hallucinations. (Doc. 60, ¶ 15). Ms. Dunn admits in her reply that the citations were incorrect and claims to have corrected them (Doc. 61, ¶ 7), but she did not file an amended or corrected motion. 9 Case 5:25-cv-05107-TLB Document 66 Filed 02/25/26 Page 10 of 10 PageID #: 407 enforcement action by Nelnet against Ms. Dunn—it is Ms. Dunn’s action against Nelnet. Nelnet was directed to provide “the document(s) authorizing it to service Ms. Dunn’s loan,”", "ai_tool_named": null, "archive_url": null, "case_name": "Christina Leas Dunn v. Nelnet", "citation": null, "cited_authorities": [], "court": "United States District Court for the Western District of Arkansas", "court_code": "arwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-25", "decision_id": "arwd-2026-christina-leas-dunn-v-nelnet", "disposition": "The court granted Nelnet's motion to dismiss, denied the plaintiff's motions, and dismissed the case without prejudice.", "docket_number": "Case 5:25-cv-05107-TLB", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motions cited several cases that Nelnet said did not exist; the party admitted the citations were incorrect and filed no correction.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1579/Dunn_v._Nelnet_USA_26_February_2026.pdf", "state": "AR", "summary": "Western District of Arkansas on 2026-02-25 in Christina Leas Dunn v. Nelnet found the self-represented party's motions cited several cases that Nelnet said did not exist; the party admitted the citations were incorrect and filed no correction. The court granted Nelnet's motion to dismiss, denied the plaintiff's motions, and dismissed the case without prejudice.", "text_sha256": "a7bf03e068e35614ab1ebab935dc3077ec469f858cf80edb72ef2f3d127329f0", "topics": [ "fabricated-citations" ], "tracker_slug": "christina-leas-dunn-v-nelnet", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/arwd-2026-christina-leas-dunn-v-nelnet", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arwd-2026-christina-leas-dunn-v-nelnet" }, { "ai_passage": "on appeal. See Alma S., 245 Ariz. at 151, ¶ 18. Reasonable relying on inappropriate legal authorities). We will forward evidence supports the court's best interests findings. this decision to the State Bar of Arizona to determine whether Mother's counsel violated any rules of professional conduct. IV. Mother's Answering Brief ¶26 Mother's answering brief contains what appear to be CONCLUSION hallucinated quotations from statutes and cases. ¶31 We affirm. ¶27 Mother claims that Section 8-531(1) states that “[a]bandonment is measured by a parent's conduct, not 8-533(B)(1) provides that abandonment is established when the parent has failed to maintain a normal parental relationship", "ai_tool_named": null, "archive_url": null, "case_name": "In re termination of parental rights (HK)", "citation": "2026 WL 517864", "cited_authorities": [ "a parent", "The court concluded these quotes are not in that opinion. || Fabricated: Legal Norm | Mother", "[a]bandonment is measured by a parent", "s subjective intent", "s brief attributed language to A.R.S. § 8-533(B)(1) stating abandonment is established when a parent has failed to maintain a normal parental relationship", "The court found the statute does not contain the quoted phrasing. || False Quotes: Case Law | Mother", "t of Econ. Sec., 224 Ariz. 373, 378, ¶ 21 (App. 2010)", "Mother's brief attributed a non-existent quote to Raymond F. v. Dep't of Econ. Sec" ], "court": "Court of Appeals of Arizona", "court_code": "arizctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-25", "decision_id": "arizctapp-2026-in-re-termination-of-parental-rights", "disposition": "The court referred counsel to disciplinary authorities for the defective citations.", "docket_number": "No. 1 CA-JV 25-0131", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained four citation defects, including Raymond F. v. Dep't, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1584/In_re_termination_of_parental_rights_USA_25_February_2026.pdf", "state": "AZ", "summary": "Arizona Court of Appeals on 2026-02-25 in In re termination of parental rights (HK) found counsel's brief contained four citation defects, including Raymond F. v. Dep't, involving nonexistent authorities, fabricated or misattributed quotations. The court referred counsel to disciplinary authorities for the defective citations.", "text_sha256": "f2092641d4a0f71448e0cfd0209cca071d44180e210d50e7e560037c2d236ec5", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-termination-of-parental-rights-hk", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/arizctapp-2026-in-re-termination-of-parental-rights", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/arizctapp-2026-in-re-termination-of-parental-rights" }, { "ai_passage": "Fung fails to allege sufficient facts to pass even the first element of this test—her complaint merely alleges “Liberty failed to adhere to its established graduation policies,” without establishing what those policies are or what “false representations” Liberty made regarding her graduation. Dkt. 38 at 1. And further, Fung’s complaint is silent as to the “false representations” Liberty made about the degrees that dissertation chairs must have in order to work in their positions. 3 The Court finds that Fung’s cited case, Friedman v. Southern New Hampshire University, 104 A.D. 3d 617 (N.Y. App. Div. 2013) does not exist, nor does it provide support for the assertion that students may bring claims of education fraud against their schools and universities. The Court addresses Liberty’s request for sanctions related to Fung’s inclusion of this case in the conclusion of this memorandum opinion. 4 She relies on Hoffman v. Board of Education in making this argument—a case which, even construed liberally—does not address “the impact of educational institutions’ actions on students’ career prospects.” Dkt. 38 at 2; 400 N.E.2d 121 (N.Y. Ct. App. 1979). Hoffman concerned a student’s placement in special education for intellectually disabled children, where he remained improperly for “over ten years.” Id. at 123-24. The Court denied his parents the right to challenge his placement. Id. at 127. 5 Case 6:25-cv-00058-NKM-CKM Document 48 Filed 02/24/26 Page 6 of 11 Pageid#: 132", "ai_tool_named": null, "archive_url": null, "case_name": "Gail Fung v. Liberty University", "citation": null, "cited_authorities": [ "Friedman v. Southern New Hampshire University, 104 A.D. 3d 617 (N.Y. App. Div. 2013)", "Friedman v. Southern New Hampshire University", "Rule 11" ], "court": "United States District Court for the Western District of Virginia", "court_code": "vawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-24", "decision_id": "vawd-2026-gail-fung-v-liberty-university", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 6:25-cv-00058-NKM-CKM", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's complaint contained one citation defect involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1595/Fung_v._Liberty_Univiersity_USA_24_February_2026.pdf", "state": "VA", "summary": "Western District of Virginia on 2026-02-24 in Gail Fung v. Liberty University found the self-represented party's complaint contained one citation defect involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "c903fbf8e9d7458ea730284610bf76a51a3b405f2d19ca87ddd3edb5b15adecc", "topics": [ "fabricated-citations" ], "tracker_slug": "gail-fung-v-liberty-university", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/vawd-2026-gail-fung-v-liberty-university", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/vawd-2026-gail-fung-v-liberty-university" }, { "ai_passage": "Co., 15 does not support Plaintiff's position. The court agrees Amended Complaint should be dismissed as to ABC Legal. that Plaintiff's authority is misplaced. However, the court has wide discretion in considering a Rule 12(b)(5) motion. This In closing, the court notes its concern with the use of artificial includes dismissing a case if it appears unlikely that proper intelligence (AI) in this case. ABC Legal avers that Plaintiff's service can be instituted. Or quashing service and giving use of AI in this case undermines the discretion given to a plaintiff an opportunity to re-serve the defendant. 16 The Mr. Lee as a pro se party and raises serious concerns due court finds Plaintiff reserved ABC Legal and therefore the to the misstatements of the law and holdings in Plaintiff's court will deny the 12(b)(5) motion and move to address ABC cited authority. Based on these problems, ABC Legal asks the Legal's contention for dismissal under Rule 12(b)(6). 17 court to “disregard any AI-generated portions of Plaintiff's opposition to the extent they are inaccurate or hallucinated” ABC Legal argues Plaintiff's tortious interference claim and to the extent Mr. Lee “relies primarily on such content fails because no contractual relationship was disrupted. without providing specific factual support for its claims.” 24 The court agrees. “A party is subject to liability for an intentional interference with present contractual relations if Judges have increasingly sanctioned attorneys and parties for he intentionally and improperly causes one of the parties not using generative AI tools, such as ChatGPT, to draft legal to perform the contract.” 18 Liability for future contractional documents that contain fabricated cases, fake citations, or relations is similar, a party causes another party to not perform “hallucinated” legal arguments. For example, in Lexos Media a future contract. Plaintiff's allegations are general in nature IP, LLC v. Overstock.com, Inc., 25 a Judge in this Circuit fined multiple attorneys for submitting documents in the case that contained defective legal citations created using generative AI. 26 Another court in this Circuit noted that RECOMMENDATION 27 Rule 11 and possible sanctions apply to the use of AI. For the reasons set forth above, the undersigned Pro se parties are not immune and have also been sanctioned RECOMMENDS that Defendant's Motion to Dismiss under for false citations in filings. 28 The court declines ABC Rule 12(b)(6) be GRANTED and that this action be Legal's invitation regarding Plaintiff's AI generated materials. DISMISSED. 30 However, the admonition of the Seventh Circuit is appropriate here for Mr. Lee: As pro se litigants employ AI to assist with court NOTICE TO PARTIES filings, a basic reminder seems wise. Accuracy and honesty matter. Indeed, the submission of a legal filing constitutes Copies of this Report and Recommendation are being sent a representation to a court and, as the Federal Rules to all parties, who are hereby notified of their right to of Civil Procedure put the point, both attorneys and object. 31 The parties must file any objection to this Report unrepresented parties are certifying “that to the best of and Recommendation within fourteen (14) days of service. the person's knowledge, information and belief, formed “[A] party's objections to the magistrate judge's report and after an inquiry reasonable under the circumstances,” recommendation must be both timely and specific to preserve the “factual contentions have evidentiary support” and an issue for de novo review by the district court of for the “legal contentions are warranted by existing law or appellate review.” 32 Failure to object may constitution", "ai_tool_named": null, "archive_url": null, "case_name": "Ryan Lee v. Capital One Bank et al.", "citation": "2026 WL 690784", "cited_authorities": [ "LLC v. Overstock.com", "Rule 11" ], "court": "United States District Court for the District of Utah", "court_code": "utd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-24", "decision_id": "utd-2026-ryan-lee-v-capital-one-bank", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 2:25-cv-540 TC DBP", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained one citation defect involving mischaracterized authority, incorrect statutory or rule text, defective exhibits or submissions.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1656/Ryan_Lee_Plaintiff_v_Capital_One_Bank_USA_USA_24_February_2026.pdf", "state": "UT", "summary": "District of Utah on 2026-02-24 in Ryan Lee v. Capital One Bank et al. found the self-represented party's motion contained one citation defect 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.", "text_sha256": "f2dbb106991195cb1ced3b74795f50d493d4ca7a66e12397d7108d55925e6092", "topics": [ "fabricated-citations" ], "tracker_slug": "ryan-lee-v-capital-one-bank-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/utd-2026-ryan-lee-v-capital-one-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/utd-2026-ryan-lee-v-capital-one-bank" }, { "ai_passage": "(W.D. Tex. Oct. 19, 2009). 618, 621 (5th Cir. 1985). The decision to grant or deny an injunction lies within the court's discretion. Id. II. Dean's Reliance on Nonexistent Citations Dean cites several cases, or purported cases, in her DISCUSSION motion and reply. Two of them—American Residential Services of Texas, LP v. Jimenez, 446 S.W.3d 649, 652–53 I. Lack of Entitlement to an Injunction (Tex. App.—Houston [1st Dist.] 2014), and Holub v. FDIC, Dean does not specify whether she is seeking a preliminary 159 B.R. 782, 789 (S.D. Tex. 1993)—do not exist. Others do injunction or a TRO. But she has not shown an entitlement not stand for the cited proposition. City of Austin v. Houston to either. Lighting & Power Co., 844 S.W.2d 773 (Tex. App.—Dallas 1992, writ denied), was decided by a different court than she Dean argues that she has established an imminent risk of says it was. And she failed to note that Glade v. Dietert, 286 irreparable harm because there is an ongoing risk that the S.W.2d 955 (Tex. App.—Fort Worth 1956), was reversed by bank, through its agents, will lock her out of the property the Supreme Court of Texas, Glade v. Dietert, 295 S.W.2d 642 again and that another violent incident will occur. Dkt. 23 (Tex. 1956). at 3. In some cases, repeated trespasses to land will warrant injunctive relief if they are “continuous such that stopping The court suspects that those errors stem from the use [them] would require a multiplicity of suits.” Texas v. DHS, of generative artificial intelligence. See Margie Alsbrook, 123 F.4th 186, 212 (5th Cir. 2024). But a trespass to land is Untangling Unreliable Citations, 37 Geo. J. L. Ethics 415, ordinarily compensable by damages. Stevenson v. E.I. DuPont 446–47 (2024). That has become a regrettably common De Nemours & Co., 327 F.3d 400, 408 (5th Cir. 2003). That problem, wasting party and court resources alike. E.g., Wilt v. Whitehouse Police Dep't, No. 6:25-cv-00117-JCB-JDL, 2025", "ai_tool_named": null, "archive_url": null, "case_name": "Wells Fargo Bank v. Frances W. Dean", "citation": "2026 WL 555590", "cited_authorities": [ "LP v. Jimenez", "Holub v. FDIC", "Others do injunction or a TRO. But she has not shown an entitlement not stand for the cited proposition. City of Austin v. Houston to either. Lighting & Power Co", "Dean argues that she has established an imminent risk of says it was. And she failed to note that Glade v. Dietert", "Glade v. Dietert", "Texas v. DHS", "Stevenson v. E.I. DuPont 446", "Wilt v. Whitehouse Police Dep't, No. 6:25-cv-00117-JCB-JDL, 2025", "B.R. 782" ], "court": "United States District Court for the Eastern District of Texas", "court_code": "txed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-24", "decision_id": "txed-2026-wells-fargo-bank-v-frances-w-dean", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "NO. 4:25-CV-00263-ALM-BD", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained four citation defects involving nonexistent authorities, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1591/Wells_Fargo_v._Dean_USA_24_February_2026.pdf", "state": "TX", "summary": "Eastern District of Texas on 2026-02-24 in Wells Fargo Bank v. Frances W. Dean found the self-represented party's motion contained four citation defects involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "b08253f0f0c0b6ffc5730be064efc09e36da95ef144ec4a3adda1de9657f8227", "topics": [ "fabricated-citations" ], "tracker_slug": "wells-fargo-bank-v-frances-w-dean", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txed-2026-wells-fargo-bank-v-frances-w-dean", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txed-2026-wells-fargo-bank-v-frances-w-dean" }, { "ai_passage": "579 U.S. 40, 47 (2016) (recognizing a district court’s inherent power to manage its docket); Moore v. City of Del City, No. 25-6002, 2025 WL 3471341, at *3 (10th Cir. Dec. 3, 2025) (recognizing the same in the context of an attorney who submitted briefs that contained hallucinated or fake case citations as a result of using generative AI technology). The Court’s inherent authority is not without limits, and the exercise of these powers “must be a ‘reasonable response to the problems and needs’ confronting the court’s fair administration of justice,” and such exercise “cannot be contrary to any express grant of or limitation on the district court's power contained in a rule or statute.” Dietz, 579 U.S. at 45. Just as Judge Huntsman did, federal courts 5", "ai_tool_named": null, "archive_url": null, "case_name": "Chapter Kris Jackson v. BOK Financial Corporation et al. (3)", "citation": null, "cited_authorities": [ "Badillo v. Thorpe, 158 F. Supp. 2d 177 (D. Conn. 2001)", "Inc. v. Carmen Feliciando de Melecio", "Badillo v. Thorpe decision is at 158 F. App'x 208", "Moore v. City of Del City, No. 25-6002, 2025 WL 3471341" ], "court": "United States District Court for the Northern District of Oklahoma", "court_code": "oknd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-24", "decision_id": "oknd-2026-chapter-kris-jackson-v-bok-financial", "disposition": "The court ordered the self-represented party to pay $405 for the defective authorities.", "docket_number": "Case 4:25-cv-00297-SEH-SH", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained three citation defects, including Inc. v. Carmen Feliciando and Badillo v. Thorpe, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": "USD", "monetary_penalty": 405, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1566/Jackson_v._BOK_USA_24_February_2026.pdf", "state": "OK", "summary": "Northern District of Oklahoma on 2026-02-24 in Chapter Kris Jackson v. BOK Financial Corporation et al. (3) found the self-represented party's brief contained three citation defects, including Inc. v. Carmen Feliciando and Badillo v. Thorpe, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered the self-represented party to pay $405 for the defective authorities.", "text_sha256": "c6991fdd165514bc36d8166cecae719a0ba2ed6121a45c121c5d904a0d277b07", "topics": [ "fabricated-citations" ], "tracker_slug": "chapter-kris-jackson-v-bok-financial-corporation-et-al-3", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/oknd-2026-chapter-kris-jackson-v-bok-financial", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/oknd-2026-chapter-kris-jackson-v-bok-financial" }, { "ai_passage": "Court.1 10. Lindner v. Countrywide Hom Loans, Inc., 447 F. Supp. 2d 999 (D. Minn. 2006) AI can be a powerful tool for pro se plaintiffs. However, the (Doc. No. 7). In her reply, Plaintiff cites two more fake cases Court cannot blindly ignore its risks, including the increased (Eaton v. Am. Bankers Life Assurance Co., 2020 U.S. Dist. LEXIS 150102 (W.D.N.C.), and Cox v. Chase Bank, N.A., likelihood of factual and legal hallucinations.2 2015 WL 13654749) and cites a real case for a proposition that the case does not support (Marash v. Morrill, 496 F.2d IT IS, THEREFORE, ORDERED that Plaintiff must show 1138 (2d Cir. 1974)). (Doc. Nos. 7, 9). cause as to why her complaint should not be dismissed with prejudice for failing to comply with this Court's Standing Plaintiff's AI generated pleading violates this Court's standing Order Regarding Use of Artificial Intelligence. Within 21 order and attempts to mislead the Court. The Court days of this Court's Order, Plaintiff shall (1) file a brief with understands that Plaintiff is proceeding pro se, but that does the Court explaining her fraudulent case citations, (2) file a not allow her to flaunt the Court's rules and haphazardly motion to amend her non-compliant pleadings, and (3) certify file pleadings without completing any due diligence. Even to the Court—in each motion or brief filed—that she has and a cursory Google search would reveal that these cases do will comply with this Court's Standing Order Regarding Use not exist. Furthermore, AI's limitations at this point are well- of Artificial Intelligence. Failure to do so will result in the documented, and its proclivity for hallucinating case citations dismissal of Plaintiff's complaint with prejudice. is broadly known. A pro se litigant doing the minimum due diligence would discover that fact. *3 Signed: February 24, 2026 The Court has been extremely lenient on pro se plaintiffs filing AI-generated pleadings in this Court and has generally 1 The Court notes that this is not Plaintiff's first warning with respect to these issues. See 3:25-cv-832, Doc. No. 10. Further, at least one other case reflects similar problems. See 3:25-cv-1008, Doc. No. 5. Plaintiff is forewarned that if she continues to file documents without the required AI certification or with AI hallucinations, then the Court may, without further warning, order that documents lacking in AI certification be returned to her without filing. Also, documents containing AI hallucinations (notwithstanding a certification) may be summarily stricken and not considered. 2 Pro se parties should also be aware that their “conversations” with AI tools such as ChatGPT are not privileged and may be subject to discovery. Government Works.", "ai_tool_named": null, "archive_url": null, "case_name": "Ebony Sherisse Lucas v. Charles W. Scharf, et al.", "citation": "2026 WL 642917", "cited_authorities": [ "s reply as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff", "s response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff", "Eaton v. Am. Bankers Life Assurance Co", "Cox v. Chase Bank", "Marash v. Morrill" ], "court": "United States District Court for the Western District of North Carolina", "court_code": "ncwd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-24", "decision_id": "ncwd-2026-ebony-sherisse-lucas-v-charles-w-scharf", "disposition": "The court ordered the self-represented party to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "CIVIL ACTION NO. 3:25-CV-01015-KDB-WCM", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained 13 citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1626/Lucas_v._Wells_Fargo_USA_25_February_2026.pdf", "state": "NC", "summary": "Western District of North Carolina on 2026-02-24 in Ebony Sherisse Lucas v. Charles W. Scharf, et al. found the self-represented party's brief contained 13 citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court ordered the self-represented party to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "text_sha256": "9bfedc27268ac62634bdfdd0fd6f2386d2d4bcdcca5bccfb7fc7d275af2b1eb1", "topics": [ "fabricated-citations" ], "tracker_slug": "ebony-sherisse-lucas-v-charles-w-scharf-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ncwd-2026-ebony-sherisse-lucas-v-charles-w-scharf", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ncwd-2026-ebony-sherisse-lucas-v-charles-w-scharf" }, { "ai_passage": "(3) Appellant’s vague, confusing, and unpersuasive responses to the Board’s orders raise questions as to the credibility and veracity of his responses. 2 In response to a Board order, appellant stated that he did not use artificial intelligence (AI) to draft his motion. A characteristic of using AI is its propensity to “hallucinate,” meaning to create information which appears credible and real but which is actually false, non-existent, or a mischaracterization of existing information. There is no prohibition against using AI at the Board. However, “[i]f using AI, parties retain full responsibility for the accuracy of all submissions to the Board.” Annual Report, United S t a t e s C i v ilian Board of Contract Appeals, Fiscal Y ea r 2 0 2 5, https://cbca.gov/files/2025-CBCA-Annual-Report.pdf (last visited February 23, 2026). CBCA 7992, 7993 5 Sanction Appellant’s actions as described herein constitute sanctionable misconduct pursuant to Board Rule 35. We issue this formal admonishment to appellant to alert appellant that, as the case proceeds, if he continues such conduct, additional and harsher sanctions will be imposed, which could include dismissal of the appeals without proceeding to the merits. Rule 35(b)(6).", "ai_tool_named": null, "archive_url": null, "case_name": "Louis J. Blazy v. Department of State", "citation": null, "cited_authorities": [], "court": "Civilian Board of Contract Appeals", "court_code": null, "court_level": "federal-specialty", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-24", "decision_id": "cbca-2026-louis-j-blazy-v-department-of-state", "disposition": "The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.", "docket_number": null, "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1573/Blazy_v._State.pdf", "state": null, "summary": "Civilian Board of Contract Appeals on 2026-02-24 in Louis J. Blazy v. Department of State found the self-represented party's motion contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.", "text_sha256": "60bc0891ee42d0460dbbba7fc7d4c0ef65c90e14151562436112706de33951ca", "topics": [ "fabricated-citations" ], "tracker_slug": "louis-j-blazy-v-department-of-state", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cbca-2026-louis-j-blazy-v-department-of-state", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cbca-2026-louis-j-blazy-v-department-of-state" }, { "ai_passage": "20 respond to the troubling assertion that defendant has produced improperly redacted records. 21 Defendant also cites cases purportedly from this district that do not exist, 1 even though defendant 22 was issued a prior warning in this case that doing so is a potential ground for sanctions. (See ECF 23 No. 29 at 5-6.) 24 The undersigned reserves ruling on the request for attorney fees for plaintiffs’ initial 25 motion to compel, subject to plaintiffs filing a properly noticed and supported motion for 26 1 These case citations provided by defendant, and possibly others, are inaccurate and/or the cases 27 do not exist: Brown v. Johnson, No. 1:06-cv-01068, 2009 WL 1788406 (E.D. Cal. June 23, 2009); Watkins v. Cal. Dep’t of Corr. & Rehab., No. 1:08-cv-01530, 2012 WL 1906523, at *1 28 (E.D. Cal. May 25, 2012). (See ECF No. 36 at 13.) 4 Case 2:24-cv-02305-DJC-CKD Document 39 Filed 02/24/26 Page 5 of 5 1 sanctions with evidence to substantiate the request. In addition, defendant and/or defendant’s", "ai_tool_named": null, "archive_url": null, "case_name": "Juan Villalovos-Gutierrez, et al. v. Gerard Van de Pol, et al. (2)", "citation": null, "cited_authorities": [ "Brown v. Johnson, No. 1:06-cv-01068, 2009 WL 1788406", "Watkins v. Cal. Dep’t of Corr. & Rehab., No. 1:08-cv-01530, 2012 WL 1906523" ], "court": "United States District Court for the Eastern District of California", "court_code": "caed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-24", "decision_id": "caed-2026-juan-villalovos-gutierrez-v-gerard-van-de-pol", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "Case 2:24-cv-02305-DJC-CKD", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's motion contained two citation defects involving nonexistent authorities.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1572/Villalovos_Guttierez_USA_24_February_2026.pdf", "state": "CA", "summary": "Eastern District of California on 2026-02-24 in Juan Villalovos-Gutierrez, et al. v. Gerard Van de Pol, et al. (2) found counsel's motion contained two citation defects involving nonexistent authorities. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "text_sha256": "7d3464ef37596e9cbeaebe0fa0f764228b002420fcc05771dc6a778f657c2735", "topics": [ "fabricated-citations" ], "tracker_slug": "juan-villalovos-gutierrez-et-al-v-gerard-van-de-pol-et-al-2", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/caed-2026-juan-villalovos-gutierrez-v-gerard-van-de-pol", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/caed-2026-juan-villalovos-gutierrez-v-gerard-van-de-pol" }, { "ai_passage": "“By presenting to the court a ... written motion ... an attorney or unrepresented party certifies that to the best of that person's knowledge, information, and belief, formed after an inquiry reasonable under circumstances the ... legal contentions are warranted by existing law.” FED R. CIV. P. 11(b)(2) (emphases added). Providing these nonexistent citations wastes this Court's and counsel's time. Plaintiff is cautioned that Rule 11's obligations and consequences—up to an including stricken filings or monetary sanctions—apply to all who present writings to the Court, including those appearing pro se. Fletcher v. Experian Info. Sols., Inc., No. 25-20086, 2026 WL 456842, at *5–6 (5th Cir. Feb. 18, 2026) (discussing the appropriateness of sanctions for “hallucinated” cases); Vargas v. Salazar, No. 4:23-CV-04267, 2024 WL 4804091, at *3 (S.D. Tex. Nov. 1, 2024) (noting that future presentation “of pleadings or motions that contain ‘made up’ citations” could subject the pro se plaintiff to sanctions), adopted, No. 4:23CV4267, 2024 WL 4804065 (S.D. Tex. Nov. 15, 2024). 11 Plaintiff filed his original state court petition on April 3, 2025. ECF No. 1-4 at 2–8. He then filed an amended state court petition on April 26, 2025. Id. at 13–19. After this case was removed to federal court, he filed the operative complaint on May 20, 2025, styled “First Amended Complaint,” even though it is his second amendment to his pleadings. ECF No. 3.", "ai_tool_named": null, "archive_url": null, "case_name": "Kenneth Hawkins v. I.C. System, Inc.", "citation": "2026 WL 497165", "cited_authorities": [ "made up", "Fletcher v. Experian Info. Sols", "Vargas v. Salazar, No. 4:23-CV-04267, 2024 WL 4804091", "Rule 11" ], "court": "United States District Court for the Southern District of Texas", "court_code": "txsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-23", "decision_id": "txsd-2026-kenneth-hawkins-v-i-c-system", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Civil Action No. 4:25-CV-2194", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1568/KENNETH_HAWKINS_Plaintiff_v_IC_SYSTEM_INC_et_al_Defendants.pdf", "state": "TX", "summary": "Southern District of Texas on 2026-02-23 in Kenneth Hawkins v. I.C. System, Inc. 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.", "text_sha256": "9344312252de23bc5d0b52cf0436fc2a3549ee85cc119752d74ef90d15e14340", "topics": [ "fabricated-citations" ], "tracker_slug": "kenneth-hawkins-v-i-c-system-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txsd-2026-kenneth-hawkins-v-i-c-system", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txsd-2026-kenneth-hawkins-v-i-c-system" }, { "ai_passage": "PREJUDICE. Plaintiff is admonished that any further failure to comply with the notice requirements set out in Local Civil Rule 7.2(f)(1)-(3) or filing of pleadings with citations to nonexistent cases, in violation of Fed. R. Civ. P. 11, may result in the imposition of sanctions, including the striking of filings, the imposition of filing restrictions and monetary penalties, or the dismissal of this civil action. see Whitehead Case 3:25-cv-01602-K-BK Document 40 Filed 02/23/26 Page 2 of 2 PageID 368 v. Food Max of Miss., Inc., 332 F.3d 796, 802-03 (5th Cir. 2003) (a violation of any provision of Rule 11(b) justifies sanctions).", "ai_tool_named": null, "archive_url": null, "case_name": "Shawn Olali v. Ampex Brands, LLC", "citation": null, "cited_authorities": [ "Page 2 of 2 PageID 368 v. Food Max of Miss", "Fed. R. Civ. P. 11", "Rule 11", "Rule 11(b)" ], "court": "United States District Court for the Northern District of Texas", "court_code": "txnd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-23", "decision_id": "txnd-2026-shawn-olali-v-ampex-brands", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "Case 3:25-cv-01602-K-BK", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's filing contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1624/Olali_v.__USA_23_February_2026.pdf", "state": "TX", "summary": "Northern District of Texas on 2026-02-23 in Shawn Olali v. Ampex Brands, LLC found the self-represented party's filing 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.", "text_sha256": "8820f9974016aaf0ca1ba6a1f51abed9201224475f51223526e4dc914aa5b03b", "topics": [ "fabricated-citations" ], "tracker_slug": "shawn-olali-v-ampex-brands-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txnd-2026-shawn-olali-v-ampex-brands", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txnd-2026-shawn-olali-v-ampex-brands" }, { "ai_passage": "1 As an initial matter, the Court notes that in Defendant's Opposition. Defendant asserts that Plaintiff has filed numerous pleadings based on the same legal and factual grounds already ruled upon by the trial court in the unlawful detainer action. Opposition at 11. Defendant further claims that it believes Plaintiff's recent filings are a product of Artificial Intelligence. Id. The Court notes that Plaintiff's Motion includes citations to nonexistent cases and inaccurate quotations. See Opposition at 910. As stated herein, the Court denies the Motion based on a lack of jurisdiction. Although Defendant's contentions regarding estoppel and artificial intelligence do not directly center on jurisdiction, the Court will address the arguments where relevant.", "ai_tool_named": null, "archive_url": null, "case_name": "Zeus Realty Group LLC v. 1032 N Sycamore Owner LA, LLC et al", "citation": "2026 WL 563023", "cited_authorities": [ "s Motion contained citations to nonexistent cases; Court noted the citations were nonexistent per Defendant", "s Motion included inaccurate quotations from cases; Court observed the quotations were inaccurate per Defendant" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-23", "decision_id": "cacd-2026-zeus-realty-group-v-1032-n-sycamore-owner", "disposition": "The court dismissed the complaint without leave to amend, denied the temporary-restraining-order motion, and dismissed the action without prejudice.", "docket_number": "No. 4. On January 23, 2026, Plaintiff filed the instant Motion", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's temporary-restraining-order motion cited nonexistent cases and inaccurate quotations while seeking to halt a state unlawful-detainer proceeding.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1593/Zeus_Realty_Group_LLC_v_1032_N_Sycamore_Owner_LA_LLC_et_al_USA_23_February_2026.pdf", "state": "CA", "summary": "Central District of California on 2026-02-23 in Zeus Realty Group LLC v. 1032 N Sycamore Owner LA, LLC et al found counsel's temporary-restraining-order motion cited nonexistent cases and inaccurate quotations while seeking to halt a state unlawful-detainer proceeding. The court dismissed the complaint without leave to amend, denied the temporary-restraining-order motion, and dismissed the action without prejudice.", "text_sha256": "7c36b7be39622adf7269b2e1c46bd30f3d34412e170be023175dcbd1f8d921a7", "topics": [ "fabricated-citations" ], "tracker_slug": "zeus-realty-group-llc-v-1032-n-sycamore-owner-la-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-zeus-realty-group-v-1032-n-sycamore-owner", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-zeus-realty-group-v-1032-n-sycamore-owner" }, { "ai_passage": "sever her claim from Sharon’s. Id. at PageID.2357–58. Fourth, she argues that Judge Morris erred in not recusing herself. Id. at PageID.2358–59. In so doing, she cites a case that does not exist— “Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022).” 3 Id. at PageID.2359. Fifth, Peggy asserts that the R&R erred by denying her Motion for Summary Judgment as premature. Id. In that Objection, she critiques the R&R for failing to cite or analyze 3 To be sure, there is a decision named Wells v. United Parcel Serv. Airlines, 688 F. Supp. 3d 567, 570 (W.D. Ky. 2023). But that case addressed no issue of recusal, was decided in a different year than the fake authority Plaintiff invokes, and appears at a different reporter citation than the one she provides. In short, it is not the case Plaintiff purports to cite. -9- Case 1:23-cv-12693-TLL-PTM ECF No. 164, PageID.2714 Filed 02/20/26 Page 10 of 12 a “binding” case. Id. at PageID.2360. But like before, the “binding” case that she cites, “ABC Corp. v. XYZ Inc., 123 F.3d 456 (6th Cir. 2019),” does not exist. Id. If a party properly objects, then “[t]he district judge must determine de novo” the part of the R&R to which the objection pertains. FED. R. CIV. P. 72(b)(3). When reviewing an R&R de novo, courts must review at least the evidence that the parties presented to the magistrate judge. See Hill v. Duriron Co., 656 F.2d 1208, 1215 (6th Cir. 1981). After reviewing the evidence, the", "ai_tool_named": null, "archive_url": null, "case_name": "Zlatkin v. Gladwin County, et al.", "citation": null, "cited_authorities": [ "Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022)", "s recusal argument. || Fabricated: Case Law | Plaintiff cited", "Wells v. UPS Airlines", "Wells v. United Parcel Serv. Airlines", "ABC Corp. v. XYZ Inc", "See Hill v. Duriron Co" ], "court": "United States District Court for the Eastern District of Michigan", "court_code": "mied", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-20", "decision_id": "mied-2026-zlatkin-v-gladwin-county", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 1:23-cv-12693", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained two citation defects, including Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022), ABC Corp. v. XYZ Inc., 123 F.3d 456 (6th Cir. 2019) and Wells v. UPS Airlines, involving nonexistent authorities, mischaracterized...", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1594/Zlatkin_et_al_v._Butman_Township_of_et_al_USA_20_February_2026.pdf", "state": "MI", "summary": "Eastern District of Michigan on 2026-02-20 found the self-represented party's motion contained two citation defects, including Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022), ABC Corp. v..... The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "6ae5d0e340fc4ceb642586e62462de971570027d769428e5dad1e9a84bf19fa1", "topics": [ "fabricated-citations" ], "tracker_slug": "zlatkin-v-gladwin-county-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mied-2026-zlatkin-v-gladwin-county", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-zlatkin-v-gladwin-county" }, { "ai_passage": "B. Count I: “Fraud on the Court” In Count I, the Complaint alleges that Kennedy-Jensen, Here, Count I fails to state a claim upon which relief can Souza, and Druary (the “Count I Defendants”)31 committed be granted because none of the alleged conduct occurred fraud on the court by “submitting fabricated orders, before this Court. See King, 790 F. Supp. 3d at 35 n.1; false employer affiliations, and unserved pleadings; by Beaulieu, 2014 WL 4843809, at *10 n.5. Additionally, none misrepresenting docket entries; and by working with clerks of the allegations relating to conduct that occurred in federal to suppress filings and reroute the case without proper court in the District of Maine — namely that the case was authority.”32 The Debtors argue that events in the United removed to federal court; that Souza appeared as counsel States District Court for the District of Maine, including the in federal court; that Druary electronically filed on the filing of the state court order denying leave to amend the docket a copy of the state court's order denying leave to counterclaim on the federal docket, sufficiently demonstrates amend; and that the case was remanded to state court — are fraud on the court and therefore this Court should set “egregious,” Bogosian, 2017 WL 9324764, at *8, describe aside the state court Foreclosure Judgment. The Count I “an unconscionable scheme calculated to interfere with the Defendants argue that the claim should be dismissed because judicial system's ability impartially to adjudicate a matter the Complaint fails to assert any legal basis for this claim. involving an officer of the court,” id., or constitute actions that would “seriously affect[ ] the integrity of the normal Federal Rule 60(d)(3) permits a federal court to “set aside process of adjudication,” Torres, 914 F.3d at 19. Entering a judgment for fraud on the court.” Fed. R. Civ. P. 60(d) an appearance or filing documents on a docket, even if (3). However, the First Circuit does not recognize fraud fabricated, false, and unserved, as the Complaint asserts, is on the court as an independent cause of action except in insufficient to meet the applicable standard. The remaining rare circumstances. See, e.g., Bogosian v. R.I. Airport Corp. conduct alleged in the Complaint occurred in state court, not (T.F. Green Airport), C.A. No. 17-16S, 2017 WL 9324764, federal court. See Cline v. Burke, 682 F. Supp. 3d 125, 134 at *8 (D.R.I. May 3, 2017); Shirokov v. Dunlap, Grubb & (D. Mass. 2023), aff'd, No. 23-1680, 2024 WL 5412394 (1st Weaver, PLLC, Civil Action No. 10-12043-GAO, 2012 WL Cir. Oct. 16, 2024) (dismissing claim because, inter alia, “the 1065578, at *30 (D. Mass. Mar. 27, 2012). “[A] claim of alleged fraud appear[ed] to have been committed on [a state fraud o[n] the court may be sustained as an independent court], not a federal court”). Accordingly, Count I will be action only if the issue raised is ‘egregious’ and involves DISMISSED. ‘an unconscionable scheme calculated to interfere with the", "ai_tool_named": null, "archive_url": null, "case_name": "In re: Marrett", "citation": "2026 WL 479029", "cited_authorities": [ "Goguen v. Nason, 419 A.2d 1032 (Me. 1980)", "filings of", "Debtors cited 'Goguen v. Nason", "Ridgway v. Prudential Ins. Co", "Bogosian v. R.I. Airport Corp. conduct alleged in the Complaint occurred in state court", "See Cline v. Burke", "Shirokov v. Dunlap", "Fed. R. Civ. P. 60(d)" ], "court": "United States District Court for the District of Massachusetts", "court_code": "mad", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-19", "decision_id": "mad-2026-in-re-marrett", "disposition": "The court dismissed claims or denied relief after identifying the defective authorities.", "docket_number": "No. 25-30440-EDK", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's complaint contained two citation defects, including Goguen v. Nason and Ridgway v. Prudential Ins. Co, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "dismissal" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1564/In_re_Marrett_USA_19_February_2026_GFXYwRZ.pdf", "state": "MA", "summary": "District of Massachusetts on 2026-02-19 in In re: Marrett found the self-represented party's complaint contained two citation defects, including Goguen v. Nason and Ridgway v. Prudential Ins. Co, involving nonexistent authorities, fabricated or misattributed quotations. The court dismissed claims or denied relief after identifying the defective authorities.", "text_sha256": "6db6781d0bfa2a1fa322869fa547a04ba305c91d8fe905c8a3651e282d40bfc7", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-marrett", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mad-2026-in-re-marrett", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mad-2026-in-re-marrett" }, { "ai_passage": "the FCRA. Indeed, Holden never discusses or mentions injunctive relief. At worst, Plaintiffs have obtained their Holden analysis and citation from an unreliable source, such as artificial intelligence (“AI”). The best indication of this possibility is Plaintiffs’ citation to page 1371 of Holden. Holden, 4 Case 0:25-cv-62431-MD Document 37 Entered on FLSD Docket 02/19/2026 Page 5 of 5 however, ends on page 1369. No level of misreading would cause Plaintiffs to cite to a non-existent page. This Court previously admonished Plaintiffs for potentially using AI hallucinated legal citations. DE 11 at 2. The Court should not have to warn Plaintiffs again. If Plaintiffs include any other false or inaccurate legal citations in briefing that the Court suspects were generated by AI, the Court will order Plaintiffs to appear in person to explain those citations and why they should not be sanctioned for their conduct. III. Recommendation Because Plaintiffs cannot obtain injunctive relief under the FCRA, the Court", "ai_tool_named": null, "archive_url": null, "case_name": "Juandel Pena and Martina Ruiz v. Wells Fargo Bank, N.A.", "citation": null, "cited_authorities": [ "Plaintiffs cited Holden v. Holiday Inn Club Vacations" ], "court": "United States District Court for the Southern District of Florida", "court_code": "flsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-19", "decision_id": "flsd-2026-juandel-pena-and-martina-ruiz-v-wells-fargo-bank", "disposition": "The magistrate judge recommended denying the renewed preliminary-injunction motion and warned that further false AI citations could require a sanctions hearing.", "docket_number": "Case 0:25-cv-62431-MD", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented parties' reply misread Holden and cited a nonexistent page beyond the end of the Eleventh Circuit opinion.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1554/Pena_v._Wells_Fargo_USA_19_February_2026.pdf", "state": "FL", "summary": "Southern District of Florida on 2026-02-19 in Juandel Pena and Martina Ruiz v. Wells Fargo Bank, N.A. found the self-represented parties' reply misread Holden and cited a nonexistent page beyond the end of the Eleventh Circuit opinion. The magistrate judge recommended denying the renewed preliminary-injunction motion and warned that further false AI citations could require a sanctions hearing.", "text_sha256": "218c9548e9d76aac1b2b104fa9d5b360a81f1d10040a2b25353e874bc8d73e4b", "topics": [ "fabricated-citations" ], "tracker_slug": "juandel-pena-and-martina-ruiz-v-wells-fargo-bank-n-a", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/flsd-2026-juandel-pena-and-martina-ruiz-v-wells-fargo-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flsd-2026-juandel-pena-and-martina-ruiz-v-wells-fargo-bank" }, { "ai_passage": "Brown v. Crawford, 906 F.2d 667, 670 (11th Cir. 1990). Plaintiff's response to Defendant DJJ's Motion for Summary Judgment regarding Count I, III, IV, V, and VII was then struck by the Court, Dkt. 158, as it cited to hallucinated cases. DISCUSSION See Dkt. 150 at 7, 13, 16 (citing Watson v. Amedisys Holding, LLC, 298 F. App'x 395, 396 (5th Cir. 2008), Martin v. Dep't I. Count I: Retaliation under Title VII of Corrections, 682 So. 2d 331, 333 (Fla. 5th DCA 1996), and Defendant DJJ seeks summary judgment on Count I, which Campbell v. DCF, 201 So. 3d 164, 170 (Fla. 1st DCA 2016), alleges “unlawful retaliation against the Plaintiff for his which are non-existent). The Court granted Plaintiff leave to protected whistleblowing activities” under Title VII. Dkt. 36 refile his response with proper citations, Dkt. 158, and he did ¶ 93. so. Dkt. 159. Title VII prohibits retaliation against an employee “because he has opposed any practice made an unlawful employment practice under [Title VII], or because he has made a charge, LEGAL STANDARD testified, assisted, or participated in any manner in an A district court should grant summary judgment when it investigation, proceeding, or hearing under [Title VII].” 42 determines that there are no genuine issues as to any material U.S.C. § 2000e-3(a). A plaintiff may support a claim of", "ai_tool_named": null, "archive_url": null, "case_name": "Johnson v. Florida Department of Juvenile Justice et al", "citation": "2026 WL 472321", "cited_authorities": [ "x 395, 396 (5th Cir. 2008) || Fabricated: Case Law | Martin v. Dep", "Watson v. Amedisys Holding", "Martin v. Dep't of Corrections", "Brown v. Crawford", "Martin v. Dep't I. Count I", "Campbell v. DCF" ], "court": "United States District Court for the Middle District of Florida", "court_code": "flmd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-19", "decision_id": "flmd-2026-johnson-v-florida-department-of-juvenile-justice", "disposition": "The court struck the defective filing and warned the self-represented party to verify cited authorities before filing again.", "docket_number": "No. 8:24-CV-02195-WFJ-NHA", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained two citation defects, including Watson v. Amedisys Holding and Martin v. Dep't, involving nonexistent authorities.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1570/QUINTAURUS_L_JOHNSON_Plaintiff_v_DEPARTMENT_OF_JUVENILE_JUSTICE_ANDREW_COR.pdf", "state": "FL", "summary": "Middle District of Florida on 2026-02-19 in Johnson v. Florida Department of Juvenile Justice et al found the self-represented party's motion contained two citation defects, including Watson v. Amedisys Holding and Martin v. Dep't, involving nonexistent authorities. The court struck the defective filing and warned the self-represented party to verify cited authorities before filing again.", "text_sha256": "851bcebb0ab86213f3ffbbf473c9a535eb780edecacb6f9cd2f0fcd8d75430a6", "topics": [ "fabricated-citations" ], "tracker_slug": "johnson-v-florida-department-of-juvenile-justice-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/flmd-2026-johnson-v-florida-department-of-juvenile-justice", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flmd-2026-johnson-v-florida-department-of-juvenile-justice" }, { "ai_passage": "464 (5th Cir. 1985) (“[T]he denial of a motion for summary judgment is not the equivalent of the entry of judgment ORDER against the movant.”). Thus, plaintiff's second objection is J. CAMPBELL BARKER United States District Judge meritless. Plaintiff brought this action under the Fair Credit As to plaintiff's final objection, the court appreciates Reporting Act, 15 U.S.C. §§ 1681 et. seq. Doc. 106 at 1. plaintiff's clarification that the citing of fictitious cases was The case was referred to a magistrate judge. Plaintiff filed a “unintentional, not made in bad faith, and not intended motion for summary judgment. Doc. 80. The magistrate judge to mislead the Court.” Doc. 140 at 2. However, plaintiff issued a report recommending that the court deny that motion. is still warned “that further citation to nonexistent cases Doc. 138 at 9. Plaintiff filed written objections. Doc. 140. and noncompliance with Local Rule CV-11(g) may result in sanctions, including her pleadings and other papers The court reviews the objected-to portions of a magistrate being struck, filing restrictions, dismissal of her claims, and judge's report and recommendation de novo. 28 U.S.C. monetary penalties.” Doc. 138 at 8. § 636(b)(1)(C); Fed. R. Civ. P. 72(b)(3). “Parties filing objections must specifically identify those findings objected Having reviewed the magistrate judge's report de novo and to. Frivolous, conclusive, or general objections need not be finding no error, the court overrules plaintiff's objections and considered by the district court.” Nettles v. Wainwright, 677 accepts the report's findings and recommendations. Plaintiff's F.2d 404, 410 n.8 (5th Cir. Unit B 1982) (en banc), overruled motion for summary judgment (Doc. 80) is denied without on other grounds by Douglass v. United Servs. Auto. Ass'n, prejudice to refiling. Plaintiff may file another motion for 79 F.3d 1415 (5th Cir. 1996) (en banc). Furthermore, a party's summary judgment by March 30, 2026. See Doc. 132 at 3. entitlement to de novo review does not entitle it to raise arguments that were not presented to the magistrate judge *2 So ordered by the court on February 18, 2026.", "ai_tool_named": null, "archive_url": null, "case_name": "Shaerica L. Walder v. Experian Information Solutions", "citation": "2026 WL 468409", "cited_authorities": [ "Nettles v. Wainwright", "Douglass v. United Servs. Auto. Ass'n", "Fed. R. Civ. P. 72(b)(3)" ], "court": "United States District Court for the Eastern District of Texas", "court_code": "txed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-18", "decision_id": "txed-2026-shaerica-l-walder-v-experian-information-solutions", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 6:25-cv-00120", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1559/Walder_v._Experian_Information_Solutions_Inc_Defendant_USA_18_February_2026.pdf", "state": "TX", "summary": "Eastern District of Texas on 2026-02-18 in Shaerica L. Walder v. Experian Information Solutions 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.", "text_sha256": "d5f2b422dd8b2603286857a654239f590a9002f6b5c4d5c979d55bb658465376", "topics": [ "fabricated-citations" ], "tracker_slug": "shaerica-l-walder-v-experian-information-solutions", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/txed-2026-shaerica-l-walder-v-experian-information-solutions", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/txed-2026-shaerica-l-walder-v-experian-information-solutions" }, { "ai_passage": "claims, the Court notes that many of Plaintiff’s citations to caselaw are inaccurate or contain incomplete citations.3 To the extent that Plaintiff is using generative artificial intelligence to aid 3 For example, Plaintiff cites to Zschernig v. Miller, 389 U.S. 429, 432 (1968), for a quote that does not exist on the cited page or anywhere else in the case. Pl.’s Mot. 14. Elsewhere, Plaintiff appears to cite within rhymed verse Hartman v. Moore, 547 U.S. 250 (2006), Estelle v. Gamble, 429 U.S. 97 (1976), and Washington v. Glucksberg, 521 U.S. 702 (1997), without full citations supporting Plaintiff’s argument. Id. at 36–37, 76–77. 3 – ORDER Case 3:26-cv-00298-AB Document 7 Filed 02/18/26 Page 4 of 5", "ai_tool_named": null, "archive_url": null, "case_name": "David Martin v. ODS Community Dental Insurance et al.", "citation": null, "cited_authorities": [ "Estelle v. Gamble", "Washington v. Glucksberg in rhymed verse and without full or supporting citations", "Washington v. Glucksberg" ], "court": "United States District Court for the District of Oregon", "court_code": "ord", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-18", "decision_id": "ord-2026-david-martin-v-ods-community-dental-insurance", "disposition": "The court denied the temporary-restraining-order motion and warned the self-represented plaintiff against further inaccurate or incomplete citations.", "docket_number": "Case 3:26-cv-00298-AB", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion quoted language not found in Zschernig and gave incomplete citations to Hartman, Estelle, and Glucksberg.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1560/Martin_v._ODS_USA_18_February_2026.pdf", "state": "OR", "summary": "District of Oregon on 2026-02-18 in David Martin v. ODS Community Dental Insurance et al. found the self-represented party's motion quoted language not found in Zschernig and gave incomplete citations to Hartman, Estelle, and Glucksberg. The court denied the temporary-restraining-order motion and warned the self-represented plaintiff against further inaccurate or incomplete citations.", "text_sha256": "88035003d5f278011333516ccf6711ddd53a69e1c9ec65477ce6a4a68f788389", "topics": [ "fabricated-citations" ], "tracker_slug": "david-martin-v-ods-community-dental-insurance-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ord-2026-david-martin-v-ods-community-dental-insurance", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ord-2026-david-martin-v-ods-community-dental-insurance" }, { "decision_id": "okla-rule-2026", "case_name": "In re Addition of a New Rule to the Rules of the Court of Criminal Appeals", "court": "Oklahoma Court of Criminal Appeals", "court_code": "oklacrimapp", "court_level": "state-supreme", "state": "OK", "date_filed": "2026-02-18", "citation": "2026 OK CR 7", "docket_number": "CCAD-2026-1", "document_type": "administrative-order", "topics": [ "rules-by-opinion" ], "primary_topic": "rules-by-opinion", "court_used_ai": false, "disposition": "The court adopted Rule 1.17 requiring verification of generative-AI-assisted filings.", "ai_passage": "Recognizing the novel and rapid development of generative artificial intelligence (\"generative AI\") and its use in the practice of law, as well as its potential to produce misinformation or even to hallucinate, Rules of the Oklahoma Court of Criminal Appeals, Title 22, Ch.18, App. (2026), set forth as follows: Section I. GENERAL RULES OF THE COURT AND DEFINITIONS Rule 1.17 Use of Generative Artificial Intelligence A. Use. When generative artificial intelligence (\"generative AI\") has been used in the drafting of any document for filing in this Court, the party, or their counsel, shall ensure that any portion of the document produced or modified by generative AI, whether in whole or in part, has been verified as accurate by a person responsible for the document. B. Definition. For purposes of this Rule, \"generative artificial intelligence\" or \"generative AI\" is defined as any type of artificial intelligence that generates content or data in response to a prompt or query by a user. C. Sanctions. Failure to comply with the above requirements may result in the imposition of sanctions by this Court including, but not limited to, waiver of the affected issue(s) on appeal, striking of a non-compliant document from the record, and/or a finding of contempt.", "cited_authorities": [], "summary": "The Oklahoma Court of Criminal Appeals adopts a procedural rule for generative-AI use in filings. Rule 1.17 requires parties or counsel to verify AI-generated or AI-modified content for accuracy and makes noncompliant filings subject to sanctions.", "verification": "mirror-read", "courtlistener_url": "https://www.courtlistener.com/opinion/10795792/x/", "lead_source": [ "user brief", "CourtListener anonymous search" ], "notes": "Official OSCN endpoint timed out; court-authored public-domain text was read from CourtListener storage fallback.", "ai_tool_named": null, "incident": null, "tracker_slug": null, "text_sha256": "c602a41d0919ffa16fc3f3f5557606a58deeee05e5e481c31e9bf244f2a47811", "source_url": "https://www.oscn.net/applications/oscn/deliverdocument.asp?citeid=551159", "archive_url": "https://web.archive.org/web/20260220102219/https://www.oscn.net/applications/oscn/deliverdocument.asp?citeid=551159", "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/opinions/okla-rule-2026", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/okla-rule-2026" }, { "ai_passage": "Moreover, both Car Source and the Dealer Loyalty Defendants point out that Plaintiff is citing hallucinated cases that do not exist, likely generated by artificial intelligence (“AI”). (See ECF No. 23, PageID 100 (explaining “Plaintiff cites Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) for the proposition that Car Source’s disclosure is insufficient. (ECF No. 22, PAGEID #97). But the case does not exist, it is hallucinated.”); ECF No. 37, PageID 151 (“Plaintiff appears to be utilizing AI-generated briefs and ‘fake, hallucinated law’ that ignore the actual facts of the docket and prior Court orders.”).) As Rule 11 states, by presenting a paper, Plaintiff certifies that to the best of his knowledge “the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing", "ai_tool_named": null, "archive_url": null, "case_name": "Kendle Mardis v. Dealer Loyalty Protection, Inc., et al.", "citation": null, "cited_authorities": [ "Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020)", "Rule 11" ], "court": "United States District Court for the Southern District of Ohio", "court_code": "ohsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-18", "decision_id": "ohsd-2026-kendle-mardis-v-dealer-loyalty-protection", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 2:25-cv-1237", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained one citation defect, including Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) and Johnson v. Mitchell, involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1553/Mardis_v._Dealer_Loyalty_Protection_USA_18_February_2026.pdf", "state": "OH", "summary": "Southern District of Ohio on 2026-02-18 found the self-represented party's brief contained one citation defect, including Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) and Johnson v. Mitchell, involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "15d2335c1e3dadfe2d84e593624006b687813169bc1b1d876f57423413223e78", "topics": [ "fabricated-citations" ], "tracker_slug": "kendle-mardis-v-dealer-loyalty-protection-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ohsd-2026-kendle-mardis-v-dealer-loyalty-protection", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ohsd-2026-kendle-mardis-v-dealer-loyalty-protection" }, { "ai_passage": "surrounding passages that Plaintiff omits. (Doc. 55-1 at 115-116.) The short, punctual exchange that Plaintiff quotes, does not exist. On page nine, Plaintiff quotes another long passage from the Ashley deposition that the court won’t bother to reproduce. (Doc. 55 at 9) (quoting Doc. 55-1 at 161:22-162:16). While the subject matter of the cited portion is vaguely on point, the quoted passage does not exist. This pattern of behavior is egregious. The repetition rules out any likelihood of inadvertence. It is unclear to the court what Plaintiff’s attorney was attempting to achieve. He has succeeded only in being a kamikaze to his credibility. Plaintiff is responsible for the content of his filings with the court. Fed. R. Civ. P. 11(b). Inaccuracies or misrepresentations are grounds", "ai_tool_named": null, "archive_url": null, "case_name": "Kennon v. Ashley", "citation": null, "cited_authorities": [ "what he said, not what he did", "It was the language", "No, not that I recall", "There was no contact", "not threatening", "No. I didn", "He didn", "after reviewing the video footage", "footage", "So why did you arrest him?", "He said", "I said" ], "court": "United States District Court for the District of Kansas", "court_code": "ksd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-18", "decision_id": "ksd-2026-kennon-v-ashley", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "Case 5:24-cv-04034-JWB-BGS", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained nine citation defects, including Take me to jail, Okay and It was the language, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1557/Kennon_v._Ashley_USA_18_February_2026.pdf", "state": "KS", "summary": "District of Kansas on 2026-02-18 in Kennon v. Ashley found counsel's brief contained nine citation defects, including Take me to jail, Okay and It was the language, 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.", "text_sha256": "68edd276bb4838737d754d11e5bf37cb00ea3d0392017d6a6b0990c2bff7a36c", "topics": [ "fabricated-citations" ], "tracker_slug": "kennon-v-ashley", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ksd-2026-kennon-v-ashley", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ksd-2026-kennon-v-ashley" }, { "ai_passage": "None of the original citations correctly identified both the case B-number and date; one citation contained an inaccurate B-number. Although the protester provided accurate revised citations, none of the three decisions cited support the asserted proposition. An attorney’s citation of non-existent or inapposite decisions that might have been generated by artificial intelligence may implicate applicable rules of professional conduct. See, e.g., United States v. Hayes, 763 F. Supp. 3d 1054, 2025 U.S. Dist. LEXIS 9408, at *19 (E.D. Cal. 2025) (“Submitting fictitious cases and quotations to the court ‘degrades or impugns the integrity of the Court’ and ‘interferes with the administration of justice’ in violation of Local Rule 180(e), and violates California Rules of Professional Conduct 3.1(a)(2), 3.3(a)(1), and 3.3(a)(2).”). We therefore advise attorneys appearing before our Office that the citation of non-existent authority may result in referral to appropriate bar associations or other disciplinary bodies. 10 That regulation states: A procuring activity has discretion whether to require a protégé or lead small business member of a joint venture to demonstrate some level of past performance and/or experience. It may rely solely on the past performance (continued...)", "ai_tool_named": null, "archive_url": null, "case_name": "Matter of: Adapt Forward, LLC", "citation": null, "cited_authorities": [ "SRA Int’l, Inc", "Boeing Sikorsky Aircraft Support", "Caci, Inc", "United States v. Hayes" ], "court": "Government Accountability Office", "court_code": null, "court_level": "federal-specialty", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-18", "decision_id": "gao-2026-matter-of-adapt-forward", "disposition": "The court warned counsel to verify legal authorities before future filings.", "docket_number": "B-424006", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's filing contained three citation defects, including SRA Int’l, Inc, Boeing Sikorsky Aircraft Support and Caci, Inc, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1597/Adapt_Forward.pdf", "state": null, "summary": "Government Accountability Office on 2026-02-18 in Matter of: Adapt Forward, LLC found counsel's filing contained three citation defects, including SRA Int’l, Inc, Boeing Sikorsky Aircraft Support and Caci, Inc, involving nonexistent authorities, fabricated or misattributed quotations. The court warned counsel to verify legal authorities before future filings.", "text_sha256": "fa03b9a58ea6e041a327cd7d5250c0e1417282ea3d22b3085aae6c3cb6ff96ec", "topics": [ "fabricated-citations" ], "tracker_slug": "matter-of-adapt-forward-llc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gao-2026-matter-of-adapt-forward", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gao-2026-matter-of-adapt-forward" }, { "ai_passage": "before the filing deadline, and did not have time to cite appeal. The OSC noted that several quotations in EFD's check it before filing. Keiter acknowledges that the mistakes briefing in the “R” appeal appear to be fabricated. Azar, who in the briefing are “unacceptable,” but he asserts that signed the opening brief, and Keiter, who signed the reply, sanctions are unnecessary because the fabricated quotations both filed written responses to the OSC. are substantively similar to propositions in the cases cited. According to his response to the OSC, Azar was EFD's “To state the obvious, it is a fundamental duty of attorneys to trial counsel. Azar hired Keiter, a Certified Appellate Law read the legal authorities they cite in appellate briefs or any Specialist, to assist with the appeal. Azar ultimately prepared other court filings to determine that the authorities stand for the opening brief and most of the reply brief. Keiter formatted the propositions for which they are cited. Plainly, counsel did and filed the reply brief. not read the cases he cited before filing his appellate briefs: Had he read them, he would have discovered, as we did, Azar asked an artificial intelligence (AI) “consultant” to use that the cases did not contain the language he purported to AI to prepare a draft opening brief using trial court briefs quote [and] did not support the propositions for which they filed in the underlying lawsuit and an outline that Azar had were cited ....” (Noland v. Land of the Free, L.P. (2025) 114 prepared. The AI consultant cautioned Azar to double check Cal.App.5th 426, 445 (Noland).) These failures violate the the citations in the draft to confirm that the AI system had California Rules of Court, which require that arguments be not fabricated any legal authorities. After completing the draft supported “with citations to real (as opposed to fabricated) opening brief, Azar asked a paralegal to cite check the legal legal authority.” (Id. at p. 447, citing Cal. Rules of Court, authorities. He then realized the brief exceeded the word limit rule 8.204(a)(1)(B).) On our own motion, we may impose by around 6,000 words. Azar and his AI consultant decided sanctions for reliance on nonexistent legal authority and for words, “when one of a number of tort defendants enters unreasonable violations of the California Rules of Court. into a settlement agreement with a plaintiff, the nonsettling (Noland, at p. 445; Cal. Rules of Court, 8.276.) defendants’ liability to the plaintiff is reduced by the amount of the settlement.” (Bay Development, Ltd. v. Superior Court Sanctions may be awarded to compensate “the clerk (1990) 50 Cal.3d 1012, 1018.) of the court for conduct that unnecessarily burdens the court and the taxpayers.” 8 (Noland, supra, 114 Cal.App.5th “[T]he language of section 877 is significant—its drafters did at p. 447.) The fabricated citations in EFD's briefing not use the narrow term ‘joint tortfeasors,’ they used the broad required this court to spend unnec", "ai_tool_named": null, "archive_url": null, "case_name": "EFD USA, INC., et al. v. Band Pro Film and Digital, Inc., et al.", "citation": "2026 WL 457265", "cited_authorities": [ "(1) times of services performed; (2) specific obligations involved; and (3) resulting damages", "a judgment by default admits all material allegations of the complaint", "Noland v. Land of the Free", "Ltd. v. Superior Court Sanctions may be awarded to compensate" ], "court": "California Court of Appeal", "court_code": "calctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-18", "decision_id": "calctapp-2026-efd-usa-v-band-pro-film-and-digital", "disposition": "The court ordered counsel to pay $900 for the defective authorities and complete corrective CLE.", "docket_number": "No. BC661332)", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's reply brief contained six citation defects, including Leaf v. City, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": "USD", "monetary_penalty": 900, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1552/EFD_USA_v_BAND_PRO_FILM_AND_DIGITAL_IN_USA_18_February_2026.pdf", "state": "CA", "summary": "California Court of Appeal on 2026-02-18 in EFD USA, INC., et al. v. Band Pro Film and Digital, Inc., et al. found counsel's reply brief contained six citation defects, including Leaf v. City, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to pay $900 for the defective authorities and complete corrective CLE.", "text_sha256": "639c481a90bb9931acd5692bc067f31aac5691abdacaf0e0a24e6cf02610b8e7", "topics": [ "fabricated-citations" ], "tracker_slug": "efd-usa-inc-et-al-v-band-pro-film-and-digital-inc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp-2026-efd-usa-v-band-pro-film-and-digital", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp-2026-efd-usa-v-band-pro-film-and-digital" }, { "ai_passage": "Proposed Rule, https://www.ca5.uscourts.gov/docs/default-source/default- document-library/court-decision-on-proposed-rule.pdf?sfvrsn=5967c92d_2 (last visited Feb. 18, 2026). In doing so, we concluded that existing rules were sufficient to deter misconduct related to generative AI use, without the need for a rule specific to generative AI. Federal Rule of Appellate Procedure 46(c), for instance, allows a court of appeals, after notice and an opportunity to show cause, to “discipline an attorney who practices before it for conduct unbecoming a member of the bar or for failure to comply with any court rule.” We also have “inherent power to impose sanctions for abuse of the judicial process.” Anderson v. Wells Fargo Bank, N.A., 953 F.3d 311, 315 (5th Cir. 2020). Other courts have noted that submitting a brief riddled with fabricated quotations and assertions is such an abuse. See Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024) (referring attorney to the Second Circuit’s Grievance Panel under 2d Cir. R. 46.2 for failing to make inquiry into the validity of her argument). Regrettably, despite numerous news stories, CLE presentations, scholarly articles, and judicial entreaties, AI-hallucinated case citations have increasingly become an even greater problem in our courts, and the problem shows no sign of abating. Damien Charlotin, a French lawyer and data scientist, maintains a database that tracks court orders related to AI- hallucinated content. AI Hallucination Cases, Damien Charlotin, https://www.damiencharlotin.com/hallucinations (last visited Feb. 18, 2026). As of the date of this order, Charlotin has identified 239 cases of hallucination by lawyers in the United States. Id.2 Within our circuit, district courts have shouldered the burden of addressing AI hallucinations in court _____________________ 2 This figure excludes hallucinations introduced by pro se litigants and judges. 4 Case: 25-20086 Document: 89-1 Page: 5 Date Filed: 02/18/2026 No. 25-20086 filings.3 It is a problem that is getting worse—not better. If it were ever an excuse to plead ignorance of the risks of using generative AI to draft a brief without verifying its output, it is certainly no longer so. To ethically use generative AI in the practice of law—which we do not dispute can be helpful if done properly and carefully—a lawyer must “ensure that the legal propositions and authority generated are trustworthy.” ByoPlanet Int’l, LLC v. Johansson, 792 F. Supp. 3d 1341, 1347 (S.D. Fla. 2025). Failure to do so “abdicate[s] one’s duty, waste[s] legal resources, and lower[s] the public’s respect for the legal profession and judicial proceedings.” Id. II A A brief recitation of the facts underlying this case is helpful. This is an appeal of a sanctions award against Shawn Jaffer, plaintiff’s counsel in the", "ai_tool_named": null, "archive_url": null, "case_name": "Fletcher v. Experian Information Solutions & Bridgecrest Credit Company", "citation": null, "cited_authorities": [ "Brief cited Edwards v. General Motors Corp. for the proposition that sua sponte sanctions implicate de novo review", "Brief asserted Lewis v. Brown & Root reversed", "Anderson v. Wells Fargo Bank", "Other courts have noted that submitting a brief riddled with fabricated quotations and assertions is such an abuse. See Park v. Kim", "LLC v. Johansson", "Cir. R. 46.2" ], "court": "United States Court of Appeals for the Fifth Circuit", "court_code": "ca5", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-18", "decision_id": "ca5-2026-fletcher-v-experian-information-solutions-and-bridgecrest-cred", "disposition": "The court ordered counsel to pay $2,500 for the defective authorities and complete corrective CLE.", "docket_number": "No. 25-20086", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's reply brief contained four citation defects, including Edwards v. General Motors Corp and Lewis v. Brown, involving fabricated or misattributed quotations, mischaracterized authority.", "currency": "USD", "monetary_penalty": 2500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1539/Fletcher_v._Experian_USA_18_February_2026.pdf", "state": null, "summary": "Fifth Circuit on 2026-02-18 in Fletcher v. Experian Information Solutions & Bridgecrest Credit Company found counsel's reply brief contained four citation defects, including Edwards v. General Motors Corp and Lewis v. Brown, involving fabricated or misattributed quotations, mischaracterized authority. The court ordered counsel to pay $2,500 for the defective authorities and complete corrective CLE.", "text_sha256": "938c575bd51477b39b0ab395380832c770959eafe432482f1a42b280ea09b447", "topics": [ "fabricated-citations" ], "tracker_slug": "fletcher-v-experian-information-solutions-bridgecrest-credit-company", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca5-2026-fletcher-v-experian-information-solutions-and-bridgecrest-cred", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca5-2026-fletcher-v-experian-information-solutions-and-bridgecrest-cred" }, { "court_code": "nysd", "state": "NY", "citation": null, "docket_number": "1:25-cr-00503-JSR", "ai_tool_named": "Claude", "incident": null, "tracker_slug": null, "courtlistener_url": "https://storage.courtlistener.com/recap/gov.uscourts.nysd.652138/gov.uscourts.nysd.652138.27.0.pdf", "text_sha256": "b7bd04c056563e6864cc4fcb68ed62eff732eaacf812377d2d4f6d24fb9f920c", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "Court-authored public-domain PDF was image-only; text was read from local OCR of the CourtListener storage PDF.", "decision_id": "nysd-2026-united-states-v-heppner", "case_name": "United States v. Heppner", "court": "U.S. District Court for the Southern District of New York", "court_level": "federal-district", "date_filed": "2026-02-17", "document_type": "memorandum-opinion", "topics": [ "privilege-work-product" ], "primary_topic": "privilege-work-product", "court_used_ai": false, "disposition": "The court granted the government’s request to inspect AI documents, holding attorney-client privilege and work product did not protect them.", "ai_passage": "Thus, the communications between Heppner and Claude were not privileged at the time they took place. Moreover, even assuming that Heppner intended to share these communications with his counsel and eventually did so, it is black-letter law that non-privileged communications are not somehow alchemically changed into privileged ones upon being shared with counsel. Thus, because the AI Documents “would not be privileged if they remained in [Heppner’s] hands,” they did not “acquire protection merely because they were transferred” to counsel. See Gould, Inc. v. Mitsui Min. & Smelting Co., Ltd., 825 F.2d 676, 679-80 (2d Cir. 1987). ... The AI Documents do not merit protection under the work product doctrine because, even assuming, arguendo, that they were prepared “in anticipation of litigation,” In re Grand Jury Subpoenas, 318 F.3d at 383, they were nevertheless not “prepared by or at the behest of counsel,” id., nor did they reflect defense counsel’s strategy, see Matter of Grand Jury Subpoenas, 959 F.2d at 1167. ... Because Heppner’s use of Claude fails to satisfy either of these rules, the AI Documents do not merit the protections Heppner has claimed.", "cited_authorities": [ "Gould, Inc. v. Mitsui Mining & Smelting Co., Ltd., 825 F.2d 676 (2d Cir. 1987)", "United States v. Nobles, 422 U.S. 225 (1975)", "In re Grand Jury Subpoenas Dated March 19, 2002, and August 2, 2002, 318 F.3d 379 (2d Cir. 2003)", "Matter of Grand Jury Subpoenas Dated Oct. 22, 1991, and Nov. 1, 1991, 959 F.2d 1158 (2d Cir. 1992)" ], "summary": "On 2026-02-17, the Southern District of New York holds that a criminal defendant’s Claude exchanges were not shielded from government review. The court finds no attorney-client privilege or work-product protection because the defendant used the AI tool on his own, not at counsel’s behest.", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.nysd.652138/gov.uscourts.nysd.652138.27.0.pdf", "verification": "mirror-read", "lead_source": [ "user lead", "CourtListener storage mirror" ], "url": "https://safelegalai.com/courts/opinions/nysd-2026-united-states-v-heppner", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2026-united-states-v-heppner" }, { "court_code": "ny", "state": "NY", "citation": "2026 NY Slip Op 00825", "docket_number": "No. 7", "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": null, "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "Sensitive child-protective matter; summary limited to the ruling. Official page was read through web retrieval after local curl produced a Cloudflare challenge, so no source hash is recorded.", "decision_id": "ny-2026-matter-of-ms", "case_name": "Matter of M.S. (M.H.)", "court": "New York Court of Appeals", "court_level": "state-supreme", "date_filed": "2026-02-17", "document_type": "opinion", "topics": [ "evidence-authentication" ], "primary_topic": "evidence-authentication", "court_used_ai": false, "disposition": "The court reversed and remitted because the videos were admitted without a sufficient authentication foundation.", "ai_passage": "Investigator Mahoney’s testimony that the videos matched his personal observations of the layout of the living room and items he observed there are similarly insufficient and are not meaningfully different from what we rejected in Patterson. There, an officer who had visited the store where the robbery occurred testified that the video was an accurate depiction of the store’s “actual physical layout” (Patterson, 242 AD2d at 741). The fact that much of the video apparently accurately depicted the home is not sufficient—as it was not in Patterson—to authenticate the video. If such testimony was insufficient then, the increasing prevalence of “deepfake” videos has only rendered the method of matching circumstantial details in a video to personal observations a more suspect form of authentication; most fabricated videos “leverage” real details from real photos and videos of real places and people, then alter the pieces the person wishes to alter to create a realistic, but manipulated, video (see Amicus Br. of Center for Integrity in Forensic Sciences at 7-8). In the authentication context, what matters most is whether the events depicted are as real as the proponent claims them to be, not whether there are some identifying features of the video that can be corroborated in real life.", "cited_authorities": [ "People v. Patterson, 93 N.Y.2d 80 (1999)", "Amicus Brief of Center for Integrity in Forensic Sciences" ], "summary": "On 2026-02-17, the New York Court of Appeals reverses Family Court abuse findings based solely on videos obtained from a third party. The court holds the authentication foundation insufficient and discusses how deepfake technology makes circumstantial matching of places and people less reliable.", "source_url": "https://www.nycourts.gov/reporter/3dseries/2026/2026_00825.htm", "verification": "fetched-and-read", "lead_source": [ "user lead", "New York Law Reporting Bureau" ], "url": "https://safelegalai.com/courts/opinions/ny-2026-matter-of-ms", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ny-2026-matter-of-ms" }, { "ai_passage": "not act with malice are factual disputes that are inappropriate for consideration on a motion to dismiss. D. Warning to Turpen Concerning Artificial Intelligence Turpen has elected to proceed in this case without counsel. He may do so, but he is warned that he will be held to the same standards as parties who appear with counsel. Turpen’s Motion to Dismiss contains what appears to be prompts from some artificial intelligence guidance.45 He also cited a fake case: In re Raspanti, 414 B.R. 263 (Bankr. D. Colo. 2009). Turpen states the incorrect citation was an error, but he is cautioned that he, like all the attorneys who appear in this Court, is subject to all the requirements of Fed. R. Bankr. P. 9011. The Court further cautions Turpen that the use of artificial intelligence for research or drafting of pleadings, whether by attorneys or pro 42 Fowler, 91 F.3d at 1371. 43 McCreary v. Kichler (In re Kichler), 226 B.R. 910, 913 (Bankr. D. Kan. 1998) (“Unless there exists some additional fact, section 523(a)(4), as it relates to a debtor acting in a fiduciary capacity, does not apply to", "ai_tool_named": null, "archive_url": null, "case_name": "McDowell et al. v. Turpen", "citation": null, "cited_authorities": [ "In re Raspanti, 414 B.R. 263 (Bankr. D. Colo. 2009)", "F.3d at 1371. 43 McCreary v. Kichler", "Fed. R. Bankr. P. 9011", "B.R. 263", "B.R. 910" ], "court": "United States Bankruptcy Court for the District of Colorado", "court_code": "cob", "court_level": "federal-bankruptcy", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-17", "decision_id": "cob-2026-mcdowell-v-turpen", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 25-12572 MER", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1558/In_re_Jorge_Luis_Mier_Escobedo_USA_17_February_2026.pdf", "state": "CO", "summary": "United States Bankruptcy Court for the District of Colorado on 2026-02-17 in McDowell et al. v. Turpen 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.", "text_sha256": "03a1aafdef056535b26a7acb470b778d28e0160b3558a49f016485637c1594b5", "topics": [ "fabricated-citations" ], "tracker_slug": "mcdowell-et-al-v-turpen", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cob-2026-mcdowell-v-turpen", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cob-2026-mcdowell-v-turpen" }, { "ai_passage": "9 based on a lack of reliable methodology or on hearsay grounds. 10 3. AI-Generated Citations 11 Defendants contend that Osborne admitted at deposition that articles upon which he 12 purportedly relied do not exist, and that other incorrect citations were miscites generated by AI. 13 Plaintiffs respond that none of the academic articles were actually false, but rather that citations 14 were merely incorrectly formatted based on use of an AI citation tool, which was subsequently 15 corrected. The Court declines to exclude Osborne’s opinions on this basis. Defendants may, 16 however, raise the issue on cross-examination. 4. Not Qualified to Offer Opinions about Platform Design and Scientific 17 Literature on Social Media 18 Defendants maintain that Osborne’s conclusions that social media has adverse mental 19 health effects on youth, and that platforms are engineered to maximize attention, are outside of his", "ai_tool_named": null, "archive_url": null, "case_name": "In re: Social Media Adolescent Addiction Litigation", "citation": null, "cited_authorities": [], "court": "United States District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-17", "decision_id": "cand-2026-in-re-social-media-adolescent-addiction-litigation", "disposition": "The court declined to exclude the expert but left the incorrect AI-generated citations for cross-examination.", "docket_number": "Case 4:22-md-03047-YGR", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "expert", "ai_tool": null, "conduct": "The expert's submission contained two citation defects involving mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1604/Social_Media_Litigation_USA_17_February_2026.pdf", "state": "CA", "summary": "Northern District of California on 2026-02-17 in In re: Social Media Adolescent Addiction Litigation found the expert's submission contained two citation defects involving mischaracterized authority. The court declined to exclude the expert but left the incorrect AI-generated citations for cross-examination.", "text_sha256": "cdf3ff5ef5a540a64036b603f549b8f44ab7e680f18df8f7e754b79051ee6660", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-social-media-adolescent-addiction-litigation", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cand-2026-in-re-social-media-adolescent-addiction-litigation", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cand-2026-in-re-social-media-adolescent-addiction-litigation" }, { "ai_passage": "In opposition, Plaintiffs argue that because they still possess all five original, uncancelled CDs, a presumption of nonpayment automatically applies under Comm. Code § 3104(j) and Evid. Code § 635. Plaintiffs also argue that triable issues of material fact remain over whether the CDs were ever paid, surrendered, cancelled, or rolled over. Plaintiffs further argue that banks in the 1980s wrote non-negotiable on CDs to mean that the interest rate was fixed, not that there was a contractual obligation to repay. In reply, Defendant argues that Plaintiffs fail to establish that the certificates are admissible because they failed to lay an evidentiary foundation. Additionally, Defendant alleges Plaintiffs cited a non-existent, AI-generated case, Mitchell v. Bank of America (1928) 89 Cal.App. 467, 471-472, to prove that an essential feature of a CD is the requirement of surrender at maturity. Defendant further alleges that Plaintiffs' counsel cited cases that do exist but do not stand for the propositions for which they are cited, including People v. Wharton (1991) 53 Cal.3d 522 and AARTS Productions, Inc. v. Crocker Nat'l Bank(1986) 179 Cal.App.3d 1061. Defendant argues that Plaintiffs admitted to rolling over their initial deposit into successive certificates of deposit. Defendant also argues that its evidence shows that it does not owe money to Plaintiffs. Finally, Defendant argues that Plaintiff's argument about 1980s banking practices is unsupported in fact and law. c. Evidentiary Objections Plaintiffs object to the declaration of Mandi Willis. Objections 1-5 are OVERRULED. Plaintiffs object to the declaration of Jeffrey Kirshenbaum. Objections 1-8 are OVERRULED.", "ai_tool_named": null, "archive_url": null, "case_name": "Greenberg v. First Bank, Inc.", "citation": "2026 WL 638479", "cited_authorities": [ "Plaintiffs cited People v. Wharton but allegedly relied on it for a proposition the case does not support", "Inc. v. Crocker Nat'l Bank but allegedly misapplied its holding. In opposition", "Mitchell v. Bank of America", "People v. Wharton", "Inc. v. Crocker Nat'l Bank" ], "court": "Superior Court of California, Los Angeles County", "court_code": "calsuperct", "court_level": "state-trial", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-17", "decision_id": "calsuperct-2026-greenberg-v-first-bank", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "No. 25PSCV02072", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel cited a nonexistent AI-generated case about certificate-of-deposit surrender and misapplied People v. Wharton and AARTS Productions.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2333/06_-_Greenberg_v_First_Bank_Inc.pdf", "state": "CA", "summary": "Superior Court of California, Los Angeles County on 2026-02-17 in Greenberg v. First Bank, Inc. found counsel cited a nonexistent AI-generated case about certificate-of-deposit surrender and misapplied People v. Wharton and AARTS Productions. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "text_sha256": "e80135768ef88e026e1e826d440f87197cd2a407454cb5688e3da5d07e019767", "topics": [ "fabricated-citations" ], "tracker_slug": "greenberg-v-first-bank-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calsuperct-2026-greenberg-v-first-bank", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calsuperct-2026-greenberg-v-first-bank" }, { "ai_passage": "2 We take our facts from the complaint. 3 Rios cites “Stanley v. Univ. of Southern California (2022) 98 Cal.App.5th 151” for the proposition that a defendant's unilateral misunderstanding as to a plaintiff's intent is unenforceable against the plaintiff. He cites “Eustace v. Lynch (2012) 209 Cal.App.4th 1457” for the proposition that general releases must be accompanied by a Civil Code section 1542 waiver. These reporter citations lead to decisions with entirely different names, and which do not support Rios's claims. Although we located decisions with the case names Rios provided, the existing Stanley decision is from a different jurisdiction and the existing Eustace case was decided 71 years before the nonexistent case Rios cites. (Stanley v. University of Southern California (9th Cir. 1994) 13 F.3d 1313; Eustace v. Lynch (1941) 43 Cal.App.2d 486.) The actual cases with these names do not support Rios's claims. 4 Rios purports to quote from Osumi and Fiore in his brief on appeal, but the quotations do not exist in those cases. Government Works.", "ai_tool_named": null, "archive_url": null, "case_name": "Alejandro Rios v. Puente Hills Ford", "citation": "2026 WL 445097", "cited_authorities": [ "Stanley v. Univ. of Southern California (2022) 98 Cal.App.5th 151", "Eustace v. Lynch (2012) 209 Cal.App.4th 1457", "Osumi v. Sutton", "Fiore v. Alvord", "Stanley v. Univ. of Southern California", "Eustace v. Lynch", "Stanley v. University of Southern California" ], "court": "California Court of Appeal", "court_code": "calctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-17", "decision_id": "calctapp-2026-alejandro-rios-v-puente-hills-ford", "disposition": "The court warned the self-represented party to verify legal authorities before future filings.", "docket_number": "No. 24NNCV00486)", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's brief contained three citation defects, including Osumi v. Sutton, Fiore v. Alvord and Stanley v. Univ, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1536/Rios_v._Puente_Hills_Ford_USA_17_February_2026.pdf", "state": "CA", "summary": "California Court of Appeal on 2026-02-17 in Alejandro Rios v. Puente Hills Ford found the self-represented party's brief contained three citation defects, including Osumi v. Sutton, Fiore v. Alvord and Stanley v. Univ, involving nonexistent authorities, fabricated or misattributed quotations. The court warned the self-represented party to verify legal authorities before future filings.", "text_sha256": "395da999d06ac41125c9e6989777097f00679e3be33ce9ae13e677188eefee26", "topics": [ "fabricated-citations" ], "tracker_slug": "alejandro-rios-v-puente-hills-ford", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/calctapp-2026-alejandro-rios-v-puente-hills-ford", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/calctapp-2026-alejandro-rios-v-puente-hills-ford" }, { "ai_passage": "United States v. Dann, 652 F.3d 1160 (9th Cir. 2011) containing and highlighting all stated principles of law as cited in the Motion no later than 12:00 p.m., Pacific Standard Time, on February 19, 2026. IT IS FURTHERED ORDERED that, if he is unable to do so, Cabanday shall file with the Court an explanation in writing how the quotation and citations were included in the Motion and why he should not be sanctioned pursuant to (1) Rule 11(b), (c); (2) 28 U.S.C. § 1927; and (3) the inherent power of the Court to order sanctions for citing non-existent quotations and legal principles to the Court no later than 12:00 p.m., Pacific Standard Time, on February 19, 2026. IT IS FURTHER ORDERED that the written submission due on February 19, 2026, shall take the form of a sworn declaration. IT IS FURTHER ORDERED that, should Cabanday have witnesses, their statements shall also be submitted in the form of a sworn declaration and filed by February 19, 2026. IT IS FURTHER ORDERED that the Court reserves the right to call a hearing for this matter based on the evidence received. III. FACTUAL ALLEGATONS", "ai_tool_named": null, "archive_url": null, "case_name": "Doe 1, et al. v. Shirley Lai, et al.", "citation": null, "cited_authorities": [ "Rule 11(b)" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-17", "decision_id": "cacd-2026-doe-1-v-shirley-lai", "disposition": "The court denied the motion to dismiss, granted judicial notice, and ordered defense counsel to produce authorities or explain why sanctions should not issue.", "docket_number": "Case 5:25-cv-03485-JGB-DTB", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Defense counsel attributed a quotation to Headley that the court could not locate and cited Dann for a proposition the court could not find.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/2683/Doe_1_v._Lai_USA_17_February_2026.pdf", "state": "CA", "summary": "Central District of California on 2026-02-17 found defense counsel attributed a quotation to Headley that the court could not locate and cited Dann for a proposition the court could not find. The court denied the motion to dismiss, granted judicial notice, and ordered defense counsel to produce authorities or explain why sanctions should not issue.", "text_sha256": "ce816ba3105255852adf0f95c78a386e46bb83b0a516f1214ed48b1d674a4cb8", "topics": [ "fabricated-citations" ], "tracker_slug": "doe-1-et-al-v-shirley-lai-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-doe-1-v-shirley-lai", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-doe-1-v-shirley-lai" }, { "ai_passage": "third amended complaint. Davis responded to this motion Davis filed her original complaint on June 9, 2025. (Doc. 1.) and requested leave to amend if her complaint was found A little over one month later, Davis filed a “Motion to Accept insufficient. (Doc. 35 at 4.) Davis's opposition also contained Waiver of Service.” (Doc. 13.) The court denied that motion a citation to a non-existent case. (Doc. 35 at 4.) American after explaining it was not appropriate because it would be Airlines's reply argued the fictitious citation merited sanctions up to American Airlines to object to the adequacy of service. in the form of dismissal. (Doc. 38 at 10.) (Doc. 14 at 1.) The court informed Davis that although she was proceeding pro se, she was required to comply with the *2 On January 15, 2026, Davis filed a “Notice of Correction same rules of procedures that apply to all litigants. Davis and Request for Leave to Amend.” (Doc. 39.) In that was also instructed to “ensure her filings compl[ied] with all notice, Davis sought to withdraw the fictitious citation in applicable rules and procedures.” (Doc. 14 at 1.) Despite those her opposition. Davis also requested leave to amend the warnings, on July 25, 2025, Davis filed another “Motion to complaint if the motion to dismiss was granted. (Doc. 39.) Accept Waiver of Service.” (Doc. 20.) The court issued a Given that Davis had already made a request for leave to second order denying the motion as “baseless” and reminding amend, it is not clear why she made this separate request. Davis she was risking sanctions by ignoring court orders. (Doc. 23 at 2.) Turning to the substance, the third amended complaint begins by stating Davis “was subjected to adverse treatment based", "ai_tool_named": null, "archive_url": null, "case_name": "Nia Elan Davis v. American Airlines, et al.", "citation": "2026 WL 444958", "cited_authorities": [], "court": "United States District Court for the District of Arizona", "court_code": "azd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-17", "decision_id": "azd-2026-nia-elan-davis-v-american-airlines", "disposition": "The court granted the motion to dismiss, entered judgment for American Airlines, and did not impose sanctions after the plaintiff withdrew the fictitious citation.", "docket_number": "No. CV-25-01992-PHX-KML", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's opposition cited a fictitious case, then withdrew the citation after the defendant requested dismissal as a sanction.", "currency": null, "monetary_penalty": null, "outcome": "sanctions" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1535/Davis_v._American_Airlines_USA_17_February_2026.pdf", "state": "AZ", "summary": "District of Arizona on 2026-02-17 in Nia Elan Davis v. American Airlines, et al. found the self-represented party's opposition cited a fictitious case, then withdrew the citation after the defendant requested dismissal as a sanction. The court granted the motion to dismiss, entered judgment for American Airlines, and did not impose sanctions after the plaintiff withdrew the fictitious citation.", "text_sha256": "f2c221b66e6e5e472dcaffbe0675f57e0653dbdc3dc360404706cf77f80d5e8c", "topics": [ "fabricated-citations" ], "tracker_slug": "nia-elan-davis-v-american-airlines-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/azd-2026-nia-elan-davis-v-american-airlines", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/azd-2026-nia-elan-davis-v-american-airlines" }, { "ai_passage": "comic book collection to the Kalama Public Library. In July (9) Outrage. Dkt. 27. 2021 the proffered donation was discussed at the library board meeting, which Merz attended (on Zoom). Merz alleges that he was made to feel unwelcome at this meeting, and that II. HOUSEKEEPING “Jenkins stated that Plaintiff was not an appropriate person As an initial matter, the Court previously rejected Defendants’ to be volunteering with children or selecting comic books objections about the length and timing of Merz's Response, for children.” Dkt. 27 at 11. He alleges Jenkins performed and denied Merz's motion to strike. Dkt. 60. It left open a “background check” on Merz, seeking to find a reason to the issue of Merz citing to fabricated, inaccurate authority: reject the comic book donation. Id. at 10. “In Sorensen v. City of Bellingham, 15 Wn. App. 2d 730, 733, 478 P.3d 1110 (2020), the court held that when officers Second, in 2021, Merz was apparently the focus of a stalker affirmatively act in a way that leaves a person worse off, a named Christopher Jensen. Dkt. 27 at 13. He does not duty can arise even absent explicit assurances.” Dkt. 48 at 23. articulate why Jensen targeted him, but he does allege that Jensen threatened to murder him in an email sent to Merz's *3 Merz corrected and explained the source of the inaccurate Kalama email account, though he alleges he never saw the cite at Dkt. 52. He intended to cite Norg v. City of Seattle, email. Id. Nevertheless he alleges that the email “contained a 200 Wn.2d 749 (2023) for the same proposition. Norg did not manifesto that purported to expose plaintiff.” Id. He alleges involve analogous facts, and it is tenuous support for Merz's that “someone” deleted the email instead of forwarding it claim that any defendant is liable to him for failing to warn to law enforcement. Id. He alleges that he sought to discuss him of a known danger, particularly where no harm resulted. Jensen and his threats at various city council meetings, and Nevertheless, because the Court can resolve the motion on the Reuter muted his microphone. Id. at 16. merits, it declines to dismiss based on the inaccurate citation.", "ai_tool_named": null, "archive_url": null, "case_name": "Merz v. City of Kalama", "citation": "2026 WL 411837", "cited_authorities": [ "per se", "Sorensen v. City of Bellingham, 15 Wn. App. 2d 730, 733, 478 P.3d 1110 (2020)", "Merz relied on Caruso v. Local Union 690", "Merz cited 'Sorensen v. City of Bellingham", "Merz later admitted he intended to cite Norg v. City of Seattle", "In Sorensen v. City of Bellingham", "Dkt. 52. He intended to cite Norg v. City of Seattle" ], "court": "United States District Court for the Western District of Washington", "court_code": "wawd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-13", "decision_id": "wawd-2026-merz-v-city-of-kalama", "disposition": "The court granted the motions to dismiss and for judgment on the pleadings, struck improper notices, and dismissed all claims with prejudice.", "docket_number": "NO. C24-5588 BHS", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's briefing misused Caruso for a per se defamation point and gave an inaccurate Sorensen citation later corrected to Norg.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1612/Merz_v_City_of_Kalama_USA_13_February_2026.pdf", "state": "WA", "summary": "Western District of Washington on 2026-02-13 in Merz v. City of Kalama found the self-represented party's briefing misused Caruso for a per se defamation point and gave an inaccurate Sorensen citation later corrected to Norg. The court granted the motions to dismiss and for judgment on the pleadings, struck improper notices, and dismissed all claims with prejudice.", "text_sha256": "78c6467e2af0672f40e69c33143746d4895c2616c537be080a1a7c1b44d23e82", "topics": [ "fabricated-citations" ], "tracker_slug": "merz-v-city-of-kalama", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/wawd-2026-merz-v-city-of-kalama", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2026-merz-v-city-of-kalama" }, { "ai_passage": "‘all reasonable inferences that can be drawn from’ those allegations ... and, construing the allegations and reasonable inferences ‘in the light most favorable to the [plaintiff]’..., we determine whether they ‘plausibly give rise to an entitlement to relief.’ ” Oakwood Lab'ys LLC v. Thanoo, 999 F.3d 892, 904 (3d Cir. 2021) (internal citations omitted). 15 ECF 15-1 at 5–8. 16 Trial counsel and judges increasingly work under a risk of miscitations or unsupported arguments patched from artificial intelligence favored by many lawyers. We have no reason to today find the abuse of artificial intelligence research. We instead see old-fashioned lack of diligence. Counsel is professionally obligated (compounded by risk to their and their law firm's reputations) to be diligent in ensuring the accuracy of citations and quotations in briefing submitted to us and our colleagues. Experienced federal lawyers know our talented lawyers in Chambers study their work product to advise the judges. And these Chambers's lawyers are unfairly burdened in a busy urban federal court docket. We rely on counsel to present accurate citations.", "ai_tool_named": null, "archive_url": null, "case_name": "Nydia Rosario v. Liberty Mutual Personal Insurance Company", "citation": "2026 WL 413438", "cited_authorities": [ "56 F. App", "instead of the correct", "x 133", "2017 U.S. Dist. LEXIS 93673, at *2-3", "Id. at *2-3", "Counsel quoted Kiessling v. State Farm", "Santiago v. Warminster Twp", "F. App'x 133' instead of the correct '506 F. App'x 133' for Smith v. State Farm Auto. Ins. Co", "Incorrect pincite and mixed database locators for Jones v. Allstate", "Oakwood Lab'ys LLC v. Thanoo" ], "court": "United States District Court for the Eastern District of Pennsylvania", "court_code": "paed", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-13", "decision_id": "paed-2026-nydia-rosario-v-liberty-mutual-personal-insurance", "disposition": "The court ordered counsel to share the decision with the firm and address the citation-verification failure internally.", "docket_number": "CIVIL ACTION NO. 26-276", "document_type": "order", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained five citation defects, including Id. at *2-3, Kiessling v. State Farm and Santiago v. Warminster Twp, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1531/NYDIA_ROSARIO_v_LIBERTY_MUTUAL_PERSONAL_INSURANCE_COMPANY.pdf", "state": "PA", "summary": "Eastern District of Pennsylvania on 2026-02-13 in Nydia Rosario v. Liberty Mutual Personal Insurance Company found counsel's brief contained five citation defects, including Id. at *2-3, Kiessling v. State Farm and Santiago v. Warminster Twp, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to share the decision with the firm and address the citation-verification failure internally.", "text_sha256": "63a2816f4fae20281de5cb3a6e444c7aaa51a9844c6eeb4380a50fa7c45544ac", "topics": [ "fabricated-citations" ], "tracker_slug": "nydia-rosario-v-liberty-mutual-personal-insurance-company", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/paed-2026-nydia-rosario-v-liberty-mutual-personal-insurance", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/paed-2026-nydia-rosario-v-liberty-mutual-personal-insurance" }, { "ai_passage": "purpose of securing Attorney Bonsignore's status as lead Furthermore, this is not the first time that Attorney counsel and (2) any evidence supporting Dos Santos’ claims Passatempo has misrepresented the law to this Court, and is so obviously absent from the record that her attorneys must such misrepresentations bear the clear hallmark of artificial have known that her claims were frivolous. intelligence hallucinations. 1 Wadsworth v. Walmart Inc., The record is not, however, as deficient as defendants suggest. 348 F.R.D. 489, 493 (D. Wyo. 2025) (“A hallucination First, defendants point to the Court's entry of summary occurs when an AI database generates fake sources of judgment against plaintiff (Docket No. 2292) as support information.”). Plaintiff's counsel should be prepared to for the argument that her claims were baseless from the address these misrepresentations at the status conference outset. A ruling of summary judgment does not, however, scheduled for February 19, 2026, and to show cause why the automatically render the losing claims so frivolous as to Court should not impose sanctions and/or refer the matter to entitle the prevailing party to attorneys’ fees. See Nelson v. the Massachusetts Board of Bar Overseers.", "ai_tool_named": null, "archive_url": null, "case_name": "In re: Telexfree Securities Litigation", "citation": "2026 WL 412550", "cited_authorities": [ "l Co. v. Rochem Int", "Wadsworth v. Walmart Inc" ], "court": "United States District Court for the District of Massachusetts", "court_code": "mad", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-13", "decision_id": "mad-2026-in-re-telexfree-securities-litigation", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "No. 4:14-md-2566-NMG", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's filing contained four citation defects, including Jensen v. Phillips Screw Co, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1530/In_re_Telexfree_Securities_Litigation.pdf", "state": "MA", "summary": "District of Massachusetts on 2026-02-13 in In re: Telexfree Securities Litigation found counsel's filing contained four citation defects, including Jensen v. Phillips Screw Co, 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.", "text_sha256": "e392e90d234cae2701d293aa7c7e2919411e9d593139c33225a735cf9d7c8c3f", "topics": [ "fabricated-citations" ], "tracker_slug": "in-re-telexfree-securities-litigation", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/mad-2026-in-re-telexfree-securities-litigation", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mad-2026-in-re-telexfree-securities-litigation" }, { "ai_passage": "4 Dean, 56 Kan. App. 2d 770, 772-73, 437 P.3d 46 (2018) (citing King v. Stephens, 113 Kan. 558, 560, 215 P. 311 [1923]). If no transcript or adequate substitute is provided, we will not review any action of the trial court requiring us to examine the evidence. In re Marriage of Dean, 56 Kan. App. 2d at 772-73 (citing First Nat'l Bank & Trust Co. v. Lygrisse, 231 Kan. 595, 603, 647 P.2d 1268 [1982]; Osborne v. Fakes, 178 Kan. 373, 376, 286 P.2d 156 [1955]). \"Without an objection, this court will presume the district court made all the necessary factual findings to support its judgment, though this court may consider a remand if the lack of specific findings precludes meaningful appellate review.\" Bicknell v. Kansas Dept. of Revenue, 315 Kan. 451, Syl. ¶ 14, 509 P.3d 1211 (2022). Including documents in an appendix does not make those documents part of the record on appeal; only materials properly designated and filed may be considered. Rodriguez v. U.S.D. No. 500, 302 Kan. 134, 144, 351 P.3d 1243 (2015); Rule 6.02(a)(4)- (5). LuPardus did not designate a transcript for the first day of trial. When an appellant fails to provide a complete record, Kansas law requires the appellate court to presume the district court's factual findings were correct. In re Marriage of Dean, 56 Kan. App. 2d at", "ai_tool_named": null, "archive_url": null, "case_name": "Landmark Development Group, LLC v. Lonnie LuPardus", "citation": null, "cited_authorities": [ "Meadors v. Feltor", "Edwards v. Scholtzs", "Wilson v. Gutschenritter", "King v. Stephens", "First Nat'l Bank & Trust Co. v. Lygrisse", "Osborne v. Fakes", "Bicknell v. Kansas Dept. of Revenue", "Rodriguez v. U.S.D. No. 500" ], "court": "Kansas Court of Appeals", "court_code": "kanctapp", "court_level": "state-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-13", "decision_id": "kanctapp-2026-landmark-development-group-v-lonnie-lupardus", "disposition": "The court deemed the arguments unsupported or waived because the cited authorities were defective.", "docket_number": "No. 128,180", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's expert submission contained three citation defects, including Meadors v. Feltor, Edwards v. Scholtzs and Wilson v. Gutschenritter, involving incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1525/Landmark_v._Lupardus_USA_13_February_2026.pdf", "state": "KS", "summary": "Kansas Court of Appeals on 2026-02-13 in Landmark Development Group, LLC v. Lonnie LuPardus found the self-represented party's expert submission contained three citation defects, including Meadors v. Feltor, Edwards v. Scholtzs and Wilson v. Gutschenritter, involving incorrect statutory or rule text. The court deemed the arguments unsupported or waived because the cited authorities were defective.", "text_sha256": "3ece1d548496d075c8f31bbf8e1202b97bcbafe5f1cca9ef1c870eba1621e3c5", "topics": [ "fabricated-citations" ], "tracker_slug": "landmark-development-group-llc-v-lonnie-lupardus", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/kanctapp-2026-landmark-development-group-v-lonnie-lupardus", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/kanctapp-2026-landmark-development-group-v-lonnie-lupardus" }, { "ai_passage": "The agency requested dismissal of the protest and in its response, the protester cited to certain cases in support of its argument against dismissal. After the intervenor requested clarification on these cited cases, the protester’s counsel acknowledged that the response included citations to non-existent caselaw. Electronic Protest Docketing System (EPDS) Docket Entries No. 21 Request for Clarification on Cases Cited by Protester; No. 22, Request to Substitute Response to Dismissal Request and Acknowledgment of Citation Error. G2 Ops’ erroneous citations bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) without adequate verification that the generated results were accurate. See KE Sys. Servs., Inc., B-423881 et al., Dec. 22, 2025, at 6. The use of AI programs to draft or assist in drafting legal filings can result in the citation of non-existent decisions, such that reliance on those programs without review for accuracy wastes the time of all parties and GAO. KE Sys. Servs., Inc., supra; Raven Investigations & Sec. Consulting, LLC, B-423447, May 7, 2025, at 4. As we have explained, our Office necessarily reserves an inherent right to dismiss any protest and to impose sanctions against a protester, where a protester’s actions undermine the integrity and effectiveness of our process. Raven Investigations & Sec. Consulting, LLC, supra. The protester’s counsel is advised that any future submission of filings to our Office with citations to non-existent authority may, after reviewing the totality of the circumstances, result in the imposition of sanctions. Id. Page 8 B-423967", "ai_tool_named": null, "archive_url": null, "case_name": "G2 Ops, Inc.", "citation": null, "cited_authorities": [ "and GAO" ], "court": "Government Accountability Office", "court_code": null, "court_level": "federal-specialty", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-13", "decision_id": "gao-2026-g2-ops", "disposition": "GAO denied the protest in part, dismissed it in part, and warned that future submissions with nonexistent authority may lead to sanctions.", "docket_number": "B-423967", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's response to dismissal cited nonexistent case law that GAO said bore hallmarks of AI or large-language-model use without verification.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1685/G2_Ops_Inc..pdf", "state": null, "summary": "Government Accountability Office on 2026-02-13 in G2 Ops, Inc. found counsel's response to dismissal cited nonexistent case law that GAO said bore hallmarks of AI or large-language-model use without verification. GAO denied the protest in part, dismissed it in part, and warned that future submissions with nonexistent authority may lead to sanctions.", "text_sha256": "dbf1c63cb8e0a36861eb4e6c0bdbcd6d6efaffc40ef674922a32b13ec3c45ae1", "topics": [ "fabricated-citations" ], "tracker_slug": "g2-ops-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gao-2026-g2-ops", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gao-2026-g2-ops" }, { "ai_passage": "1 Defendants filed an opposed motion for another extension of the discovery deadline. DE 81. Judge Middlebrooks denied the Motion, finding Defendants had “not shown they ha[d] acted with diligence” and had not established why the broad discovery they sought was needed. DE 84. Therefore, the discovery period expired on December 28, 2025. 2 After I notified Defendants of an apparent artificial intelligence hallucination in their response, DE 87, they withdrew their original response, DE 99, and an amended response. DE 100. These filings acknowledged that there were additional hallucinations in the original response. DE 99 at 1; DE 100 at 1 n.1. While the amended response contained replacements for many incorrect case citations, its substance did not materially differ from that of the original response. 3 Defendants also argue it was improper for Ms. Newell to notice depositions for the \"person in charge of collections\" instead of noticing 30(b)(6) depositions for corporate representatives of the Law Firm and FLC, specifying topics for questioning. DE 87 at 3. The case Defendants cite, Meraki Solar, LLC v. Rosenbalm, contradicts this conclusion. The Meraki court explained that a party is not required to take a 30(b)(6) deposition, nor does the availability of 30(b)(6) depositions prohibit parties from deposing agents of a corporate entity to investigate their personal knowledge. 2021 WL 12286635, at *2 (N.D. Fla. Oct. 29, 2021). Further, by the text of Rule 30, Ms. Newell was permitted to notice a witness by role rather than by name. See Fed. R. Civ. P. 30(b)(1) “If the name is unknown, the notice must provide a general description sufficient to identify the person or the particular class or group to which the person belongs.”).", "ai_tool_named": null, "archive_url": null, "case_name": "Lindsey Newell v. The Law Offices of Travis R. Walker, et al.", "citation": "2026 WL 507533", "cited_authorities": [ "LLC v. Rosenbalm", "Fed. R. Civ. P. 30(b)(1)" ], "court": "United States District Court for the Southern District of Florida", "court_code": "flsd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-13", "decision_id": "flsd-2026-lindsey-newell-v-the-law-offices-of-travis-r-walker", "disposition": "The magistrate judge recommended granting discovery sanctions in part and noted defendants corrected AI hallucinations after the court flagged them.", "docket_number": "NO. 25-14017-CIV-", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Defense counsel's sanctions response included apparent AI hallucinations, later corrected after the court notified counsel of the problem.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1569/LINDSEY_NEWELL_Plaintiff_v_THE_LAW_OFFICES_OF_TRAVIS_R_WALKER_et_al_Defend.pdf", "state": "FL", "summary": "Southern District of Florida on 2026-02-13 in Lindsey Newell v. The Law Offices of Travis R. Walker, et al. found defense counsel's sanctions response included apparent AI hallucinations, later corrected after the court notified counsel of the problem. The magistrate judge recommended granting discovery sanctions in part and noted defendants corrected AI hallucinations after the court flagged them.", "text_sha256": "837cac9da3c756cc3ff7d5aed3116bbff9fb924e53ad3ee789d8bb7ad1d133ac", "topics": [ "fabricated-citations" ], "tracker_slug": "lindsey-newell-v-the-law-offices-of-travis-r-walker-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/flsd-2026-lindsey-newell-v-the-law-offices-of-travis-r-walker", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/flsd-2026-lindsey-newell-v-the-law-offices-of-travis-r-walker" }, { "ai_passage": "Menera, 60 F.4th 1289 (10th Cir. 2023), which involved a they were targeted because of their familial relationship to criminal defendant's challenge to his sentence, see id. at 1291. “someone perceived as defiant to a criminal organization” Petitioners’ counsel relies on or quotes from this apparently because “the threats in this case followed [the] uncle's fictitious Rodriguez-Romero case multiple other times in his resistance to extortion and his subsequent shooting.” Id. at brief. See Pet'rs’ Br. at 8, 9, 11, 15, 18, 19, 22. 19. Petitioners further argue that the BIA misapplied the “one central reason” standard because “[t]hat standard does not Petitioners’ counsel did not file a reply brief, where he might require a persecutor to expressly declare their motives but have explained this fabricated citation. If counsel made a allows adjudicators to consider indirect evidence, including citation error, we have not been able to deduce what it might the sequence of events, patterns of threats, and the broader be. We have not uncovered any relevant federal case similarly social and political context.” Id. at 23–24. captioned or containing any of the quotations that counsel attributes to this apparently nonexistent case.2 This line of argument fails to persuade us that the BIA erred. This case citation and the quotations and propositions First, Petitioners never testified that there was any link attributed to it appear fabricated. This is likely the result of between the uncle's shooting in 2020 and the threats to their Petitioners’ counsel's use of a generative artificial intelligence son in 2022, so there is no evidence that would support a tool as a research and drafting aid without adequate review finding that the threats to their son were on account of their of the results the tool generated. See Wadsworth v. Walmart family membership to the uncle. Inc., 348 F.R.D. 489, 497 (D. Wyo. 2025) (“It is ... well- known in the legal community that AI resources generate Second, the IJ and the BIA considered the circumstantial fake cases.”). Such fabrications are often referred to as evidence Petitioners claim is relevant to their application, “AI [h]allucinations,” which happen “when an AI [model] so there was no misapplication of the “one central reason” generates fake sources of information.” Id. at 493 (internal standard. quotation marks omitted). We must, of course, disregard Third, Petitioners’ argument is contrary to our decision in Petitioners’ reliance on this case.3 a factually analogous case, Orellana-Recinos. There, gang members repeatedly threatened a mother that she and her So doing, we disagree with Petitioners’ argument son would “pay” if the son refused to join the gang and sell regarding recognition of a particular social group. Although drugs. 993 F.3d at 853 (internal quotation marks omitted).", "ai_tool_named": null, "archive_url": null, "case_name": "Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi", "citation": "2026 WL 412348", "cited_authorities": [ "Rodriguez-Romero v. Garland, 60 F.4th 1283 (10th Cir. 2023)", "Counsel repeatedly cited and quoted a non-existent Tenth Circuit decision captioned 'Rodriguez-Romero v. Garland", "See Wadsworth v. Walmart family membership to the uncle. Inc" ], "court": "United States Court of Appeals for the Tenth Circuit", "court_code": "ca10", "court_level": "federal-appellate", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-13", "decision_id": "ca10-2026-martha-liliana-picon-diaz-v-pamela-j-bondi", "disposition": "The court warned counsel to verify legal authorities before future filings.", "docket_number": "No. 25-9530", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's reply brief contained one citation defect, including Rodriguez-Romero v. Garland, 60 F.4th 1283 (10th Cir. 2023) and Rodriguez-Romero v. Garland, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1517/Picon_Diaz_v._Bondi_USA_13_February_2026.pdf", "state": null, "summary": "Tenth Circuit on 2026-02-13 in Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi found counsel's reply brief contained one citation defect, including Rodriguez-Romero v. Garland, 60 F.4th 1283 (10th Cir. 2023) and Rodriguez-Romero v. Garland, involving nonexistent authorities, fabricated or misattributed quotations. The court warned counsel to verify legal authorities before future filings.", "text_sha256": "3fdc50c18cea4a222bca02503961b0d4aa698b8fea24774f0b93be5fbcdf7993", "topics": [ "fabricated-citations" ], "tracker_slug": "martha-liliana-picon-diaz-et-al-v-pamela-j-bondi", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/ca10-2026-martha-liliana-picon-diaz-v-pamela-j-bondi", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca10-2026-martha-liliana-picon-diaz-v-pamela-j-bondi" }, { "ai_passage": "N.W.2d 811 2016 ND 198 N.W.2d 807, 811 N.W.2d 399 (Wis. Ct. App. 2016) [¶17] Like our sister states, we view the use of AI- [¶15] The record also shows Helgeson submitted false related technology as a means of improving access to citations to the district court. Helgeson does not defend or explain his use of fictitious cases, but instead argues the courts. See, e.g., Illinois Supreme Court, Policy on the City's brief contains incorrect citations. He correctly Artificial Intelligence (2024) (noting the use of AI can improve access to justice and “should not be discouraged” claims the appellee's brief miscites State v. Kovalevich, 2023 if it is reviewed and falls within ethical guidelines); Chief ND 206, 997 N.W.2d 628, as a 2003 case, and People v. Justice G. Richard Bevan, AI in the Courts: Balancing Marshall, 73 Mich.App. 97, 250 N.W.2d 557 (1976) as Tradition and Innovation, Idaho State Bar (Dec. 29, a 1994 case. He makes other meritless claims against the 2025), https://isb.idaho.gov/blog/ai-in-the-courts-balancing- City, alleging citation errors. Helgeson wrongly argues we tradition-and-innovation-by-chief-justice-g-richard-bevan should “disregard Appellee's claim that Appellant relied on (“We cannot ignore technology that may serve people better nonexistent authority” because of citation errors in the City's brief. or help us work more efficiently.”); Willis v. U.S. Bank Nat'l Ass'n as Tr., Igloo Series Trust, 783 F. Supp. 3d 959, 960 (N.D. [¶16] This Court does not appreciate the extra work caused by Tex. 2025) (“AI is a powerful tool, that when used prudently, erroneous citations contained in any party's brief. However, provides immense benefits.’ AI also ‘may ultimately prove a the errors in Helgeson's brief go far beyond a mistake in helpful tool to assist pro se litigants in bringing meritorious citation. Five of his cases are fictitious. “Fake or nonexistent cases to the courts,’ ....”). legal citations typically are the result of AI ‘hallucinations.’ ” Mezu v. Mezu, 267 Md.App. 354, 346 A.3d 181, 189 (2025) *5 [¶18] That said, the use of technology, especially (citing Noland v. Land of the Free, L.P., 114 Cal.App.5th developing technology like AI, requires careful use and 426, 336 Cal. Rptr. 3d 897, 911 (2025)). By this statement scrupulous verification of the arguments and authorities and citation, we do not criticize the use of AI or AI-assisted generated by anyone using the tool. Evenstad v. Buchholz, tools. To the contrary, we encourage and embrace the use 1997 ND 141, ¶ 8, 567 N.W.2d 194 (“[O]ur statutes and of technology to improve the work product of all litigants, rules on procedure will not be modified or applied differently whether represented or self-represented. merely because a party not learned in the law is acting pro se.”). For our purposes here, it does not matter whether Helgeson's fictitious cases and erroneous citations were AI- generated or the result of careless work. Rather, regardless City of Dickinson v. Helgeson, --- N.W.3d ---- (2026) 2026 ND 34 noncriminal, and the district court did not abuse its discretion", "ai_tool_named": null, "archive_url": null, "case_name": "City of Dickinson v. Helgeson", "citation": "2026 WL 392303", "cited_authorities": [ "State v. Clark, 2012 ND 135, 818 N.W.2d 739", "State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977)", "s brief. || Fabricated: Case Law | Court identified the citation State v. Clark, 2022 ND 85 999 N.W.2d 632 in Helgeson", "State ex rel. Olson v. City of Fargo, 250 N/A", "State v. $44,140.00 U.S. Currency, 2003 ND 28, 657 N.W.2d 829", "State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697", "State v. Clark, 2022 ND 85, 999 N.W.2d 632", "State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829", "s brief as a non-existent or incorrect citation and treated it as fictitious. || Fabricated: Case Law | Court noted", "as offered by Helgeson did not correspond to the cited authorities and was treated as a nonexistent/misleading citation. || Fabricated: Case Law | Court found", "in Helgeson", "State v. Kovalevich, 2023 if it is reviewed and falls within ethical guidelines)" ], "court": "Supreme Court of North Dakota", "court_code": "nd", "court_level": "state-supreme", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-12", "decision_id": "nd-2026-city-of-dickinson-v-helgeson", "disposition": "The court ordered the self-represented party to pay $500 for the defective authorities.", "docket_number": "No. 20250340", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's appellee brief contained 15 citation defects, including Olson v. City and Stenehjem v. FreeEats.com Inc, involving nonexistent authorities, mischaracterized authority.", "currency": "USD", "monetary_penalty": 500, "outcome": "fine" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1488/City_of_Dickinson_v_Helgeson.pdf", "state": "ND", "summary": "Supreme Court of North Dakota on 2026-02-12 in City of Dickinson v. Helgeson found the self-represented party's appellee brief contained 15 citation defects, including Olson v. City and Stenehjem v. FreeEats.com Inc, involving nonexistent authorities, mischaracterized authority. The court ordered the self-represented party to pay $500 for the defective authorities.", "text_sha256": "ff04de1fc1b02f9cd15cae3cdae98ceb95cbfed38d9d1f784c3ff3d9d95f7ebe", "topics": [ "fabricated-citations" ], "tracker_slug": "city-of-dickinson-v-helgeson", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/nd-2026-city-of-dickinson-v-helgeson", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nd-2026-city-of-dickinson-v-helgeson" }, { "ai_passage": "conduct was reasonable under the circumstances.\" Brown 175 F.R.D. 508, 510 n.1 (N.D. Ill. 1997). Confirming that v. Fed'n of State Med. Boards of the U.S., 830 F.2d 1429, a case is good law is a basic, routine matter and something 1435 (7th Cir. 1987) (collecting cases), overruled on other that is expected from a practicing attorney. As noted in the grounds by Mars Steel Corp. v. Cont'l Bank N.A., 880 F.2d 928 case of an expert witness, an individual's \"citation to fake, (7th Cir. 1989). One specific inquiry for determining whether AI-generated sources...shatters his credibility.\" See Kohls v. sanctions are appropriate is \"whether the party or attorney Ellison, 2025 WL 66514, at *4 (D. Minn. Jan. 10, 2025). made a reasonable inquiry into the law.\" Brown, 830 F.2d at The same is true even if the fake citations were somehow 1435, see Fed. R. Civ. P. 11(b)(2). Indeed: generated without the knowing use of AI. Mr. Policchio admits that he did not make the requisite Rule 11 requires counsel to study the reasonable inquiry into the law before filing his brief. law before representing its contents to Whether or not AI was the genesis of the non-existent a federal court. An empty head but citations, Mr. Policchio's failure to review them before a pure heart is no defense. The Rule submitting them to the court was a clear violation of Rule 11. requires counsel to read and consider See United States v. Hayes, 763 F. Supp. 3d 1054, 1066-67 before litigating. Counsel who puts the (E.D. Cal. 2025), reconsideration denied, No. 2:24-cr-0280- burden of study and illumination on DJC, 2025 WL 1067323 (E.D. Cal. Apr. 9, 2025) (\"The the defendants or the court must expect Court need not make any finding as to whether Mr. Francisco to pay attorneys' fees under the Rule. actually used generative AI to draft any portion of his motion and reply, including the fictitious case and quotation....Citing nonexistent case law or misrepresenting the holdings of a case is making a false statement to a court. It does not matter if Thornton v. Wahl, 787 F.2d 1151, 1154 (7th Cir. 1986) generative AI told you so.\") (citations and quotations marks (citations omitted). omitted). As the court in Johnson v. Dunn, 792 F. Supp. 3d 1241, 1256-57 (N.D. Ala. 2025), aptly put it: Courts have consistently held for decades that failing to check the treatment and soundness—let alone the existence Every lawyer knows that citing fake cases in a court filing is —of a cited case warrants sanctions. See, e.g., Salahuddin a terrible decision. No one here is attempting to defend it. In v. Coughlin, 999 F. Supp. 526, 529 (S.D.N.Y. 1998) (noting the few years that generative AI has affected court filings, that Shepardizing would have led defense counsel to a key it has become well established that \"[m]any harms flow case); Brown v. Lincoln Towing Serv., No. 88C0831, 1988 from the submission of fake opinions.\" Mata v. Avianca, WL 93950 (N.D. Ill. 1988) (imposing sanctions where the Inc., 678 F. Supp. 3d 443, 448 (S.D.N.Y. 2023); see, e.g., attorney filed a claim based on an expired federal statute); Dehghani v. Castro, No. 2:25-cv-00052-MIS-DLM, 782 Pravic v. U.S. Indus.-Clearing, 109 F.R.D. 620, 623 (E.D. F.Supp.3d 1051 (D.N.M. May 9, 2025); Bevins v. Colgate- Mich. 1986) (holding that the act of relying on another Palmolive Co., No. 25-576, 2025 WL 1085695 (E.D. Pa. attorney's memorandum without Shepardizing the cases cited Apr. 10, 2025); Ferris v. Amazon.com Servs., LLC, No. warranted sanctions); Blake v. Nat'l Cas. Co., 607 F. Supp. 3:24-cv-304-MPM-JMV, 778 F.Supp.3d 879 (N.D. Miss. 189, 191 (C.D. Ca. 1984) (in imposing sanctions, noting Apr. 16, 2025); United States v. Hayes, 763 F. Supp.", "ai_tool_named": null, "archive_url": null, "case_name": "Virgil v. Experian Information Solutions, et al.", "citation": "2026 WL 401066", "cited_authorities": [ "Counsel cited Myers v. Passport Health, 2013 WL 5819270", "Counsel cited Schuh v. American Express Bank", "Counsel cited Merriman v. Equifax Info. Servs", "Counsel cited Treece v. Perrillo, No. 1:17-cv-00406, 2018 WL 3815004", "Counsel cited Armstrong v. Kroger Co", "Counsel cited Hinkle v. CBE Grp", "Counsel cited Wigington v. Hill-Soberg Co", "Counsel cited Jenkins v. Equifax Info. Servs", "Counsel cited Rodriguez v. Pasquarella, 2019 WL 2411480", "Counsel cited Harris v. Mexican Specialty Foods", "Counsel cited Wright v. Experian Info. Sols", "Counsel cited King v. Gen. Info. Servs" ], "court": "United States District Court for the Southern District of Indiana", "court_code": "insd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-12", "decision_id": "insd-2026-virgil-v-experian-information-solutions", "disposition": "The court referred counsel to disciplinary authorities for the defective citations.", "docket_number": "No. 1:25-cv-01641-MPB-MJD", "document_type": "report-and-recommendation", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief contained 15 citation defects, including Myers v. Passport Health, 2013 WL 5819270, Schuh v. American Express Bank and Merriman v. Equifax Info. Servs, involving nonexistent authorities, fabricated or misattributed quotations.", "currency": null, "monetary_penalty": null, "outcome": "referral" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1498/SETH_CAMERON_VIRGIL_Plaintiff_v_EXPERIAN_INFORMATION_SOLUTIONS_INC_et_al_D.pdf", "state": "IN", "summary": "Southern District of Indiana on 2026-02-12 in Virgil v. Experian Information Solutions, et al. found counsel's brief contained 15 citation defects, including Myers v. Passport Health, 2013 WL 5819270, Schuh v. American Express Bank and Merriman v. Equifax Info. Servs, involving nonexistent authorities, fabricated or misattributed quotations. The court referred counsel to disciplinary authorities for the defective citations.", "text_sha256": "5c653e36fcea2806941e0c669ad7ababf433cc10aefd32096eca8d51f4f0618c", "topics": [ "fabricated-citations" ], "tracker_slug": "virgil-v-experian-information-solutions-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/insd-2026-virgil-v-experian-information-solutions", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/insd-2026-virgil-v-experian-information-solutions" }, { "ai_passage": "standing as government actors in their efforts.” Deville v. Specialized Loan Servicing, LLC, 2020 WL 13267725, at *5 (C.D. Cal. Sept. 9, 2020). Finally, the problems are not just substantive. Seifert’s Complaint appears to contain fabricated or hallucinated case citations. For example, Seifert cites “McGinnis v. GMAC Mortg. Corp., 2013 WL 1282124 (D. Colo.).” Dkt. 1-2, at 6. However, 2013 WL 1282124 is not a case called McGinnis v. GMAC Mortgage Corp., nor is it from the District of MEMORANDUM DECISION AND ORDER - 7 Case 4:25-cv-00645-DCN Document 15 Filed 02/12/26 Page 8 of 10", "ai_tool_named": null, "archive_url": null, "case_name": "Seifert v. Nationstar Mortgage LLC, et al.", "citation": null, "cited_authorities": [ "McGinnis v. GMAC Mortg. Corp., 2013 WL 1282124 (D. Colo.)", "McGinnis v. GMAC Mortg. Corp., 2013 WL 1282124", "Deville v. Specialized Loan Servicing", "WL 1282124 is not a case called McGinnis v. GMAC Mortgage Corp" ], "court": "United States District Court for the District of Idaho", "court_code": "idd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-12", "decision_id": "idd-2026-seifert-v-nationstar-mortgage", "disposition": "The court granted the dismissal motions and judicial-notice request, dismissed the complaint without prejudice, and allowed an amended complaint.", "docket_number": "Case 4:25-cv-00645-DCN", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "litigant-in-person", "ai_tool": null, "conduct": "The self-represented party's response cited McGinnis v. GMAC Mortgage for propositions the court found fabricated or hallucinated.", "currency": null, "monetary_penalty": null, "outcome": "other" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1516/Seifert_v._Nationstar_Mortgage_USA_12_February_2026.pdf", "state": "ID", "summary": "District of Idaho on 2026-02-12 in Seifert v. Nationstar Mortgage LLC, et al. found the self-represented party's response cited McGinnis v. GMAC Mortgage for propositions the court found fabricated or hallucinated. The court granted the dismissal motions and judicial-notice request, dismissed the complaint without prejudice, and allowed an amended complaint.", "text_sha256": "41a973bf273001c2139355c2c381c30d4dd14cfdb6e6ca7a7d3aa448766bd730", "topics": [ "fabricated-citations" ], "tracker_slug": "seifert-v-nationstar-mortgage-llc-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/idd-2026-seifert-v-nationstar-mortgage", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/idd-2026-seifert-v-nationstar-mortgage" }, { "ai_passage": "intelligence) tool, CoCounsel, in preparing the supplemental protest. Resp. to GAO at 1. The protester’s attorneys expressly acknowledged that “some of the citations the AI tool indicates that he identified some irregularities and attempted to correct them, the attorney admittedly failed to correct all the erroneous citations in the final supplemental protest filed with our Office. Id. at 1-2. CVTEK’s counsel apologized and took full responsibility for the errors, explaining that new protocols have been implemented to ensure that “all case citations will be manually verified.” Id. at 2-3; Supp. Resp. to GAO at 1-2. As the courts and our forum have explained, “there is nothing inherently wrong with . . . properly and competently utilizing AI or any of its subsets to practice law or litigate cases,” but that “the evolving technology has many glitches (including hallucinations) and does not always work properly or as expected,” and “[t]his is why close and careful attorney supervision, fact-checking, and citation-checking are absolute necessities 8 Moreover, our Office generally does not review an affirmative determination of responsibility absent a showing of failure to properly apply definitive responsibility criteria, or where the protester identifies evidence raising serious concerns that, in reaching the responsibility determination, the agency unreasonably failed to consider available relevant information or otherwise violated statute or regulation. 4 C.F.R. § 21.5(c); Bannum, Inc., B-408838, Dec. 11, 2013, 2013 CPD ¶ 288 at 4. Page 9 B-423943; B-423943.2 when utilizing AI or any of its subsets.” KE Sys. Servs., Inc., B-423881 et al., Dec. 22, 2025, at 6; Oready, LLC, B-423524.2, Aug. 13, 2025, 2025 CPD ¶ 194 at 7 (both citing Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enters., LLC, No. 17-cv- 81140, 2025 U.S. Dist. LEXIS 98418 at *11 (S.D. Fl. May 20, 2025). In order to satisfy our statutory mandate to resolve protests expeditiously and to maintain our role as a meaningful, efficient protest forum, we expect all parties to prepare and present their cases carefully and diligently. Wolverton Prop. Mgmt., LLC-- Recon., B-415295.4, June 6, 2018, 2018 CPD ¶ 205 at 3. The use of AI tools to draft or assist in drafting legal filings can result in the citation of non-existent decisions, such that reliance on those programs without review for accuracy wastes the time of all parties and GAO. Raven Investigations & Sec. Consulting, LLC, B-423447, May 7, 2025, 2025 CPD ¶ 81 at 4. As we have explained, our Office necessarily reserves an inherent right to dismiss any protest and to impose sanctions against a protester, where a protester’s actions undermine the integrity and effectiveness of our process. Id. Here, because we deny this protest, we do not exercise our right to impose sanctions for submission of non- existent citations. The protester, however, is advised that any future submission of filings to our Office with citations to non-existent authority may, after a review of the totality of the circumstances, result in the imposition of sanctions. The protest is denied. Edda Emmanuelli Perez General Counsel", "ai_tool_named": "Westlaw CoCounsel", "archive_url": null, "case_name": "CVTEK, LLC (B-423943; B-423943.2)", "citation": null, "cited_authorities": [ "Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enters", "4 C.F.R. § 21.5(c)" ], "court": "Government Accountability Office", "court_code": null, "court_level": "federal-specialty", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-12", "decision_id": "gao-2026-cvtek", "disposition": "The court warned counsel to verify legal authorities before future filings.", "docket_number": "B-423943; B-423943.2", "document_type": "opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": "Westlaw CoCounsel", "conduct": "Counsel's filing contained two citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1541/CVTEK_LLC.pdf", "state": null, "summary": "Government Accountability Office on 2026-02-12 in CVTEK, LLC (B-423943; B-423943.2) found counsel's filing contained two citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court warned counsel to verify legal authorities before future filings in the challenged filing before resolving the pending matter.", "text_sha256": "ee69e4d95e088d07f19fc4c0041321646cedf9f6605de77778f4812f42730a8e", "topics": [ "fabricated-citations" ], "tracker_slug": "cvtek-llc-b-423943-b-423943-2", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/gao-2026-cvtek", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/gao-2026-cvtek" }, { "ai_passage": "apparently even an awareness that they were present in the what steps to take with respect to the Motion and with respect brief—is equally troubling; it suggests he did not review the to sanctions. authority cited before he filed the Reply under his signature or before he appeared to argue the Motion. IT IS SO ORDERED No later than February 19, 2026, Mr. Charnley is cc: Counsel of Record ordered to show cause why he should not be sanctioned (either monetarily, or by the striking of his pleading) Initials of Preparer: ch under Rule 11, 28 U.S.C. § 1927, or the Court's inherent include an explanation for the inclusion of nonexistent legal", "ai_tool_named": null, "archive_url": null, "case_name": "TQJ, LLC v. Jennifer Esquivel et al.", "citation": "2026 WL 395737", "cited_authorities": [ "Steele v. County of San Mateo", "Kogan v. Martin", "United States v. De La Paz", "Rule 11" ], "court": "United States District Court for the Central District of California", "court_code": "cacd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-12", "decision_id": "cacd-2026-tqj-v-jennifer-esquivel", "disposition": "The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "docket_number": "Case No.: 2:25-cv-09673-BFM", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's brief cited four defective authorities, including Steele v. County of San Mateo, Kogan v. Martin, and a Muller citation the court could not locate.", "currency": null, "monetary_penalty": null, "outcome": "pending" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1500/TQJ_LLC_v_Jennifer_Esquivel_et_al.pdf", "state": "CA", "summary": "Central District of California on 2026-02-12 in TQJ, LLC v. Jennifer Esquivel et al. found counsel's brief cited four defective authorities, including Steele v. County of San Mateo, Kogan v. Martin, and a Muller citation the court could not locate. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.", "text_sha256": "72f97de5984202a8df9489639680b4fba3283752f66f5874eaa1e828497bfb4a", "topics": [ "fabricated-citations" ], "tracker_slug": "tqj-llc-v-jennifer-esquivel-et-al", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/cacd-2026-tqj-v-jennifer-esquivel", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/cacd-2026-tqj-v-jennifer-esquivel" }, { "ai_passage": "1 Docket 14. 2 Docket 20. 3 Docket 22. 4 Additionally, Defendants have provided a list identifying 17 cases cited by Plaintiff that “quote language that does not exist in the case,” including one where the language is correct but from a different case. Docket 23-1. The rapid development of artificial intelligence (“AI”) requires caution in the context of legal research. The Court recommends that attorneys also follow the guidance provided to the judiciary, that AI systems should be used only to perform tasks that can be easily verified for accuracy and involve public data or nonconfidential and nonsensitive information. 5 Accordingly, the Court refers to plural “Defendants” in this Order.", "ai_tool_named": null, "archive_url": null, "case_name": "Andre Legarza v. Northern Star (Alaska), Inc.", "citation": "2026 WL 396509", "cited_authorities": [ "s filings that" ], "court": "United States District Court for the District of Alaska", "court_code": "akd", "court_level": "federal-district", "court_used_ai": false, "courtlistener_url": null, "date_filed": "2026-02-12", "decision_id": "akd-2026-andre-legarza-v-northern-star", "disposition": "The court warned counsel to verify legal authorities before future filings.", "docket_number": "No. 3:24-cv-0007-HRH", "document_type": "memorandum-opinion", "fetched_at": "2026-09-07T14:34:42-07:00", "incident": { "actor": "lawyer", "ai_tool": null, "conduct": "Counsel's filing contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority.", "currency": null, "monetary_penalty": null, "outcome": "warning" }, "lead_source": [ "charlotin-cc0" ], "notes": "official copy pending", "primary_topic": "fabricated-citations", "source_url": "https://www.damiencharlotin.com/documents/1487/ANDRE_LEGARZA_Plaintiff_v_NORTHERN_STAR_ALASKA_INC_dba_NORTHERN_STAR_RES.pdf", "state": "AK", "summary": "District of Alaska on 2026-02-12 in Andre Legarza v. Northern Star (Alaska), Inc. found counsel's filing contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned counsel to verify legal authorities before future filings.", "text_sha256": "f78461b2955af864ffc543d47384be4fbf4091cf335e576be2d7d0f40f7bb85c", "topics": [ "fabricated-citations" ], "tracker_slug": "andre-legarza-v-northern-star-alaska-inc", "verification": "mirror-read", "url": "https://safelegalai.com/courts/opinions/akd-2026-andre-legarza-v-northern-star", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/akd-2026-andre-legarza-v-northern-star" }, { "court_code": "mied", "state": "MI", "citation": "2026 WL 373043", "docket_number": "2:24-cv-12333-GAD-APP", "ai_tool_named": "ChatGPT", "incident": null, "tracker_slug": null, "courtlistener_url": "https://storage.courtlistener.com/recap/gov.uscourts.mied.379552/gov.uscourts.mied.379552.94.0.pdf", "text_sha256": "8eecb063d437dfbaeb9b8efaf548783a7498ef2ccb1394e2280663a79788a5cf", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "Court-authored public-domain PDF was read from CourtListener storage; no separate CourtListener opinion page was captured.", "decision_id": "mied-2026-warner-v-gilbarco", "case_name": "Warner v. Gilbarco, Inc.", "court": "U.S. District Court for the Eastern District of Michigan", "court_level": "federal-district", "date_filed": "2026-02-10", "document_type": "order", "topics": [ "privilege-work-product", "discovery-ediscovery" ], "primary_topic": "privilege-work-product", "court_used_ai": false, "disposition": "The court denied defendants’ request for documents about the plaintiff’s AI use and sustained work-product protection for AI materials.", "ai_passage": "To the extent Defendants seek production of “all documents and information concerning her use of third-party AI tools in connection with this lawsuit, as requested in Defendants’ discovery requests,” this request is DENIED, as the information sought is not discoverable. See Fed. R. Civ. P. 26(b)(3)(A) (“Ordinarily, a party may not discover documents and tangible things that are prepared in anticipation of litigation or for trial by another party or its representative ….”) (emphases added). Moreover, it is not relevant, or, even if marginally relevant, is not proportional. See Fed. R. Civ. P. 26(b)(1). ... Even if this information were discoverable, it is subject to protection under the work-product doctrine, which Plaintiff is permitted to assert. ... Moreover, to the extent Defendants argue that Plaintiff waived the work-product protection by using ChatGPT, the work-product waiver has to be a waiver to an adversary or in a way likely to get in an adversary’s hand. In re Columbia/HCA Healthcare Corp. Billing Pracs. Litig., 293 F.3d 289, 306 n.28 (6th Cir. 2002) ... And ChatGPT (and other generative AI programs) are tools, not persons, even if they may have administrators somewhere in the background.", "cited_authorities": [ "Fed. R. Civ. P. 26(b)(3)(A)", "Fed. R. Civ. P. 26(b)(1)", "Anderson v. Furst, No. 2:17-12676, 2019 WL 2284731 (E.D. Mich. May 29, 2019)", "In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289 (6th Cir. 2002)", "Schanfield v. Sojitz Corp. of America, 258 F.R.D. 211 (S.D.N.Y. 2009)", "United States v. American Telephone & Telegraph Co., 642 F.2d 1285 (D.C. Cir. 1980)" ], "summary": "On 2026-02-10, the Eastern District of Michigan denies defendants’ bid to compel a pro se plaintiff’s AI-use materials. The court holds the requested materials are not discoverable and, in any event, are protected work product; using ChatGPT does not waive that protection.", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.mied.379552/gov.uscourts.mied.379552.94.0.pdf", "verification": "mirror-read", "lead_source": [ "CourtListener storage mirror", "keyword sweep" ], "url": "https://safelegalai.com/courts/opinions/mied-2026-warner-v-gilbarco", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/mied-2026-warner-v-gilbarco" }, { "decision_id": "ark-rule-221-2025", "case_name": "In re Amendments to the Arkansas Rules of Professional Conduct", "court": "Supreme Court of Arkansas", "court_level": "state-supreme", "state": "AR", "date_filed": "2025-12-11", "citation": "2025 Ark. 221", "docket_number": null, "document_type": "opinion", "topics": [ "rules-by-opinion" ], "primary_topic": "rules-by-opinion", "court_used_ai": false, "disposition": "The court adopted AI-related amendments to the Arkansas Rules of Professional Conduct effective immediately.", "ai_passage": "On June 5, 2025, we published proposed amendments to the Arkansas Rules of Professional Conduct addressing the impact of the expansion of artificial intelligence for the legal practice in Arkansas. See In re Amends. to the Ark. Rules of Prof’l Conduct, 2025 Ark. 115 (per curiam). The amendments add a paragraph to the Preamble and alter the heading of Rule 5.3 of the Arkansas Rules of Professional Conduct. The comment period closed, and we now adopt these amendments effective immediately. The amendments are shown in “line-in, line-out” form. PREAMBLE ... [22] Unless otherwise specified, nothing in these rules prohibits an attorney’s use of non- human assistance, including, but not limited to, artificial intelligence (AI). However, the use of non-human assistance does not excuse or mitigate any violation of the rules that occurs from using such assistance. Please be advised of Administrative Order No. 25 before using AI. RULE 5.3. RESPONSIBILITIES REGARDING NONLAWYER ASSISTANTSASSISTANCE. With respect to a nonlawyer assistance, employed or retained by or associated with a lawyer: (a) a partner, and a lawyer who individually or together with other lawyers possesses comparable managerial authority in a law firm, shall make reasonable efforts to ensure that the firm has in effect measures giving reasonable assurance that the nonlawyer assistance person’s conduct is compatible with the professional obligations of the lawyer; (b) a lawyer having direct supervisory authority over the nonlawyer assistance shall make reasonable efforts to ensure that the nonlawyer assistance person’s conduct is compatible with the professional obligations of the lawyer; and (c) a lawyer shall be responsible for conduct of such a person a nonlawyer assistance that would be a violation of the rules of professional conduct if engaged in by a lawyer if: (1) the lawyer orders or, with the knowledge of the specific use or conduct, ratifies the use or conduct involved; or (2) the lawyer is a partner or has comparable managerial authority in the law firm in which the nonlawyer assistance person is used employed, or has the direct supervisory authority over the use over the person, and knows of the conduct or use at a time when its consequences can be avoided or mitigated but fails to take reasonable remedial action. Comment: For purposes of this Rule, “nonlawyer assistance” includes services performed by human personnel and by technological tools such as generative artificial intelligence platforms.", "cited_authorities": [ "In re Amends. to the Ark. Rules of Prof’l Conduct, 2025 Ark. 115", "Arkansas Supreme Court Administrative Order No. 25" ], "summary": "The Arkansas Supreme Court adopts professional-conduct amendments addressing lawyers’ use of artificial intelligence and other nonhuman assistance. The amendments say AI use is not barred but does not excuse rule violations, and Rule 5.3 supervision includes generative-AI platforms.", "lead_source": [ "Arkansas court site search" ], "court_code": null, "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "ff66c223b1ebecf62fabad3888f456fed24c47290ee14b442eedd8bdd77c2b5e", "source_url": "https://opinions.arcourts.gov/ark/supremecourt/en/524044/1/document.do", "archive_url": "https://web.archive.org/web/20260907215115/https://opinions.arcourts.gov/ark/supremecourt/en/524044/1/document.do", "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/ark-rule-221-2025", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ark-rule-221-2025" }, { "decision_id": "ark-rule-220-2025", "case_name": "In re Adoption of Arkansas Supreme Court Administrative Order No. 25. Artificial Intelligence", "court": "Supreme Court of Arkansas", "court_level": "state-supreme", "state": "AR", "date_filed": "2025-12-11", "citation": "2025 Ark. 220", "docket_number": null, "document_type": "opinion", "topics": [ "rules-by-opinion" ], "primary_topic": "rules-by-opinion", "court_used_ai": false, "disposition": "The court adopted Administrative Order No. 25 on artificial intelligence effective immediately.", "ai_passage": "On June 5, 2025, we published for comment a proposed Administrative Order No. 25: Artificial Intelligence. It specifically addressed the use of generative artificial intelligence with confidential court data. See In re Creation of Ark. Sup. Ct. Admin. Order No. 25, 2025 Ark. 117 (per curiam). The comment period closed without substantive comments. The court adopts Administrative Order No. 25 as provided below effective immediately. Order 25. Artificial Intelligence. Section 1. Awareness. Everyone participating in the court system must be mindful of the following when entering client or court data into any electronic system that generates responses or uses generative artificial intelligence (GAI): (a) Certain GAI tools retain the data submitted into their system and use it to keep building their large language models (LLM), or what you would consider their database. (b) Anyone who enters confidential or sealed information into a GAI should determine whether the system is retaining and using the confidential or sealed data. A public LLM is accessible to anyone", "cited_authorities": [ "In re Creation of Ark. Sup. Ct. Admin. Order No. 25, 2025 Ark. 117" ], "summary": "The Arkansas Supreme Court adopts Administrative Order No. 25 after a comment period with no substantive comments. The new order requires court participants to consider confidentiality and data-retention risks before entering court or client data into generative-AI systems.", "lead_source": [ "Arkansas court site search", "user brief" ], "court_code": null, "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "9c45af9538d4b295390c54577442a7eb968868d3a839d67e140c76fa4e20fa87", "source_url": "https://opinions.arcourts.gov/ark/supremecourt/en/524043/1/document.do", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/ark-rule-220-2025", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ark-rule-220-2025" }, { "court_code": "wawd", "state": "WA", "citation": null, "docket_number": "2:24-cv-01625-DGE-SKV", "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": "https://storage.courtlistener.com/recap/gov.uscourts.wawd.340099/gov.uscourts.wawd.340099.59.0.pdf", "text_sha256": "96824e203289171e4bddc5f318298fea75dd610dd518ca2f645f7a834b01cb22", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "Court-authored public-domain PDF was read from CourtListener storage; no separate CourtListener opinion page was captured.", "decision_id": "wawd-2025-kirkham-v-city-of-bellingham", "case_name": "Kirkham v. City of Bellingham", "court": "U.S. District Court for the Western District of Washington", "court_level": "federal-district", "date_filed": "2025-10-09", "document_type": "order", "topics": [ "evidence-authentication" ], "primary_topic": "evidence-authentication", "court_used_ai": false, "disposition": "The court denied appointment of counsel and a neutral expert, finding the Rule 706 request premature and unsupported.", "ai_passage": "Plaintiff raises claims relating to events leading up to and occurring on the date of his September 2023 arrest by officers of the Bellingham Police Department. See Dkt. 38. He asserts, as central to his claims and relevant to the pending motions, that Defendants engaged in a conspiracy to intentionally assault him and then alter the footage of body-worn cameras (BWC) using artificial intelligence (AI) to create “deepfake” video footage to conceal their misconduct and avoid accountability. ... Plaintiff argues the appointment of a neutral expert is warranted because: (1) the authenticity of the BWC footage cannot be determined without a forensic examination, and the expert will therefore assist the trier of fact and promote accurate fact finding; (2) his sworn complaint attesting that the footage was altered and Defendants’ denial of the same is evidence of a serious dispute than can be resolved through expert testimony; ... The Court notes, as an initial matter, a lack of clarity as to the complexity of the issues in this case. Plaintiff rests his assertion of complexity on his allegations of evidence tampering. However, as reflected in the discussion above, Plaintiff lacks any evidence other than his own assertions that evidence tampering has occurred. Rule 706 does not provide for the appointment of an expert to assist Plaintiff in developing or proving those assertions.", "cited_authorities": [ "Fed. R. Evid. 706", "Williams v. Lawson, No. C21-5536-MJP, 2023 WL 8545277 (W.D. Wash. Dec. 11, 2023)", "Wilkins v. Barber, 562 F. Supp. 3d 943 (E.D. Cal. 2021)" ], "summary": "On 2025-10-09, the Western District of Washington denies requests for counsel and a neutral expert. The plaintiff alleged police used AI to create deepfake body-camera footage, but the court found only assertions of tampering and ruled Rule 706 did not support appointing an expert at that stage.", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.wawd.340099/gov.uscourts.wawd.340099.59.0.pdf", "verification": "mirror-read", "lead_source": [ "CourtListener storage mirror", "keyword sweep" ], "url": "https://safelegalai.com/courts/opinions/wawd-2025-kirkham-v-city-of-bellingham", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/wawd-2025-kirkham-v-city-of-bellingham" }, { "court_code": "nvd", "state": "NV", "citation": null, "docket_number": "2:25-cv-00504-JAD-EJY", "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": "https://storage.courtlistener.com/recap/gov.uscourts.nvd.173684/gov.uscourts.nvd.173684.107.0.pdf", "text_sha256": "6056da0cd7562d4d55a2df284f2b7ab725b93a693621c7984072b00d632fa1d5", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "Court-authored public-domain PDF was read from CourtListener storage; no separate CourtListener opinion page was captured.", "decision_id": "nvd-2025-demissie-v-ford", "case_name": "Demissie v. Ford", "court": "U.S. District Court for the District of Nevada", "court_level": "federal-district", "date_filed": "2025-10-07", "document_type": "order", "topics": [ "evidence-authentication", "discovery-ediscovery" ], "primary_topic": "evidence-authentication", "court_used_ai": false, "disposition": "The court denied the emergency protective-order motion and ordered the deposition to proceed.", "ai_passage": "The Motion argues that Plaintiff’s deposition cannot proceed because Plaintiff has a pending Motion for Terminating Sanctions (ECF No. 71) alleging fraud on the Court based on the unrelenting theme that Las Vegas Metropolitan Police Department (“Metro”) produced fabricated body worn camera footage. Id. at 1. Plaintiff further contends Metro is withholding critical discovery including “Detective Lea’s ‘Order-Out Corridor’ recommendation to prosecutors”; “[s]pecifications and grounds for … [his] placement on the ‘Order-Out Corridor’ list”; “[d]atabase logs showing agencies/officers who accessed … [his] record”; and “[u]naltered, native BWC [body worn camera] footage from Officer West’s interactions with Flamingo employee.” Id. at 3-4. Plaintiff attacks the credibility of opposing counsel’s representations and states “he knows for a fact” that the already produced body worn footage is altered. Id. at 7. Plaintiff fears his “video- or audio-recorded deposition could likewise be manipulated to prejudice” him. ... It is worth noting that the Court’s review of Plaintiff’s Motion for Terminating Sanctions appears to be based on Plaintiff’s asserted “belief” that Metro has altered body worn camera; however, Plaintiff provides no reliable evidence that the camera footage contains deepfake edits or other alteration.", "cited_authorities": [ "Fed. R. Civ. P. 26(c)(1)" ], "summary": "On 2025-10-07, the District of Nevada denies a protective order seeking to postpone a deposition. The plaintiff alleged produced body-worn camera footage contained deepfake edits and feared a recorded deposition could be manipulated, but the court found no reliable evidence of alteration.", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.nvd.173684/gov.uscourts.nvd.173684.107.0.pdf", "verification": "mirror-read", "lead_source": [ "CourtListener storage mirror", "keyword sweep" ], "url": "https://safelegalai.com/courts/opinions/nvd-2025-demissie-v-ford", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nvd-2025-demissie-v-ford" }, { "court_code": "ca6", "state": null, "citation": null, "docket_number": "24-5549", "ai_tool_named": "ChatGPT", "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10677708/thomas-smith-v-pam-transp-inc/", "text_sha256": "58134384b615cf29d256f1f4cf83e37c6ca3899189fc0dd4d888b74acb481f93", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": null, "decision_id": "ca6-2025-smith-v-pam-transport", "case_name": "Smith v. P.A.M. Transport, Inc.", "court": "U.S. Court of Appeals for the Sixth Circuit", "court_level": "federal-appellate", "date_filed": "2025-09-25", "document_type": "opinion", "topics": [ "court-ai-use" ], "primary_topic": "court-ai-use", "court_used_ai": true, "disposition": "The court reversed summary judgment and remanded; the majority noted and criticized the concurrence’s ChatGPT inquiry about a disputed phrase.", "ai_passage": "The concurrence cites a ChatGPT inquiry asking, “What does monkey ass mean?” Conc. op. at 22. ChatGPT functions as a consolidator of information, synthesizing patterns from a vast body of text, but it does not independently verify the accuracy of any material or its unknown sources. The information provided in the concurrence’s permalink to Urban Dictionary speaks for itself. ... Does the term “monkey ass,” a phrase understandably not included in traditional dictionaries, have the same racial connotation as the term “monkey”? See Monkey Ass, Urban Dictionary (last visited Sep. 22, 2025), https://perma.cc/RRF9-D7ZC (offering definitions such as “One who acts badly or stupid,” “A stubborn child, esp[ecially] one that exhibits monkey-like traits (e.g. small, agile, and wild),” and “The resultant condition from prolonged periods of poor personal hygiene . . . .”); see also ChatGPT, “What does monkey ass mean?” (Sep. 23, 2025), https://perma.cc/SS32-JRUX (explaining that monkey ass can be “potentially racial (depending on context)” but also an “insult or put-down (non-specific),” “emphasizing someone acting wild or stupid,” or “used in joking or aggressive banter” (citation modified)).", "cited_authorities": [ "ChatGPT, “What does monkey ass mean?” (Sep. 23, 2025)", "Urban Dictionary, “Monkey Ass”" ], "summary": "On 2025-09-25, the Sixth Circuit remands hostile-work-environment claims for trial. The majority notes the concurrence’s ChatGPT inquiry into a workplace slur and warns that ChatGPT consolidates text patterns without verifying sources; the concurrence cites the ChatGPT response among context-specific interpretive materials.", "source_url": "https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0264p-06.pdf", "verification": "fetched-and-read", "lead_source": [ "CourtListener anonymous search", "court site search" ], "url": "https://safelegalai.com/courts/opinions/ca6-2025-smith-v-pam-transport", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca6-2025-smith-v-pam-transport" }, { "decision_id": "kadrey-meta-2025", "case_name": "Kadrey v. Meta Platforms, Inc.", "court": "U.S. District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "state": "CA", "date_filed": "2025-06-25", "citation": "788 F. Supp. 3d 1026", "docket_number": "3:23-cv-03417-VC", "document_type": "order", "topics": [ "substantive-ai-law" ], "primary_topic": "substantive-ai-law", "court_used_ai": false, "ai_tool_named": "Llama", "disposition": "The court denied plaintiffs’ partial-summary-judgment motion and granted Meta’s cross-motion on fair use.", "ai_passage": "Companies are presently racing to develop generative artificial intelligence models— software products that are capable of generating text, images, videos, or sound based on materials they’ve previously been “trained” on. Because the performance of a generative AI model depends on the amount and quality of data it absorbs as part of its training, companies have been unable to resist the temptation to feed copyright-protected materials into their models—without getting permission from the copyright holders or paying them for the right to use their works for this purpose. This case presents the question whether such conduct is illegal.", "cited_authorities": [], "summary": "The Northern District of California grants Meta partial summary judgment on fair use for copying authors’ books to train Llama. The order stresses generative AI’s potential market harms while finding the plaintiffs’ record inadequate to defeat fair use in this case.", "source_url": "https://www.govinfo.gov/content/pkg/USCOURTS-cand-3_23-cv-03417/pdf/USCOURTS-cand-3_23-cv-03417-37.pdf", "lead_source": [ "user brief", "GovInfo search API" ], "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "a86062f7177b6fde88cc9f0178d7b36e6505ef6aac999d7e0cc681188a56a370", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/kadrey-meta-2025", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/kadrey-meta-2025" }, { "decision_id": "bartz-anthropic-2025", "case_name": "Bartz v. Anthropic PBC", "court": "U.S. District Court for the Northern District of California", "court_code": "cand", "court_level": "federal-district", "state": "CA", "date_filed": "2025-06-23", "citation": null, "docket_number": "3:24-cv-05417-WHA", "document_type": "order", "topics": [ "substantive-ai-law" ], "primary_topic": "substantive-ai-law", "court_used_ai": false, "ai_tool_named": "Claude", "disposition": "The court ruled that training uses were fair use but preserved claims over Anthropic’s central library.", "ai_passage": "An artificial intelligence firm downloaded for free millions of copyrighted books in 17 digital form from pirate sites on the internet. The firm also purchased copyrighted books 18 (some overlapping with those acquired from the pirate sites), tore off the bindings, scanned 19 every page, and stored them in digitized, searchable files. All the foregoing was done to amass 20 a central library of “all the books in the world” to retain “forever.” From this central library, 21 the AI firm selected various sets and subsets of digitized books to train various large language 22 models under development to power its AI services. Some of these books were written by 23 plaintiff authors, who now sue for copyright infringement. On summary judgment, the issue is 24 the extent to which any of the uses of the works in question qualify as “fair uses” under 25 Section 107 of the Copyright Act. 26 STATEMENT 27 Defendant Anthropic PBC is an AI software firm founded by former OpenAI employees 28 in January 2021. Its core offering is an AI software service called Claude. When a user Case 3:24-cv-05417-WHA Document 231 Filed 06/23/25 Page 2 of 32 1 prompts Claude with text, Claude quickly responds with text — mimicking human reading and 2 writing. Claude can do so because Anthropic trained Claude — or rather trained large 3 language models or LLMs underlying various versions of Claude — using books and other 4 texts selected from a central library Anthropic had assembled.", "cited_authorities": [], "summary": "The Northern District of California rules on Anthropic’s book copying for Claude and related language models. Judge Alsup distinguishes training from maintaining a central library, finding transformative fair use for training while allowing claims about pirated library retention to proceed.", "lead_source": [ "user brief" ], "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "6422ecba64150f7bd78dfa53c59fd03901b92da2908ffdeab2547da35790e328", "source_url": "https://www.govinfo.gov/content/pkg/USCOURTS-cand-3_24-cv-05417/pdf/USCOURTS-cand-3_24-cv-05417-0.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/bartz-anthropic-2025", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/bartz-anthropic-2025" }, { "decision_id": "ark-rule-117-2025", "case_name": "In re Creation of Arkansas Supreme Court Administrative Order No. 25. Artificial Intelligence", "court": "Supreme Court of Arkansas", "court_level": "state-supreme", "state": "AR", "date_filed": "2025-06-05", "citation": "2025 Ark. 117", "docket_number": null, "document_type": "opinion", "topics": [ "rules-by-opinion" ], "primary_topic": "rules-by-opinion", "court_used_ai": false, "disposition": "The court published proposed Administrative Order No. 25 on artificial intelligence for public comment.", "ai_passage": "The use of AI has become increasingly prominent. Members of the public, attorneys, and personnel who interact in the State’s justice system may be using it intentionally, or even unintentionally. We now publish for comment the proposed new Administrative Order No. 25: Artificial Intelligence. It begins by specifically addressing the use of generative artificial intelligence with confidential court data. The comment period shall end on August 1, 2025. Comments should be submitted in writing to: Kyle E. Burton, Clerk of the Arkansas Supreme Court, Attention: The Creation of Administrative Order No. 25, Justice Building, 625 Marshall Street, Little Rock, AR 72201, or by email: rulescomments@arcourts.gov. The court will consider any submitted comments and make subsequent changes if necessary. Order 25. Artificial Intelligence. Section 1. Awareness. Everyone participating in the court system must be mindful of the following when entering client or court data into any electronic system that generates responses or generative artificial intelligence (GAI): (a) Certain GAI tools retain the data submitted into their system and use it to keep building their large language models (LLM), or what you would consider their database. (b) Anyone who enters confidential or sealed", "cited_authorities": [], "summary": "The Arkansas Supreme Court proposes Administrative Order No. 25, a court-system AI rule focused first on generative-AI use with confidential court data. The opinion invites comments while warning that lawyers, court personnel, and the public may use AI intentionally or inadvertently.", "lead_source": [ "user brief", "Arkansas court site search" ], "court_code": null, "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "e55c1ed8114f541c18660c009eb19663ae4ffb78f7889d1195eb3efdb6a09ec6", "source_url": "https://opinions.arcourts.gov/ark/supremecourt/en/523726/1/document.do", "archive_url": "https://web.archive.org/web/20250624164842/https://opinions.arcourts.gov/ark/supremecourt/en/523726/1/document.do", "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/ark-rule-117-2025", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ark-rule-117-2025" }, { "decision_id": "ark-rule-115-2025", "case_name": "In re Amendments to the Arkansas Rules of Professional Conduct", "court": "Supreme Court of Arkansas", "court_level": "state-supreme", "state": "AR", "date_filed": "2025-06-05", "citation": "2025 Ark. 115", "docket_number": null, "document_type": "opinion", "topics": [ "rules-by-opinion" ], "primary_topic": "rules-by-opinion", "court_used_ai": false, "disposition": "The court published proposed AI-related amendments to the Arkansas Rules of Professional Conduct for comment.", "ai_passage": "In response to the growing use of artificial intelligence, the Supreme Court of Arkansas Committee on Automation created a subcommittee to study the use of artificial intelligence in courts. Likewise, the Arkansas Bar Association formed the Task Force on Artificial Intelligence. The two have worked together to review how the expansion of artificial intelligence impacts legal practice in Arkansas. As the result of this work, the Task Force unanimously recommended the following amendments to the Arkansas Rules of Professional Conduct. This recommendation was approved unanimously by the Arkansas Supreme Court’s Committee on Civil Practice. The amendments add a paragraph to the Preamble and bring the heading of Rule 5.3 in conformity with the Model Rules of Professional Conduct published by the American Bar Association. The amendments are shown in “line-in, line-out” form. We now publish these amendments for comment. The comment period shall end on August 1, 2025.", "cited_authorities": [], "summary": "The Arkansas Supreme Court publishes for comment professional-conduct amendments responding to artificial intelligence in legal practice. The per curiam order describes joint study by court and bar committees and proposes changes clarifying lawyers’ duties when using nonhuman assistance.", "lead_source": [ "Arkansas court site search", "user brief" ], "court_code": null, "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "14983b0182581468e39e64caa36e78e51ab238be9c2bb4525cb40b3b478cb43e", "source_url": "https://opinions.arcourts.gov/ark/supremecourt/en/523724/1/document.do", "archive_url": "https://web.archive.org/web/20250624154249/https://opinions.arcourts.gov/ark/supremecourt/en/523724/1/document.do", "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/ark-rule-115-2025", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ark-rule-115-2025" }, { "decision_id": "thaler-perlmutter-2025", "case_name": "Thaler v. Perlmutter", "court": "U.S. Court of Appeals for the D.C. Circuit", "court_code": "cadc", "court_level": "federal-appellate", "state": null, "date_filed": "2025-03-18", "citation": null, "docket_number": "23-5233", "document_type": "opinion", "topics": [ "substantive-ai-law" ], "primary_topic": "substantive-ai-law", "court_used_ai": false, "ai_tool_named": "Creativity Machine", "disposition": "The court affirmed denial of copyright registration for a work claimed to be authored by a machine.", "ai_passage": "This case presents a question made salient by recent advances in artificial intelligence: Can a non-human machine be an author under the Copyright Act of 1976? The use of artificial intelligence to produce original work is rapidly increasing across industries and creative fields. Who—or what—is the “author” of such work is a question that implicates important property rights undergirding economic growth and creative innovation. In this case, a computer scientist attributes authorship of an artwork to the operation of software. Dr. Stephen Thaler created a generative artificial intelligence named the “Creativity Machine.” The Creativity Machine made a picture that Dr. Thaler titled “A Recent Entrance to Paradise.” Dr. Thaler submitted a copyright registration application for “A Recent Entrance to Paradise” to the United States Copyright Office. On the application, Dr. Thaler listed the Creativity Machine as the work’s sole author and himself as just the work’s owner. The Copyright Office denied Dr. Thaler’s application based on its established human-authorship requirement. This policy requires work to be authored in the first instance by a human being to be eligible for copyright registration. Dr. 3 Thaler sought review of the Office’s decision in federal district court and that court affirmed. We affirm the denial of Dr. Thaler’s copyright application. The Creativity Machine cannot be the recognized author of a copyrighted work because the Copyright Act of 1976 requires all eligible work to be authored in the first instance by a human being.", "cited_authorities": [], "summary": "The D.C. Circuit holds that the Copyright Act requires human authorship and affirms the Copyright Office’s refusal to register a work listing Thaler’s Creativity Machine as sole author. The opinion frames AI authorship as a statutory question.", "lead_source": [ "user brief" ], "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "773057e1a606ea8b07e713715859a05bc5c69fdeba4c554d495540e42e3240d6", "source_url": "https://media.cadc.uscourts.gov/opinions/docs/2025/03/23-5233.pdf", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/thaler-perlmutter-2025", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/thaler-perlmutter-2025" }, { "court_code": "dc", "state": "DC", "citation": null, "docket_number": "23-CM-1067", "ai_tool_named": "ChatGPT", "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10336428/ross-v-united-states/", "text_sha256": "db489f62a83520c637ff42f97ff2124ba1bceff03f5e463f4e8be9b7bf62be69", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "D.C. Courts source URL blocked automated fetch; court-authored PDF text was read from an archived/mirrored copy. Wayback save attempt returned no usable location.", "decision_id": "dc-2025-ross-v-united-states", "case_name": "Ross v. United States", "court": "District of Columbia Court of Appeals", "court_level": "state-appellate", "date_filed": "2025-02-20", "document_type": "opinion", "topics": [ "court-ai-use" ], "primary_topic": "court-ai-use", "court_used_ai": true, "disposition": "The court reversed Ross’s conviction and remanded for judgment of acquittal; a majority footnote and dissent disclosed ChatGPT queries.", "ai_passage": "We, like the dissent, harbor doubts about whether ChatGPT is “a good proxy for what is, and what isn’t, common knowledge.” Post at 37 n.4. But to the extent the dissent relies on ChatGPT’s degree of certainty as to whether leaving a dog in a hot car is harmful, we note that ChatGPT expresses similar certainty in its response to the query, “How much would a pretty clean, operable 2002 Dodge Intrepid with no significant dents or scratches have been worth in 2012?” ... Note that $3,000 (ChatGPT’s minimum price) is significantly above the $1,000 threshold at issue in Long. ChatGPT’s analysis, therefore, does not correspond to at least one of our sufficiency decisions. ... I do not mean to suggest that ChatGPT is a good proxy for what is, and isn’t, common knowledge—it is definitely not. It can answer questions that are far from common knowledge. For instance, when I asked it what the forty-first element in the periodic table is, it responded (apparently correctly) with Niobium (Nb). But it is at least a point in favor of something being common knowledge that it is, in fact, true; and it is a far stronger point against it if it’s not. Also, when I had each of my three law clerks run this same inquiry, ChatGPT gave each of them a slightly different but substantively similar answer, all beginning with an unequivocal “Yes.”", "cited_authorities": [ "Snell v. United Specialty Ins. Co., 102 F.4th 1208 (11th Cir. 2024)", "Long v. United States" ], "summary": "On 2025-02-20, the District of Columbia Court of Appeals reverses an animal-cruelty conviction for insufficient proof. The majority and dissent both discuss ChatGPT responses: the majority questions its value as a proxy for common knowledge, while the dissent uses it as a limited check in nonprecedential reasoning.", "source_url": "https://www.dccourts.gov/sites/default/files/2025-02/Ross-v-United-States-23-CM-1067-S.pdf", "verification": "mirror-read", "lead_source": [ "user lead", "CourtListener anonymous search" ], "url": "https://safelegalai.com/courts/opinions/dc-2025-ross-v-united-states", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/dc-2025-ross-v-united-states" }, { "decision_id": "tr-ross-2025", "case_name": "Thomson Reuters Enterprise Centre GmbH v. ROSS Intelligence Inc.", "court": "U.S. District Court for the District of Delaware", "court_code": "ded", "court_level": "federal-district", "state": "DE", "date_filed": "2025-02-11", "citation": "765 F. Supp. 3d 382", "docket_number": "1:20-cv-00613-SB", "document_type": "memorandum-opinion", "topics": [ "substantive-ai-law" ], "primary_topic": "substantive-ai-law", "court_used_ai": false, "ai_tool_named": "ROSS AI search tool", "disposition": "The court granted Thomson Reuters partial summary judgment and rejected ROSS’s fair-use defense.", "ai_passage": "Ross’s use is not transformative because it does not have a “further purpose or different character” from Thomson Reuters’s. Id. at 529. Ross was using Thomson Reuters’s headnotes as AI data to create a legal research tool to compete with Westlaw. It is undisputed that Ross’s AI is not generative AI (AI that writes new content itself). Rather, when a user enters a legal question, Ross spits back relevant judicial opinions that have already been written. D.I. 723 at 5. That process resembles how Westlaw uses headnotes and key numbers to return a list of cases with fitting headnotes. Thomson Reuters uses its headnotes and Key Number System primarily to help legal researchers navigate Westlaw and (possibly, as the parties dispute this) to improve Westlaw’s internal search tool. D.I. 769 at 14 (10:24:52). The parties agree that Ross and Westlaw are competitors. D.I. 752-1 at 4. So at first glance, this factor looks simple. But, as Ross argues, the headnotes do not appear as part of the final product that Ross put forward to consumers. The copying occurred at an intermediate step: Ross 17 turned the headnotes into numerical data about the relationships among legal words to feed into its AI. D.I. 727 at 22. That makes this factor much trickier.", "cited_authorities": [ "Andy Warhol Found. for Visual Arts, Inc. v. Goldsmith, 598 U.S. 508 (2023)" ], "summary": "The District of Delaware treats ROSS’s use of Westlaw headnotes as nontransformative AI training for a competing legal-research tool. The opinion grants partial summary judgment for Thomson Reuters and becomes a central legal-AI copyright ruling on appeal.", "source_url": "https://www.ded.uscourts.gov/sites/ded/files/opinions/20-613_5.pdf", "lead_source": [ "user brief" ], "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "630a8bea8a11978c9572db4e6a39d3e0449a84bea9ec49bc1d04e31158abe3bc", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/tr-ross-2025", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/tr-ross-2025" }, { "decision_id": "illinois-policy-2024", "case_name": "Illinois Supreme Court Policy on Artificial Intelligence", "court": "Supreme Court of Illinois", "court_code": null, "court_level": "state-supreme", "state": "IL", "date_filed": "2025-01-01", "citation": null, "docket_number": null, "document_type": "administrative-order", "topics": [ "rules-by-opinion", "court-ai-use" ], "primary_topic": "rules-by-opinion", "court_used_ai": false, "disposition": "The court made an artificial-intelligence policy effective for Illinois courts on January 1, 2025.", "ai_passage": "Embracing the advancements of artificial intelligence (AI), the Illinois Supreme Court remains steadfast in its commitment to upholding the highest ethical standards in the administration of justice. We acknowledge the rapid development of generative AI technologies capable of producing human-like text, images, video, audio, and other content. The integration of AI with the courts is increasingly pervasive, offering potential efficiencies and improved access to justice. However, it also raises critical concerns about authenticity, accuracy, bias, and the integrity of court filings, proceedings, evidence, and decisions. Understanding the capabilities and limitations of AI technology is essential for the Illinois Judicial Branch. The Illinois Courts will be vigilant against AI technologies that jeopardize due process, equal protection, or access to justice. Unsubstantiated or deliberately misleading AI- generated content that perpetuates bias, prejudices litigants, or obscures truth-finding and decision-making will not be tolerated. The use of AI by litigants, attorneys, judges, judicial clerks, research attorneys, and court staff providing similar support may be expected, should not be discouraged, and is authorized provided it complies with legal and ethical standards. Disclosure of AI use should not be required in a pleading.", "cited_authorities": [], "summary": "The Illinois Supreme Court policy authorizes responsible AI use by court users, lawyers, judges, and staff while stressing accuracy, bias, confidentiality, and accountability. It states that AI use should not be discouraged and generally should not require pleading disclosure.", "source_url": "https://ilcourtsaudio.blob.core.windows.net/antilles-resources/resources/e43964ab-8874-4b7a-be4e-63af019cb6f7/Illinois%20Supreme%20Court%20AI%20Policy.pdf", "lead_source": [ "Illinois Courts news page" ], "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "bfbb85501d82a4e9202543b46af0e48cdf71ba9f8dc1329924d4623aef96ba57", "archive_url": "https://web.archive.org/web/20241218165948/https://ilcourtsaudio.blob.core.windows.net/antilles-resources/resources/e43964ab-8874-4b7a-be4e-63af019cb6f7/Illinois%20Supreme%20Court%20AI%20Policy.pdf", "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/illinois-policy-2024", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/illinois-policy-2024" }, { "court_code": "delch", "state": "DE", "citation": null, "docket_number": "2023-0873-LWW", "ai_tool_named": "technology assisted review (TAR)", "incident": null, "tracker_slug": null, "courtlistener_url": "https://www.courtlistener.com/opinion/10151354/paul-berger-v-graf-acquisition-llc/", "text_sha256": "10cdbb8ee6a9d273107a3ee3773b2409cd4f2b91d2ee885c3ad7ac5a0e4e2e5c", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "The order discusses TAR/predictive coding rather than a named generative-AI tool; included for the discovery/TAR part of this slice.", "decision_id": "delch-2024-berger-v-graf", "case_name": "Berger v. Graf Acquisition, LLC", "court": "Delaware Court of Chancery", "court_level": "state-trial", "date_filed": "2024-10-21", "document_type": "order", "topics": [ "discovery-ediscovery" ], "primary_topic": "discovery-ediscovery", "court_used_ai": false, "disposition": "The Court of Chancery granted in part the motion to compel and allowed defendants to use a TAR protocol for responsive documents.", "ai_passage": "Fortunately, the defendants also propose a reasonable means to address their burden concerns: a technology assisted review (TAR). That is, the defendants are willing to review the universe of documents captured by the plaintiff’s broad search terms so long as they can employ a TAR protocol. But the plaintiff rejected this offer and insists that the defendants conduct a manual review instead. TAR, or predictive coding, leverages machine learning techniques with the guidance of attorneys to facilitate the document review process. The TAR system is trained with a representative seed set of documents selected and reviewed by attorneys for relevance. The system ingests this initial set of documents and undergoes iterative rounds of sampling and manual review, during which it learns and improves. Human reviewers remain involved in quality control, including by reviewing and running keyword searches over documents coded by the program as non-responsive. TAR promotes efficiency in the discovery process in several meaningful ways. ... Thus, the defendants may use TAR to reduce their discovery burden, so long as they are transparent with the plaintiff about their computer-assisted review process. Delaware counsel must remain closely involved in the review and sampling process for the TAR review.", "cited_authorities": [ "Moore v. Publicis Groupe, 287 F.R.D. 182 (S.D.N.Y. 2012)", "Rio Tinto PLC v. Vale S.A., 306 F.R.D. 125 (S.D.N.Y. 2015)", "Dynamo Holdings v. Commissioner of Internal Revenue, 143 T.C. 183 (2014)", "Hyles v. New York City, 2016 WL 4077114 (S.D.N.Y. Aug. 1, 2016)", "The Sedona Principles, Third Edition" ], "summary": "On 2024-10-21, the Delaware Court of Chancery grants in part a motion to compel in SPAC litigation. To address burden from broad document requests, the court permits defendants to use a technology-assisted review protocol with attorney involvement and transparency to the plaintiff.", "source_url": "https://courts.delaware.gov/Opinions/Download.aspx?id=371000", "verification": "fetched-and-read", "lead_source": [ "CourtListener anonymous search", "Delaware Courts opinion search" ], "url": "https://safelegalai.com/courts/opinions/delch-2024-berger-v-graf", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/delch-2024-berger-v-graf" }, { "decision_id": "delaware-policy-2024", "case_name": "In re Interim Policy on the Use of Generative AI by Judicial Officers and Court Personnel", "court": "Supreme Court of Delaware", "court_code": null, "court_level": "state-supreme", "state": "DE", "date_filed": "2024-10-21", "citation": null, "docket_number": null, "document_type": "administrative-order", "topics": [ "rules-by-opinion", "court-ai-use" ], "primary_topic": "rules-by-opinion", "court_used_ai": false, "disposition": "The court ordered Delaware judicial officers and court personnel to follow an interim generative-AI policy.", "ai_passage": "WHEREAS, the DCLT has recommended adoption of the attached interim policy for the use of Generative Artificial Intelligence (“GenAI”) by judicial officers and court personnel; WHEREAS, the Interim Policy is intended to ensure the safe and appropriate use of GenAI by judicial officers and court personnel, but not be used as a substitute for judicial, legal, or professional expertise. NOW, THEREFORE, IT IS ORDERED that: 1. Judicial officers and court personnel using GenAI in their official duties shall comply with the Interim Policy on the Use of Gen AI Policy by Judicial Officers and Court Personnel (“the Interim Policy”), attached as Exhibit A. 2. The Interim Policy shall be added as Appendix O-1 to the Judicial Branch Operating Procedures, available at https://courts.delaware.gov/aoc/operating-procedures/index.aspx. 3. The DCLT shall monitor the Interim Policy and report to the Court when further changes are needed. 4. The Interim Policy shall go into effect on October 21, 2024. BY THE COURT:", "cited_authorities": [], "summary": "The Delaware Supreme Court adopts an interim policy governing generative-AI use by judicial officers and court personnel. The order emphasizes that GenAI may assist official work only under a policy designed to protect judicial, legal, and professional judgment.", "source_url": "https://courts.delaware.gov/forms/download.aspx?id=266848", "lead_source": [ "Delaware Courts operating procedures", "web search" ], "ai_tool_named": null, "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "6ae119acada0b1a6e438a03504a17801ea41a56f417fc25048c706e0dfc43759", "archive_url": "https://web.archive.org/web/20241022201623/https://courts.delaware.gov/forms/download.aspx?id=266848", "fetched_at": "2026-09-07T22:15:00Z", "verification": "fetched-and-read", "notes": null, "url": "https://safelegalai.com/courts/opinions/delaware-policy-2024", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/delaware-policy-2024" }, { "court_code": "ca11", "state": null, "citation": "116 F.4th 1260", "docket_number": "23-10478", "ai_tool_named": "ChatGPT; Claude; Gemini", "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "3f945d5fd291da654a1b451e2317fb0f4e4e8ca1dcd5d94a379d91ba3bc81d1b", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": null, "decision_id": "ca11-2024-united-states-v-deleon", "case_name": "United States v. Deleon", "court": "U.S. Court of Appeals for the Eleventh Circuit", "court_level": "federal-appellate", "date_filed": "2024-09-05", "document_type": "concurrence", "topics": [ "court-ai-use" ], "primary_topic": "court-ai-use", "court_used_ai": true, "disposition": "The court affirmed the sentencing enhancement; Judge Newsom concurred, reporting a multi-model LLM experiment on the phrase “physically restrained.”", "ai_passage": "This is a sequel of sorts to my separate opinion in Snell v. United Specialty Insurance Co., 102 F.4th 1208 (11th Cir. 2024) (Newsom, J., concurring). There, I floated the following suggestion, which I suspected (rightly, as it turns out) would be fairly provocative: “Those, like me, who believe that ‘ordinary meaning’ is the foundational rule for the evaluation of legal texts should consider—consider—whether and how AI-powered large language models like OpenAI’s ChatGPT, Google’s Gemini, and Anthropic’s Claude might—might—inform the interpretive analysis.” Id. at 1221. With the benefit of a little perspective, and incorporating by reference here all the caveats that I expressed there, I stand by what I said. The LLM research that I conducted in connection with this case, though, raised a question that I hadn’t squarely confronted in Snell, one that seemed worth flagging and exploring: What should we make of the fact that the models sometimes provide subtly different answers to the exact same question? ... That seems about right to me. But because there’s no ready dictionary definition of the composite phrase, because by their very nature LLMs aim to capture and reflect how real people ordinarily use both individual words and multi-word phrases, and because, well, I couldn’t help myself, I queried ChatGPT.", "cited_authorities": [ "Snell v. United Specialty Insurance Co., 102 F.4th 1208 (11th Cir. 2024)" ], "summary": "On 2024-09-05, the Eleventh Circuit affirms a robbery sentencing enhancement. Judge Newsom concurs to revisit ordinary meaning and explains that he queried ChatGPT, Gemini, and Claude repeatedly about “physically restrained,” using the variation in responses to discuss LLMs and everyday speech patterns.", "source_url": "https://media.ca11.uscourts.gov/opinions/pub/files/202310478.pdf", "verification": "fetched-and-read", "lead_source": [ "user lead", "court site search" ], "url": "https://safelegalai.com/courts/opinions/ca11-2024-united-states-v-deleon", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca11-2024-united-states-v-deleon" }, { "court_code": "ca11", "state": null, "citation": "102 F.4th 1208", "docket_number": "22-12581", "ai_tool_named": "ChatGPT; Bard", "incident": null, "tracker_slug": null, "courtlistener_url": null, "text_sha256": "9f9170692adc48fe2196ef0d79b33a0ae48930734f73de3fea1245c0252c5a26", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": null, "decision_id": "ca11-2024-snell-v-united-specialty", "case_name": "Snell v. United Specialty Insurance Co.", "court": "U.S. Court of Appeals for the Eleventh Circuit", "court_level": "federal-appellate", "date_filed": "2024-05-28", "document_type": "concurrence", "topics": [ "court-ai-use" ], "primary_topic": "court-ai-use", "court_used_ai": true, "disposition": "The court affirmed summary judgment for the insurer; Judge Newsom concurred and disclosed querying ChatGPT and Bard while considering ordinary meaning.", "ai_passage": "And that’s when things got weird. Perhaps in a fit of frustration, and most definitely on what can only be described as a lark, I said to one of my clerks, “I wonder what ChatGPT thinks about all this.” So he ran a query: “What is the ordinary meaning of ‘landscaping’?” Here’s what ChatGPT said in response: “Landscaping” refers to the process of altering the visible features of an area of land, typically a yard, garden or outdoor space, for aesthetic or practical purposes. This can include activities such as planting trees, shrubs, flowers, or grass, as well as installing paths, fences, water features, and other elements to enhance the appearance and functionality of the outdoor space. Interesting, for two reasons. First, ChatGPT’s explanation seemed more sensible than I had thought it might—and definitely less nutty than I had feared. Second, it squared with my own impression—informed by my own experience writing, reading, speaking, and listening to American English in the real world—that ordinary people might well use the word “landscaping” (1) to include more than just botanical and other natural improvements and (2) to cover both aesthetic and functional objectives. ... For good measure, I posed the same questions to Google’s Bard (since replaced by Gemini).", "cited_authorities": [], "summary": "On 2024-05-28, the Eleventh Circuit affirms summary judgment in an insurance coverage dispute. Judge Newsom concurs and discloses that he asked ChatGPT and Bard ordinary-meaning questions about “landscaping,” then discusses potential uses, disclosure practices, and risks of LLMs in textual interpretation.", "source_url": "https://media.ca11.uscourts.gov/opinions/pub/files/202212581.pdf", "verification": "fetched-and-read", "lead_source": [ "user lead", "CourtListener anonymous search" ], "url": "https://safelegalai.com/courts/opinions/ca11-2024-snell-v-united-specialty", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/ca11-2024-snell-v-united-specialty" }, { "court_code": "nysd", "state": "NY", "citation": null, "docket_number": "1:23-cv-00959-PAE", "ai_tool_named": "ChatGPT-4", "incident": null, "tracker_slug": null, "courtlistener_url": "https://storage.courtlistener.com/recap/gov.uscourts.nysd.593463/gov.uscourts.nysd.593463.32.0.pdf", "text_sha256": "22508faeab64ed63a2a8b671cf128341b6870464a7d3017d0655045c9d2a2399", "archive_url": null, "fetched_at": "2026-09-07T22:45:00Z", "notes": "Court-authored public-domain PDF was read from CourtListener storage; no separate CourtListener opinion page was captured.", "decision_id": "nysd-2024-jg-v-nyc-department-of-education", "case_name": "J.G. v. New York City Department of Education", "court": "U.S. District Court for the Southern District of New York", "court_level": "federal-district", "date_filed": "2024-02-22", "document_type": "opinion", "topics": [ "competence-fees" ], "primary_topic": "competence-fees", "court_used_ai": false, "disposition": "The court substantially reduced the requested fee award and rejected ChatGPT-4 as a cross-check on billing rates.", "ai_passage": "The Cuddy Law Firm also states that its requested hourly rates are supported by feedback it received from the artificial intelligence tool “ChatGPT-4.” Pl. Mem. at 16; see also Dkt 19 (“Kopp Decl.”). In fairness, the Cuddy Law Firm does not predominantly rely on ChatGPT-4 in advocating for these billing rates. It instead presents ChatGPT-4 as a “cross-check” supporting the problematic sources above. Pl. Mem. at 16. As such, the Court need not dwell at length on this point. It suffices to say that the Cuddy Law Firm’s invocation of ChatGPT as support for its aggressive fee bid is utterly and unusually unpersuasive. As the firm should have appreciated, treating ChatGPT’s conclusions as a useful gauge of the reasonable billing rate for the work of a lawyer with a particular background carrying out a bespoke assignment for a client in a niche practice area was misbegotten at the jump. In two recent cases, courts in the Second Circuit have reproved counsel for relying on ChatGPT, where ChatGPT proved unable to distinguish between real and fictitious case citations. ... The Court therefore rejects out of hand ChatGPT’s conclusions as to the appropriate billing rates here. Barring a paradigm shift in the reliability of this tool, the Cuddy Law Firm is well advised to excise references to ChatGPT from future fee applications.", "cited_authorities": [ "Mata v. Avianca, Inc., No. 22 Civ. 1461 (PKC), 2023 WL 4114965 (S.D.N.Y. June 22, 2023)", "Park v. Kim, 91 F.4th 610 (2d Cir. 2024)" ], "summary": "On 2024-02-22, the Southern District of New York awards IDEA attorneys’ fees but reduces the requested hourly rates and hours. The court rejects the Cuddy Law Firm’s ChatGPT-4 fee-rate cross-check, citing citation hallucination cases and warning against using ChatGPT in future fee applications.", "source_url": "https://storage.courtlistener.com/recap/gov.uscourts.nysd.593463/gov.uscourts.nysd.593463.32.0.pdf", "verification": "mirror-read", "lead_source": [ "CourtListener storage mirror", "keyword sweep" ], "url": "https://safelegalai.com/courts/opinions/nysd-2024-jg-v-nyc-department-of-education", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/opinions/nysd-2024-jg-v-nyc-department-of-education" } ], "litigation": [ { "case_id": "evenup-v-butler-labs", "caption": "EvenUp, Inc. v. Butler Labs, Inc.", "court": "U.S. District Court for the Northern District of California", "docket_number": "4:25-cv-08199-YGR", "filed": "2025-09-26", "country": "US", "parties_legal_ai": [ "EvenUp, Inc.", "Butler Labs, Inc." ], "qualifier": "trade-secret-vendor", "status": "active", "status_text": "Docket leads report Judge Yvonne Gonzalez Rogers denied EvenUp’s preliminary-injunction motion on March 19, 2026; no free court PDF was located.", "milestones": [ { "date": "2025-09-26", "event": "EvenUp filed trade-secret action against Butler Labs.", "url": "https://ecf.cand.uscourts.gov/" }, { "date": "2026-03-19", "event": "Public docket lead reports order denying preliminary injunction and resolving sealing motions.", "url": null } ], "summary": "EvenUp’s trade-secret suit against Butler Labs concerns competing legal-AI products for injury and claims work. Free discovery located only docket leads, not the preliminary-injunction order; the matter appears active after a March 2026 denial of interim relief.", "next_expected": "Monitor N.D. Cal. docket or RECAP for free availability of the PI order and subsequent merits schedule.", "source_url": "https://ecf.cand.uscourts.gov/", "verification": "link-only", "lead_source": [ "user brief", "web search", "CourtListener RECAP search throttled" ], "notes": "CourtListener RECAP was throttled and N.D. Cal. public-document probes did not locate a free PDF; row needs human docket review.", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/litigation/evenup-v-butler-labs", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/evenup-v-butler-labs" }, { "case_id": "canlii-v-caseway-ai", "caption": "Canadian Legal Information Institute v. Caseway AI", "court": "Supreme Court of British Columbia", "docket_number": "VLC-S-S-247574", "filed": "2024-12", "country": "CA", "parties_legal_ai": [ "Caseway AI" ], "qualifier": "database-terms", "status": "settled", "status_text": "CanLII and Caseway announced on March 20, 2026 that all matters in VLC-S-S-247574 were fully and finally resolved on confidential terms.", "milestones": [ { "date": "2026-03-20", "event": "CanLII announced confidential settlement and final resolution of the BCSC proceeding.", "url": "https://blog.canlii.org/2026/03/20/announcement-regarding-settlement-between-canlii-and-caseway/" } ], "summary": "CanLII’s British Columbia proceeding against Caseway AI concerned alleged legal-database misuse by a legal-AI product. The parties announced a confidential settlement in March 2026, stating that both organizations would move forward independently and make no further public comment.", "next_expected": null, "source_url": "https://justice.gov.bc.ca/cso/", "verification": "link-only", "lead_source": [ "user brief", "CanLII blog" ], "notes": "No public court order was located; official BC Court Services Online is the registry source, while CanLII’s public settlement statement was read only as a lead. Needs human registry verification.", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/litigation/canlii-v-caseway-ai", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/canlii-v-caseway-ai" }, { "case_id": "ftc-in-re-donotpay", "caption": "In the Matter of DoNotPay, Inc.", "court": "Federal Trade Commission", "docket_number": "Docket No. C-4812; File No. 232-3042", "filed": "2024-09-25", "country": "US", "parties_legal_ai": [ "DoNotPay, Inc." ], "qualifier": "regulator-consumer", "status": "consent-order", "status_text": "FTC final decision and order issued January 14, 2025; DoNotPay owes monetary relief and must comply with notice, substantiation, reporting, and recordkeeping terms.", "milestones": [ { "date": "2024-09-30", "event": "Federal Register published analysis of proposed consent order for public comment.", "url": "https://www.govinfo.gov/content/pkg/FR-2024-09-30/pdf/2024-22400.pdf" }, { "date": "2025-01-14", "event": "FTC issued final decision and order in Docket C-4812.", "url": "https://www.ftc.gov/system/files/ftc_gov/pdf/2323042_donotpay_decision_and_order_0.pdf" } ], "summary": "The FTC challenged DoNotPay’s “robot lawyer” and AI-lawyer claims as deceptive. The final order bars unsupported claims that its service acts like a lawyer or other professional, imposes $193,000 in monetary relief, and requires customer notice and compliance reporting.", "next_expected": "Compliance reports and customer-notice obligations under the final order.", "source_url": "https://www.ftc.gov/system/files/ftc_gov/pdf/2323042_donotpay_decision_and_order_0.pdf", "verification": "fetched-and-read", "lead_source": [ "user brief", "Federal Register API", "FTC website" ], "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "notes": null, "url": "https://safelegalai.com/courts/litigation/ftc-in-re-donotpay", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/ftc-in-re-donotpay" }, { "case_id": "faridian-v-donotpay", "caption": "Jonathan Faridian v. DoNotPay, Inc.", "court": "U.S. District Court for the Northern District of California", "docket_number": "3:23-cv-01692-RFL", "filed": "2023-04-07", "country": "US", "parties_legal_ai": [ "DoNotPay, Inc." ], "qualifier": "upl-consumer", "status": "dismissed", "status_text": "Public docket leads report a stipulated dismissal with prejudice on July 30, 2024; free final dismissal paper was not located.", "milestones": [ { "date": "2023-04-07", "event": "Removed/filed consumer class action against DoNotPay in N.D. Cal.", "url": "https://www.govinfo.gov/app/details/USCOURTS-cand-3_23-cv-01692" }, { "date": "2024-01-30", "event": "Court ordered jurisdictional discovery and related sealing response.", "url": "https://www.govinfo.gov/content/pkg/USCOURTS-cand-3_23-cv-01692/pdf/USCOURTS-cand-3_23-cv-01692-0.pdf" }, { "date": "2024-07-30", "event": "Docket lead reports stipulated dismissal with prejudice.", "url": null } ], "summary": "Faridian sued DoNotPay over alleged automated legal-service representations and consumer-facing products. Free filings show arbitration and jurisdictional-discovery activity; public docket leads indicate the parties later stipulated to dismiss the federal action with prejudice in July 2024.", "next_expected": null, "source_url": "https://www.govinfo.gov/content/pkg/USCOURTS-cand-3_23-cv-01692/pdf/USCOURTS-cand-3_23-cv-01692-0.pdf", "verification": "fetched-and-read", "lead_source": [ "user brief", "GovInfo", "public docket leads" ], "notes": "Final dismissal document was not found in free GovInfo/RECAP materials; status relies on public docket lead and is flagged for human review.", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/litigation/faridian-v-donotpay", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/faridian-v-donotpay" }, { "case_id": "millerking-v-donotpay", "caption": "MillerKing, LLC v. DoNotPay, Inc.", "court": "U.S. District Court for the Southern District of Illinois", "docket_number": "3:23-cv-00863-NJR", "filed": "2023-03-15", "country": "US", "parties_legal_ai": [ "DoNotPay, Inc." ], "qualifier": "upl-consumer", "status": "dismissed", "status_text": "Complaint was dismissed for lack of Article III standing; a November 28, 2023 order clarified any dismissal would be without prejudice, and no Seventh Circuit appeal was found.", "milestones": [ { "date": "2023-03-15", "event": "Class complaint filed alleging DoNotPay’s robot-lawyer service constituted unauthorized practice and false advertising.", "url": null }, { "date": "2023-11-28", "event": "Court amended dismissal order to clarify lack-of-standing dismissal would be without prejudice absent amendment.", "url": "https://www.govinfo.gov/content/pkg/USCOURTS-ilsd-3_23-cv-00863/pdf/USCOURTS-ilsd-3_23-cv-00863-0.pdf" } ], "summary": "MillerKing, an Illinois law firm, sued DoNotPay over “robot lawyer” marketing and alleged unauthorized practice of law. The court dismissed for lack of standing and later corrected the dismissal posture; no free record of a Seventh Circuit appeal was found.", "next_expected": null, "source_url": "https://www.govinfo.gov/content/pkg/USCOURTS-ilsd-3_23-cv-00863/pdf/USCOURTS-ilsd-3_23-cv-00863-0.pdf", "verification": "fetched-and-read", "lead_source": [ "user brief", "GovInfo", "public docket search" ], "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "notes": null, "url": "https://safelegalai.com/courts/litigation/millerking-v-donotpay", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/millerking-v-donotpay" }, { "case_id": "smartlaw-bgh-2021", "caption": "Hanseatische Rechtsanwaltskammer Hamburg v. Wolters Kluwer Deutschland GmbH (smartlaw)", "court": "Bundesgerichtshof", "docket_number": "I ZR 113/20", "filed": "2021-09-09", "country": "DE", "parties_legal_ai": [ "Wolters Kluwer smartlaw" ], "qualifier": "upl-consumer", "status": "judgment", "status_text": "BGH judgment issued September 9, 2021 affirmed dismissal of the bar chamber’s challenge and held the smartlaw document generator was not an RDG legal service.", "milestones": [ { "date": "2021-09-09", "event": "BGH held smartlaw-style digital contract generation is not a legal service under RDG § 2(1).", "url": "https://www.bundesgerichtshof.de/SharedDocs/Entscheidungen/DE/Zivilsenate/I_ZS/2020/I_ZR_113-20.pdf?__blob=publicationFile&v=1" } ], "summary": "The German Federal Court of Justice ruled that smartlaw’s rule-based contract document generator does not provide an unauthorized legal service under the Rechtsdienstleistungsgesetz. The row is marked legal-AI-adjacent because the product is rule-based rather than generative AI.", "next_expected": null, "source_url": "https://www.bundesgerichtshof.de/SharedDocs/Entscheidungen/DE/Zivilsenate/I_ZS/2020/I_ZR_113-20.pdf?__blob=publicationFile&v=1", "verification": "fetched-and-read", "lead_source": [ "user brief", "BGH official site" ], "notes": "Rule-based document generator, included because the brief requested it with qualifier upl-consumer.", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/litigation/smartlaw-bgh-2021", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/smartlaw-bgh-2021" }, { "case_id": "thomson-reuters-v-ross", "caption": "Thomson Reuters Enterprise Centre GmbH and West Publishing Corp. v. ROSS Intelligence Inc.", "court": "U.S. District Court for the District of Delaware; U.S. Court of Appeals for the Third Circuit", "docket_number": "D. Del. 1:20-cv-00613-SB; 3d Cir. No. 25-2153", "filed": "2020-05-06", "country": "US", "parties_legal_ai": [ "ROSS Intelligence Inc." ], "qualifier": "copyright-training", "status": "on-appeal", "status_text": "District-court summary judgment issued February 11, 2025; Third Circuit No. 25-2153 was argued June 11, 2026 and no opinion was found as of 2026-09-07.", "milestones": [ { "date": "2025-02-11", "event": "Memorandum opinion granted Thomson Reuters partial summary judgment and rejected ROSS’s fair-use defense.", "url": "https://www.ded.uscourts.gov/sites/ded/files/opinions/20-613_5.pdf" }, { "date": "2026-06-11", "event": "Third Circuit heard argument in No. 25-2153; decision pending.", "url": "https://www.ca3.uscourts.gov/opinions-and-oral-arguments" } ], "summary": "ROSS, an AI legal-research startup, used Westlaw-derived legal Q&A materials to train a competing search tool. The district court found key Westlaw material protectable and rejected fair use; the interlocutory appeal is pending in the Third Circuit.", "next_expected": "Third Circuit opinion in No. 25-2153.", "source_url": "https://www.ded.uscourts.gov/sites/ded/files/opinions/20-613_5.pdf", "verification": "fetched-and-read", "lead_source": [ "user brief", "Third Circuit opinions search" ], "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "notes": null, "url": "https://safelegalai.com/courts/litigation/thomson-reuters-v-ross", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/thomson-reuters-v-ross" }, { "case_id": "dalloz-v-forseti-doctrine", "caption": "Éditions Dalloz, Lexbase, LexisNexis, Lextenso, Lamy Liaisons v. Forseti (Doctrine)", "court": "Cour d’appel de Paris, Pôle 5, Chambre 1", "docket_number": "RG No. 23/06063", "filed": "2018-10", "country": "FR", "parties_legal_ai": [ "Forseti", "Doctrine.fr" ], "qualifier": "database-terms", "status": "judgment", "status_text": "Paris Court of Appeal judgment dated May 7, 2025 found unfair competition and awarded damages to legal publishers; official court page was blocked to automated access.", "milestones": [ { "date": "2025-05-07", "event": "Paris Court of Appeal issued judgment in RG No. 23/06063 concerning Doctrine.fr’s case-law collection practices.", "url": "https://www.courdecassation.fr/decision/681c3dea1ca45fa20a739723" } ], "summary": "French legal publishers challenged Forseti’s Doctrine.fr case-law collection practices. Public legal reporting and the official decision listing identify a May 2025 Paris Court of Appeal judgment finding unfair competition based on large-scale illicit collection of court decisions.", "next_expected": null, "source_url": "https://www.courdecassation.fr/decision/681c3dea1ca45fa20a739723", "verification": "link-only", "lead_source": [ "user brief", "Cour de cassation link", "Legalis article" ], "notes": "Official Cour de cassation page blocked automated access; Legalis article was read for public details, so this row needs human verification against the official judgment text.", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/litigation/dalloz-v-forseti-doctrine", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/dalloz-v-forseti-doctrine" }, { "case_id": "west-publishing-v-legalease", "caption": "West Publishing Corporation v. LegalEase Solutions, LLC", "court": "U.S. District Court for the District of Minnesota", "docket_number": "0:18-cv-01445-DSD-ECW", "filed": "2018-05-24", "country": "US", "parties_legal_ai": [ "LegalEase Solutions, LLC" ], "qualifier": "copyright-training", "status": "judgment", "status_text": "Consent judgment and stipulated permanent injunction entered May 5, 2020; case closed.", "milestones": [ { "date": "2020-05-05", "event": "Consent judgment and stipulated permanent injunction entered against LegalEase.", "url": "https://ecf.mnd.uscourts.gov/cgi-bin/show_public_doc?2018cv1445-119" } ], "summary": "West sued LegalEase over use of Westlaw content later relevant to ROSS training data. The consent judgment permanently enjoins LegalEase from using Westlaw content, sharing credentials, or using bots and automated processes to bulk copy or distribute Westlaw material.", "next_expected": null, "source_url": "https://ecf.mnd.uscourts.gov/cgi-bin/show_public_doc?2018cv1445-119", "verification": "mirror-read", "lead_source": [ "user brief", "DocketAlarm mirror" ], "notes": "Official PACER document was not freely retrieved; the court-filed consent judgment was read from a public DocketAlarm PDF mirror.", "archive_url": null, "fetched_at": "2026-09-07T22:15:00Z", "url": "https://safelegalai.com/courts/litigation/west-publishing-v-legalease", "notice": "Provided as is, without warranty. Not legal advice. SafeLegalAI (Cognesio LLP) records what courts, regulators, legislatures and vendors' own public pages state; the linked official documents are the record. Names and marks belong to their owners. Anyone named may reply: https://safelegalai.com/report. Full terms: https://safelegalai.com/disclaimer", "page": "https://safelegalai.com/courts/litigation/west-publishing-v-legalease" } ] }