Courts on AI / Fabricated or misquoted citations
Staley v. City of Elba, et al.
U.S. District Court for the Middle District of Alabama · Federal district courts · AL · · No. 1:24-cv-00141-BL-SMD · order
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.
- Disposition
- The court adopted the recommendation, dismissed claims, and noted that the plaintiff’s response and objections used nonexistent cases and false quotations.
- Recorded 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
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
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”
Authorities cited in the passage: Greer v. DeKalb County, 2009 WL 10101675
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