Courts on AI / Fabricated or misquoted citations

Watson Adams v. 3M Co.

United States District Court for the Northern District of Alabama · Federal district courts · AL · 2026-04-20 · No. No. 4:24-cv-832-CLM · order

Fabricated or misquoted citations

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.

Disposition: Plaintiffs’ counsel was ordered to show cause by May 1, 2026 why she should not be sanctioned, and the deadline to amend the complaint was stayed pending the show-cause decision.
Recorded conduct: Plaintiffs’ opposition to 3M’s Rule 12(c) motion contained nine highlighted errors, including hallucinated Adams and Jarrod Johnson citations or parentheticals, wrong interpretations of real cases, and false quotes. — outcome: pending; actor: lawyer
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.

So it seems that someone—either Plaintiffs’ counsel or an AI platform—hallucinated the page 11 parenthetical that, in Adams v. 3M Co., the Sixth Circuit described 3M’s decades-long supply of PFAS causing continuing injuries to residents. ... So again, someone fabricated the cite and parenthetical.

Authorities cited in the passage: 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 document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

United States court documents are public domain; the topic coding, disposition line and summary are SafeLegalAI's reading of the document for comparison, not a finding about any person named in it. This record summarises a public court document or official publication and reports what it says; SafeLegalAI makes no findings of its own. Individuals and organisations are named only as they appear in that public record. Anyone named may send a right of reply, correction or contextual update (for example an appeal, vacatur or later disposition) via /report; we add a dated note where appropriate. Reply or correct this record.

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub