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Courts on AI / Fabricated or misquoted citations

Bridgett Watson Adams, et al. v. 3M Company

United States District Court for the Northern District of Alabama · Federal district courts · AL · · No. 4:24-cv-00832-CLM · order

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
The court ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities.
Recorded conduct
Counsel filed an opposition with two fabricated case citations, three false case quotations, and three mischaracterized case citations. — 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.

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.

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

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