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Courts on AI / Fabricated or misquoted citations

Jackie L. Miller v. Regions Bank

United States District Court for the Northern District of Alabama · Federal district courts · AL · · No. 2:24-cv-1324-HDM · order

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.

Disposition
The court disqualified counsel from the case and from appearing before the judge for six months and referred the order to bar authorities.
Recorded conduct
Counsel submitted a filing using quotations that did not appear in the cited source. — outcome: referral; 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.

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.

Authorities cited in the passage: SeeHolly v. Clairson Indus · See EEOC v. St. Joseph’s Hosp · Breen v. Dep’t of Transp., 282 F

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