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Courts on AI / Fabricated or misquoted citations

Pleasant v. Burns

U.S. District Court for the Northern District of Alabama · Federal district courts · AL · · 2026 WL 948793 · No. 2:25-cv-1658-ACA error in her email addre · memorandum opinion

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.

Disposition
The court dismissed the case without prejudice after the plaintiff ignored orders to address Rule 11 concerns about nonexistent cases and fabricated quotations.
Recorded 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
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.

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.

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