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Courts on AI / Fabricated or misquoted citations

State National Insurance Company, Inc. v. Treadwell

United States District Court for the Northern District of Alabama · Federal district courts · AL · · No. 2:24-cv-1424-HDM · order

On 2026-03-26, U.S. District Court for the Northern District of Alabama publicly reprimanded counsel and ordered notice of the reprimand after counsel admitted ChatGPT and OpenCase produced made-up quotations. Counsel submitted a filing with false quotations and fabricated or nonexistent authorities, including Co. v. Houston National Bank and Whelan v. Abell.

Disposition
The court sanctioned Edward May with a reprimand, service of the order on clients and courts, and publication of the order.
Recorded conduct
Attorney Edward May used ChatGPT and OpenCase while preparing defendants' brief and fabricated quotations in a filing to the court. — outcome: sanctions; 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 final version did, in fact, exist. Transcript of Show-Cause Hearing at 21–22 (March 26, 2026). Mr. May confirmed that the quotations were hallucinations of one or both of two popular generative artificial intelligence (“AI”) applications used by Mr. May—ChatGPT and OpenCase. (Doc. 69 at 2). In simpler terms, the quotes Mr. May cited were completely made up and resulted from what Mr. May admits was a “lack of diligence” on his part. (Doc. 69 at 3). FINDINGS OF FACT AND CONCLUSIONS OF LAW Citations to fake legal authority pose a serious threat to the fair administration of justice and the integrity of the judicial system, and they require an equally serious sanction. Johnson v. Dunn, 792 F. Supp. 3d 1241, 1246 (N.D. Ala. 2025). This court has stated, Even in cases like this one, where lawyers who cite AI hallucinations accept responsibility and apologize profusely, much damage is done. . . . [T]he court spends time reviewing materials, holding hearings, deliberating about sanctions, and explaining its ruling; the substance of the case is delayed; and public confidence about the trustworthiness of legal proceedings may be diminished. Id. at 1257

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