Courts on AI / Fabricated or misquoted citations
State National Insurance Company, Inc. v. Damon Treadwell, et al.
U.S. 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 publicly reprimanded counsel and ordered notice of the reprimand after counsel admitted ChatGPT and OpenCase produced made-up quotations.
- Recorded conduct
- The filing used false quotations and fabricated or nonexistent authorities, including Co. v. Houston National Bank and Whelan v. Abell, which the court found nonexistent, misquoted, or unsupported. — 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
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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