Courts on AI / Fabricated or misquoted citations
Tunstall v. Alabama Department of Corrections
United States District Court for the Northern District of Alabama · Federal district courts · AL · · No. 2:24-cv-01504-RDP · memorandum opinion
The Northern District of Alabama on 2026-04-28 admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct in Tunstall v. Alabama Department of Corrections. Counsel filed a submission with one false case quotation, including Thomas v. Dillard.
- Disposition
- The court admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct.
- Recorded conduct
- Counsel filed a submission with one false case quotation, including Thomas v. Dillard. — outcome: warning; 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.
3d 1432, 1433-34 (11th Cir. 1997), and attributes to it the following quotation: “‘Resign or be fired’ scenarios are classic jury questions. ” (Doc. # 48 at 15-16). The court’s own review of Thomas reveals that no such language appears anywhere in that opinion. The court declines to speculate as to how this misattribution occurred, but counsel is cautioned that submitting fabricated quotations to the court implicates her obligations under Federal Rule of Civil Procedure 11 and that such conduct will not be tolerated in future filings. See, e. g. , Johnson v. Dunn, 792 F. Supp. 3d 1241 (N. D.
Authorities cited in the passage: Johnson v. Dunn, 792 F · Thomas v. Dillard
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