Courts on AI / Fabricated or misquoted citations
Heimkes v. Fairhope Motorcoach Resort Condominium Owners Association, Inc.
U.S. District Court for the Southern District of Alabama · Federal district courts · AL · · No. ACT. NO. 1:22-cv-448-TFM-N · memorandum opinion
On 2026-03-31, U.S. District Court for the Southern District of Alabama publicly reprimanded counsel, ordered payment of $55,597 in fees and costs, required notice in related cases, and referred the matter for discipline. Counsel submitted a filing with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities.
- Disposition
- The court publicly reprimanded counsel, ordered payment of $55,597 in fees and costs, required notice in related cases, and referred the matter for discipline.
- Recorded conduct
- The filing used multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Park v. Kim, 91 F.4th 610, 615 and United States v. McGee, which the court found nonexistent, misquoted, or unsupported. — outcome: referral; actor: lawyer; $55,597
- 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.
Avianca, Inc., 678 F. Supp.3d 443, 448 (S.D.N.Y. 2023). This concept is well known and is a longstanding principle in the practice of law. Yet, the improper use of generative AI is a problem that sadly is not going away despite the general knowledge in the legal community that AI can hallucinate and make up cases. AI hallucination has been reported on extensively in media (not just in the legal context, but at large) and the subject of many seminars and continuing legal education trainings offered by bar associations, articles written in legal journals, and numerous well reported instances of courts sanctioning attorneys. Somehow the message still has not been hammered home as the epidemic of citing fake cases continues unabated. See, e.g. Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024); United States v. McGee, 806 F. Supp. 3d 1264 (S.D. Ala. 2025); Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025); Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341 (E.D.N.Y. 2025); Ferris v. Amazon.com Servs., LLC, 778 F. Supp. 3d 879 (N.D. Miss. 2025); United States v. Hayes, 763 F. Supp. 3d 1054
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