Courts on AI / Fabricated or misquoted citations
Christina Leas Dunn v. Nelnet
United States District Court for the Western District of Arkansas · Federal district courts · AR · · No. Case 5:25-cv-05107-TLB · memorandum opinion
Western District of Arkansas on 2026-02-25 in Christina Leas Dunn v. Nelnet found the self-represented party's motions cited several cases that Nelnet said did not exist; the party admitted the citations were incorrect and filed no correction. The court granted Nelnet's motion to dismiss, denied the plaintiff's motions, and dismissed the case without prejudice.
- Disposition
- The court granted Nelnet's motion to dismiss, denied the plaintiff's motions, and dismissed the case without prejudice.
- Recorded conduct
- The self-represented party's motions cited several cases that Nelnet said did not exist; the party admitted the citations were incorrect and filed no correction. — outcome: other; 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.
required before a creditor can enforce a debt. That may be true, but this is not an 4 Nelnet points out in its response to this motion that none of Ms. Dunn’s cited case law actually exists, and Nelnet believes the citations to be AI hallucinations. (Doc. 60, ¶ 15). Ms. Dunn admits in her reply that the citations were incorrect and claims to have corrected them (Doc. 61, ¶ 7), but she did not file an amended or corrected motion. 9 Case 5:25-cv-05107-TLB Document 66 Filed 02/25/26 Page 10 of 10 PageID #: 407 enforcement action by Nelnet against Ms. Dunn—it is Ms. Dunn’s action against Nelnet. Nelnet was directed to provide “the document(s) authorizing it to service Ms. Dunn’s loan,”
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