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Courts on AI / Fabricated or misquoted citations

Nesbitt v. Trans Union, LLC

United States District Court for the Western District of Arkansas · Federal district courts · AR · · No. 5:26-CV-05085-DCF · order

The Western District of Arkansas sanctions Nicholas Nesbitt in a consumer-credit case by imposing filing restrictions. The court says he relied on AI for legal research and writing, filed at least two motions with fabricated cases, apologized after a Rule 11 show-cause order, and continued filing improper papers.

Disposition
The court imposed filing restrictions on Nesbitt and denied defendants' request for a Rule 16 conference.
Recorded conduct
Self-represented plaintiff relied on AI and filed at least two motions with fabricated cases plus many improper filings misrepresenting rules. — outcome: sanctions; 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.

Since then, Plaintiff has filed numerous replies without leave of Court, repetitive notices and motions, and at least two motions relying on fabricated cases. ... On July 17, 2026, the undersigned ordered Plaintiff to show cause why he should not be sanctioned under Federal Rule of Civil Procedure 11(b) for citing nonexistent case law in his motions. (Doc. 131). Plaintiff apologized to the Court for relying on artificial intelligence to assist him in conducting legal research and writing pleadings. (Doc. 132). Plaintiff assured the Court that he would never again submit a filing containing fabricated cases. ... Most concerning to the Court is Plaintiff’s reliance on artificial intelligence for legal research and writing, which facilitates rapid filing of numerous documents, many containing fabricated caselaw and misrepresentation of federal rules, within just a few hours. ... IT IS HEREBY ORDERED that the Clerk of Court is DIRECTED to accept no further pleadings or motions from Plaintiff without prior approval from the Court or pursuant to a Court Order.

Authorities cited in the passage: Fed. R. Civ. P. 11 · Bass v. General Motors Corp., 150 F.3d 842 (8th Cir. 1998) · Vallejo v. Amgen, Inc., 903 F.3d 733 (8th Cir. 2018)

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub