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Courts on AI / Fabricated or misquoted citations

Montes v. Suns Legacy Partners LLC

United States District Court for the District of Arizona · Federal district courts · AZ · · No. CV-25-01295-PHX-GMS · order

Fabricated or misquoted citations

On 2026-03-31, U.S. District Court for the District of Arizona ordered cost reimbursement, remedial AI education, and notice measures after finding counsel’s filed motion contained fake cases and quotations. Counsel submitted a motion with The motion cited fake cases and quotations, including supposed Arizona privilege authorities, that looked real but did not exist as cited.

Disposition
The court granted in part and denied in part the partial motion to dismiss, denied the motion to strike, and granted Rule 11 sanctions requiring fee shifting, client notice, AI ethics CLE, and service of the order on bar authorities and district judges.
Recorded conduct
Plaintiff's counsel Sheree Wright and Cortney Walters filed at least 18 fictitious citations or fictitious quotations across the complaint, the response to the motion to dismiss, the reply supporting anonymity, and a reply supporting leave to file out of time; counsel later filed errata but did not take responsibility for the filings. — outcome: regulatory referral; 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.

from an actual case” that “looks correct.” Francis & Jarral, supra, at 5-6; see also Hayes, 763 F. Supp. 3d at 1065 (“fictitious case citations created by generative AI tools” can “look[] like a real case with a case name”). Thus, Defendant’s adjustment of language in the filed motion, by noting that some of the fictitious “case[s] do[] not exist as cited,” does not substantially alter the grounds of Defendant’s served motion. (Doc. 50 at 8 (emphasis added)). The contention is still the same argument: Plaintiff’s counsel included fabricated cases and quotations that bear the characteristics of AI-hallucinated content.21 20 Defendant notes that it “adjusted certain language from ‘Case does not exist’ in the served version of the motion to ‘Case does not exist as cited’ in the filed motion to distinguish two forms of fake citations found in the offending filings: (1) fake citations where there is not even a case with the same name, and (2) fake citations that include the name of a real case, but which are otherwise fabricated—with made-up dates, courts, or Westlaw or reporter numbers—and where the real case with the same name generally

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