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Courts on AI / Fabricated or misquoted citations

Chelsea Montes v. Suns Legacy Partners LLC

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

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 ordered cost reimbursement, remedial AI education, and notice measures after finding counsel’s filed motion contained fake cases and quotations.
Recorded conduct
The motion cited fake cases and quotations, including supposed Arizona privilege authorities, that looked real but did not exist as cited. — outcome: costs order; 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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