Courts on AI / Fabricated or misquoted citations

D’Agostino v. Circle K Stores Inc.

United States District Court for the District of Arizona · Federal district courts · AZ · 2026-04-23 · No. No. CV-26-01225-PHX-JAT · order

Fabricated or misquoted citationscourt does not name AI

The District of Arizona on 2026-04-22 granted Circle K’s motion to dismiss in part, denied it in part, and identified a nonexistent Navient citation in the complaint in Daniel D’Agostino v. Circle K Stores Incorporated, et al. The self-represented plaintiff filed a motion with one fabricated case citation, including LLC v. Law Offices of Jeffrey Lohman.

Disposition: Circle K’s motion to dismiss was granted in part and denied in part, the sur-reply motion was granted in part and denied in part as moot, and Circle K was ordered to answer the remaining counts.
Recorded conduct: D’Agostino cited Navient Solutions, LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1864871, at *12 (D. Ariz. 2020), but the case does not exist and the Westlaw citation leads to an Ohio Public Utilities Commission order. — outcome: noted, no consequence; 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.

In support of this claim, Plaintiff cites to Navient Solutions, - 18 - LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1864871, at *12 (D. Ariz. 2020). This case does not exist. As Circle K notes in its Motion to Dismiss, a search of “2020 WL 1864871” returns an Ohio Public Utilities Commission Finding and Order titled “In the Matter of the Proper Procedures and Process for the Commission’s Operations and Proceedings During the Declared State of Emergency and Related Matters. ” (Doc. 11 at 13). The Court believes that Plaintiff intended to cite to a case from the Eastern District of Virginia. See Navient Sols.

Authorities cited in the passage: LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1864871, at *12 (D · LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1864871, at *12 (D. Ariz. 2020).' The Court found that citation does not · LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1867939 (E.D. Va. Apr. 14, 2020), which is irrelevant to the claim

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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