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Courts on AI / Fabricated or misquoted citations

Federal Trade Commission v. James D. Noland, Jr., et al.

U.S. District Court for the District of Arizona · Federal district courts · AZ · · No. CV-20-00047-PHX-DWL · order

Fabricated or misquoted citations

On 2026-03-31, U.S. District Court for the District of Arizona denied the emergency stay request and warned the self-represented movant that future inaccurate citations may expose him to sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities, including Ghadimi v. Ariz. Bank & Trust.

Disposition
The court denied the emergency stay request and warned the self-represented movant that future inaccurate citations may expose him to sanctions.
Recorded conduct
The motion used fabricated or nonexistent authorities, including Ghadimi v. Ariz. Bank & Trust, which the court found nonexistent, misquoted, or unsupported. — outcome: warning; 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.

logical vehicle for seeking some of the categories of relief sought in the emergency stay request. provision of future inaccurate citations may expose them to sanctions. Ghadimi v. Ariz. Bank & Trust, 2025 WL 2928933, *4 (D. Ariz. 2025) (“Ghadimi is proceeding pro se but he still must follow the same rules of procedure that govern other litigants. . . . It appears the incorrect citations may be the result of Ghadimi using artificial intelligence to draft his filings. But whether Ghadimi used artificial intelligence or simply imagined the cases himself, filing documents that contain such cases results in confusion and unnecessary work for opposing parties and the court. In the future, filing documents with fictitious cases will subject Ghadimi to sanctions under Rule 11.”) (citations omitted). Accordingly, IT IS ORDERED that: 1. The Individual Defendants’ Rule 60(b) motion (Doc. 618) is denied. 2. The Individual Defendants’ emergency stay request (Doc. 625) is denied. Dated this 31st day of March, 2026.

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