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Courts on AI / Fabricated or misquoted citations

Kevin D. Turnage v. Robert F. Kennedy, Jr., et al.

U.S. District Court for the District of Arizona · Federal district courts · AZ · · No. CV-25-03367-PHX-SMB · order

On 2026-04-02, U.S. District Court for the District of Arizona denied the plaintiff’s pending motions and warned that further false citations, including AI hallucinations, may warrant sanctions. A self-represented party submitted a complaint with nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Gao v. United States and Miller v. United States.

Disposition
The court denied the plaintiff’s pending motions and warned that further false citations, including AI hallucinations, may warrant sanctions.
Recorded conduct
The complaint used nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Gao v. United States and Miller v. United States, 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.

Wash. Oct. 22, 2025). Second, courts have dismissed cases based on litigants filing “frivolous and duplicative motions [which] needlessly disrupted the litigation and burdened the court and opposing counsel.” See, e.g., Scott v. Cunningham, 516 F. App’x 672, 673 (9th Cir. 2013). Third, the Court will not tolerate any further “presentation of false citations, including AI ‘hallucinations.’” See Stafford, 2026 WL 799409, at *2. The Court notes that Plaintiff cited more hallucinated cases than highlighted herein. Any further abuses of AI may warrant sanctions. VII. CONCLUSIONS Accordingly, IT IS HEREBY ORDERED granting Plaintiff’s Motion for Leave to File Fourth Amended Complaint (Doc. 60). IT IS FURTHER ORDERED denying the following motions: Plaintiff’s Motion to Stay Administrative Inquiry (Doc. 13); Plaintiff’s First Motion to Amend (Doc. 36); Plaintiff’s Motion to for a Protective Order and to Compel Meet and Confer (Doc. 44); Plaintiff’s Second Motion to Amend (Doc. 50); Plaintiff’s Motion for Leave to Serve Third-Party Subpoena (Doc. 51); Plaintiff’s Third Motion to Amend (Doc. 55); Plaintiff’s Motion to Compel Final Agency Decision (Doc. 57); Plaintiff’s Motion to Compel Filing of Responsive Pleading (Doc. 58); Plaintiff’s Motion to Deem Unopposed and Grant Motion to Compel Final Agency Decision (Doc. 59); and Plaintiff’s Motion to Submit Pending Motions for Decision (Doc. 64). Dated this 2nd day of April, 2026.

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