Courts on AI / Fabricated or misquoted citations
Nia Elan Davis v. American Airlines, et al.
United States District Court for the District of Arizona · Federal district courts · AZ · · 2026 WL 444958 · No. No. CV-25-01992-PHX-KML · order
District of Arizona on 2026-02-17 in Nia Elan Davis v. American Airlines, et al. found the self-represented party's opposition cited a fictitious case, then withdrew the citation after the defendant requested dismissal as a sanction. The court granted the motion to dismiss, entered judgment for American Airlines, and did not impose sanctions after the plaintiff withdrew the fictitious citation.
- Disposition
- The court granted the motion to dismiss, entered judgment for American Airlines, and did not impose sanctions after the plaintiff withdrew the fictitious citation.
- Recorded conduct
- The self-represented party's opposition cited a fictitious case, then withdrew the citation after the defendant requested dismissal as a sanction. — outcome: sanctions; 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.
third amended complaint. Davis responded to this motion Davis filed her original complaint on June 9, 2025. (Doc. 1.) and requested leave to amend if her complaint was found A little over one month later, Davis filed a “Motion to Accept insufficient. (Doc. 35 at 4.) Davis's opposition also contained Waiver of Service.” (Doc. 13.) The court denied that motion a citation to a non-existent case. (Doc. 35 at 4.) American after explaining it was not appropriate because it would be Airlines's reply argued the fictitious citation merited sanctions up to American Airlines to object to the adequacy of service. in the form of dismissal. (Doc. 38 at 10.) (Doc. 14 at 1.) The court informed Davis that although she was proceeding pro se, she was required to comply with the *2 On January 15, 2026, Davis filed a “Notice of Correction same rules of procedures that apply to all litigants. Davis and Request for Leave to Amend.” (Doc. 39.) In that was also instructed to “ensure her filings compl[ied] with all notice, Davis sought to withdraw the fictitious citation in applicable rules and procedures.” (Doc. 14 at 1.) Despite those her opposition. Davis also requested leave to amend the warnings, on July 25, 2025, Davis filed another “Motion to complaint if the motion to dismiss was granted. (Doc. 39.) Accept Waiver of Service.” (Doc. 20.) The court issued a Given that Davis had already made a request for leave to second order denying the motion as “baseless” and reminding amend, it is not clear why she made this separate request. Davis she was risking sanctions by ignoring court orders. (Doc. 23 at 2.) Turning to the substance, the third amended complaint begins by stating Davis “was subjected to adverse treatment based