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Courts on AI / Fabricated or misquoted citations

Perry v. Exeter Finance LLC

United States District Court for the District of Arizona · Federal district courts · AZ · · No. Case 2:25-cv-01552-DWL · memorandum opinion

District of Arizona on 2026-02-26 found the self-represented party's filing contained three citation defects, including Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014), Matterhorn, Inc. v. NCR Corp., 763 F.2d.... The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's filing contained three citation defects, including Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014), Matterhorn, Inc. v. NCR Corp., 763 F.2d 866, 868 (7th Cir. 1985) and Anderson v. Dean Witter Reynolds, Inc., 306 F.3d 726 (9th Cir. 2002), involving... — 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.

for at least two cases cited in Plaintiff’s opposition—Anderson v. Dean Witter Reynolds, 24 Inc., 306 F.3d 726 (9th Cir. 2002), and Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014)—the citation provided does not return the case identified. Furthermore, Plaintiff’s 25 opposition misattributes apparently fake quotations to real cases. (See, e.g., Doc. 21 at 12, citing Matterhorn, Inc. v. NCR Corp., 763 F.2d 866, 868 (7th Cir. 1985)). “It appears the 26 incorrect citations may be the result of [Plaintiff] using artificial intelligence to draft [her] filings.” Ghadimi, 2025 WL 2928933 at *4. “But whether [Plaintiff] used artificial 27 intelligence or simply imagined the cases [her]self, filing documents that contain such cases results in confusion and unnecessary work for opposing parties and the court. In the 28 future, filing documents with fictitious cases will subject [Plaintiff] to sanctions under Rule 11.” Id. - 11 - Case 2:25-cv-01552-DWL Document 24 Filed 02/26/26 Page 12 of 28

Authorities cited in the passage: Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014) · Matterhorn, Inc. v. NCR Corp., 763 F.2d 866, 868 (7th Cir. 1985) · Anderson v. Dean Witter Reynolds, Inc., 306 F.3d 726 (9th Cir. 2002) · Inc. v. NCR Corp · Anderson v. Dean Witter Reynolds · Chavez v. Bank of Am., 2014 WL 2159382 · Rule 11

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