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Courts on AI / Fabricated or misquoted citations

Perry v. Merrick Bank Corporation

United States District Court for the District of Arizona · Federal district courts · AZ · · No. 2:25-cv-02297 · order

On 2026-06-09, in Perry v. Merrick Bank Corporation, the District of Arizona dismissed the complaint without leave to amend and noted the plaintiff's prior hallucinated citations in related litigation. A self-represented litigant filed a response using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.

Disposition
The court granted the motion to dismiss, denied leave to amend, and terminated the case.
Recorded conduct
The order cited a related Perry case in which the pro se plaintiff had filed at least one hallucinated citation and fake quotations misattributed to real cases. The current dismissal and denial of leave rested on preclusion, futility, and similar litigation tactics. — outcome: dismissal; 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.

2026) (granting defendant’s motion to compel arbitration, in response to Plaintiff’s “90-page complaint [that] assert[ed] 18 causes of action under federal and state law,” and noting that Plaintiff’s filings included at least one “hallucinated citation” as well as “fake quotations” misattributed to real cases). … … … Court Action. Restatement (Second) of Judgments § 13, cmt. f (1982) (“The better view is that a judgment otherwise final remains so despite the taking of an appeal . . . .”). - 13 - Accordingly, IT IS ORDERED that Defendant’s motion to dismiss (Doc. 17) is granted.

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