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Courts on AI / Fabricated or misquoted citations

Segui v. Moniz

U.S. District Court for the District of Arizona · Federal district courts · AZ · · No. CV-25-01849-PHX-SHD · order

On 2026-03-24, U.S. District Court for the District of Arizona ordered plaintiffs’ counsel to show cause why sanctions should not be imposed for citing a nonexistent Arizona RICO limitations case. Counsel submitted a motion with fabricated or nonexistent authorities, including Barker v. Brown & Brown, 210 Ariz. 321, 110 P.3d 1011.

Disposition
The court ordered plaintiffs’ counsel to show cause why sanctions should not be imposed for citing a nonexistent Arizona RICO limitations case.
Recorded conduct
The motion used fabricated or nonexistent authorities, including Barker v. Brown & Brown, 210 Ariz. 321, 110 P.3d 1011, which the court found nonexistent, misquoted, or unsupported. — outcome: pending; actor: lawyer
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.

(Doc. 26 at 20.) This case does not exist. Additionally, the proposition for which it is cited is also incorrect: the four-year period established by Agency Holding Corp., 483 U.S. 143 (1987), applies to federal civil RICO claims only. Arizona’s private RICO action is governed by the three-year period set forth in A.R.S. § 13-2314.04(F). Citation to nonexistent authority is a serious matter that implicates counsel’s obligations under Federal Rule of Civil Procedure 11(b)(2) to certify that all legal citations are warranted by existing law and are the product of reasonable inquiry. The fabrication of legal citations, whether through artificial intelligence or otherwise, undermines the integrity of the judicial process. Pursuant to Federal Rule of Civil Procedure 11(c)(3), which authorizes the Court on its own initiative to “order an attorney, law firm, or party to show cause why conduct specifically described in the order has not violated Rule 11(b),” the Court will order Plaintiffs’ counsel to show cause in writing why sanctions should not be imposed for citation to a nonexistent case. For the reasons stated above, /// IT IS ORDERED that Defendant Gregg Woodnick’s Motion to Dismiss (Doc. 18)

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