Courts on AI / Fabricated or misquoted citations

USA ex rels. v. Barton Associates, Inc.

United States Court of Appeals for the First Circuit · Federal courts of appeals · 2026-05-28 · No. 25-1309 · order

On 2026-05-28, in USA ex rels. v. Barton Associates, Inc, the First Circuit affirmed dismissal and noted that appellants misrepresented authorities and quoted language absent from cited cases. Counsel filed a reply brief using quotations that did not appear in the cited source and authorities used for propositions they did not support.

Disposition: The court affirmed dismissal and noted that appellants misrepresented authorities and quoted language absent from cited cases.
Recorded conduct: Counsel filed a reply brief using quotations that did not appear in the cited source and authorities used for propositions they did not support. — outcome: other; 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.

Instead, they merely declared that they could "cure[]" any deficiencies and that the 4 In addition to misrepresenting the holdings of several cases in their opening appellate brief, Solano and Maxilin also referenced quotations that do not appear in those cases or in any case that we have been able to find. Then, even after Barton pointed out these errors, Solano and Maxilin filed a reply brief that again cited cases for propositions that the cases do not support and quoted language that the cases do not contain. - 21 - district court had "misapplied the Duxbury standard" in dismissing their complaint. These conclusory assertions do "no more than reiterate the[ir] [earlier] arguments." Palmer, 465 F.3d at 30. And a motion for reconsideration is "not a promising vehicle for revisiting a party's case and rearguing theories previously advanced and rejected." Id. Solano and Maxilin again misrepresent our case law in claiming that we have "repeatedly emphasized" that a "district court abuses its discretion when it fails to articulate any rationale for denying" a Rule 59(e) motion. None of the cases they cite stand for such a proposition.

Authorities cited in the passage: Rule 59(e)

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.

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