Courts on AI / Fabricated or misquoted citations

United States ex rel. Solano v. Barton Associates, Inc.

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

Fabricated or misquoted citationscourt does not name AI

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 denial of reconsideration without imposing a consequence for the misquoted authorities.
Recorded conduct: Relators’ opening brief misrepresented holdings and quoted language that did not appear in the cited cases or any case the court found; the reply repeated unsupported propositions and nonexistent quotations after appellee pointed out the errors. The court affirmed and imposed no consequence. — outcome: noted, no consequence; 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 copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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