Courts on AI / Fabricated or misquoted citations
Robinson v. Oglala Sioux Tribe
United States Court of Appeals for the Tenth Circuit · Federal courts of appeals · · No. 25-6143 · order
The Tenth Circuit affirms dismissal of Shantell Robinson’s claims with prejudice as a Rule 11 sanction. The order describes nonauthentic evidence, at least four filings with nonexistent or misrepresented authority, and a new appellate brief citation to the nonexistent Reynolds v. Smith case.
- Disposition
- The Tenth Circuit affirmed dismissal with prejudice as a Rule 11 sanction for Robinson's litigation misconduct.
- Recorded conduct
- Self-represented plaintiff filed nonauthentic evidence and multiple filings with nonexistent, misrepresented, or falsely quoted legal authorities. — 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.
The district court’s order detailed the clear and convincing evidence it relied on to determine that Ms. Robinson’s conduct was sanctionable. The court noted that despite her claims that her emergency motion was “grounded in fact,” Ms. Robinson submitted “no evidence to support the veracity of the purported intercepted statements” about Mr. Raines following her, and admitted she submitted a photo that was “not authentic” as an exhibit to one of her filings. ... The court further noted that at least four of Ms. Robinson’s filings contained non-existent and misrepresented legal authority, and cited caselaw establishing that failure “to confirm the validity of any cited legal authority” may violate Rule 11. ... Ms. Robinson also claims on appeal that “[a]ll case citations are verifiable,” and that she never submitted any fake or AI-hallucinated cases. Aplt. Opening Br. at 2. But this is not true. In fact, Ms. Robinson relied on a hallucinated case in her opening brief on appeal. See id. at 2 (citing a non-existent case called “Reynolds v. Smith, 62 F.3d 1421 (10th Cir. 1995)”). ... For example, in Ms. Robinson’s opposition to WLCC’s and Mr. Raines’s motion to dismiss, she cited “Navajo Nation Oil & Gas Co. v. Window Rock Unified Sch. Dist., 638 F. App’x 698 (10th Cir. 2016).” Aplee. Supp. App. vol. III at 256. But the case found at 638 F. App’x 698 is Sayed v. Broman. On the same page, Ms. Robinson quotes Lewis v. Clarke, 581 U.S. 155 (2017), as stating, “tribal immunity does not extend to individuals acting outside their official capacity,” but that quote does not exist in the case. Id. ... The district court did not abuse its discretion by dismissing Ms. Robinson’s claims with prejudice as a sanction for her litigation misconduct.
Authorities cited in the passage: Fed. R. Civ. P. 11 · Ehrenhaus v. Reynolds, 965 F.2d 916 (10th Cir. 1992) · Sanders v. United States, 176 Fed. Cl. 163 (2025) · Reynolds v. Smith, 62 F.3d 1421 (10th Cir. 1995) · Navajo Nation Oil & Gas Co. v. Window Rock Unified Sch. Dist., 638 F. App'x 698 (10th Cir. 2016) · Lewis v. Clarke, 581 U.S. 155 (2017)