Courts on AI / Fabricated or misquoted citations

Ryan-Michael Jarvis v. County of Teton Wyoming

United States Court of Appeals for the Tenth Circuit · Federal courts of appeals · 2026-04-24 · 2026 WL 1122106 · No. 25-8034 · opinion

Fabricated or misquoted citations

The Tenth Circuit on 2026-04-24 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Ryan-Michael Jarvis v. County of Teton Wyoming. The self-represented party filed a pleading with one false case quotation and one mischaracterized case citation, including Spinelli v. United States that does not appear in the opinion.

Disposition: The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct: The self-represented party filed a pleading with one false case quotation and one mischaracterized case citation. — outcome: warning; 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.

S. 213 (1983): “The mere assertion of a complaint ... without corroboration or personal knowledge of a crime, fails to establish probable cause. ” Aplt. Opening Br. at 21 (alteration in original) (internal quotation marks omitted). But we cannot find this quote (or any similar proposition) in Spinelli. Nor does the quotation appear in any other federal or state case. We therefore suspect that Mr. Jarvis's quotation is a fabrication generated by his use of a generative artificial intelligence (AI) tool. Cf. Wadsworth v. Walmart Inc. , 348 F. R. D. 489, 497 (D. Wyo. 2025) (“It is ... well-known in the legal community that AI resources generate fake cases. ”).

Authorities cited in the passage: Cf. Wadsworth v. Walmart Inc. , 348 F · Appellant attributed a quotation to Spinelli v. United States that does not appear in the opinion · Appellant cited Meechaicum v. Fountain for a holding about Eighth Amendment claims that the cour

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

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