Courts on AI / Fabricated or misquoted citations

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. No. 25-8034 · order

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 dismissal was affirmed; the court disregarded Jarvis’s fabricated quotation, declined sanctions, and warned litigants to verify quotations and authorities.
Recorded conduct: Jarvis’s pro se opening brief included a quotation attributed to Spinelli that the court could not find in Spinelli or any other case, and it attributed to Meechaicum a holding that is not found there; the court suspected both were AI-generated fabrications. — 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: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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