Courts on AI / Fabricated or misquoted citations
Downing v. Dwayne Brown, et al.
United States Court of Appeals for the Eleventh Circuit · Federal courts of appeals · · No. 25-14133 · order
On 2026-05-20, in Downing v. Dwayne Brown, et al, the Eleventh Circuit struck fabricated-authority portions of the brief and affirmed dismissal. A self-represented appellant filed an appellate brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and nonexistent or hallucinated authorities.
- Disposition
- The court struck fabricated-authority portions of the brief and affirmed dismissal.
- Recorded conduct
- A self-represented appellant filed an appellate brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and nonexistent or hallucinated authorities. — outcome: other; 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.
First, Downing’s argument is supported almost exclusively by fabricated legal authorities. Throughout her appellate brief, USCA11 Case: 25-14133 Document: 14-1 Date Filed: 05/20/2026 Page: 4 of 8 25-14133 Opinion of the Court 5 Downing relies on precedents that do not exist. For example, she quotes UnitedStatesv. Jones, 29 F.4th 1290, 1294 (11th Cir. 2022), as providingthat“[C]ourtsmustconfinethemselvestotherecordde- veloped in the proceeding before them.” Neither that precedent nor the quoted text exists in any of this Court’s precedents in any form. She also provides seemingly fake quotations from real prec- edents. For example, she says our real decision in In re Worldwide Web Sys., Inc., 328 F.3d 1291, 1299 (11th Cir. 2003), includes the holdingthat“Dueprocessrequiresthatapartybegivennoticeand an opportunity to respond before a court takes adverse action based on disputed factual matters.” But that precedent addresses service of process and does not include anything like the alleged quotation. Although we give liberal construction to the filings of pro se litigants, “we nevertheless have required them to conform to procedural rules.” Loren v. ... And to conclude that Downing was not the administrator of her father’s estate, the district court referred to the Fulton County Probate Court’s order appointing Luanne Bonnie to that role. These records had already been filed as exhibits in another case pending before the same district judge. USCA11 Case: 25-14133 Document: 14-1 Date Filed: 05/20/2026 Page: 6 of 8 25-14133 Opinion of the Court 7 See United States v. Glover, 179 F.3d 1300, 1302 n.5 (11th Cir. 1999) (“a court may take judicial notice of its own records . . . .”). Finally,werejectDowning’scontentionthatshewasdenied an adequate opportunity to be heard.
Authorities cited in the passage: Opinion of the Court 7 See United States v. Glover, 179 F