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Courts on AI / Fabricated or misquoted citations

Eliott Williamson v. TransUnion LLC, Experian Information Solutions, Inc.

United States Court of Appeals for the Eleventh Circuit · Federal courts of appeals · · No. 3:24-cv-00043-WWB-PDB · opinion

The Eleventh Circuit on 2026-05-04 affirmed dismissal with prejudice after the magistrate judge found willful misuse of nonexistent and misquoted cases in Eliott Williamson v. TransUnion LLC, Experian Information Solutions, Inc. The self-represented party filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation.

Disposition
The Eleventh Circuit affirmed dismissal with prejudice after the magistrate judge found willful misuse of nonexistent and misquoted cases.
Recorded conduct
The self-represented party filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation. — 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.

At this second show-cause hearing, Williamson stated that the errors were unintentional and based on his lack of legal knowledge. He admitted that some of the cases he cited did not exist, and that he had found them using artificial intelligence. He also admitted that he did not follow the Local Rules because they were confusing to him as a pro se litigant and he could not locate them. The magistrate judge found that Williamson’s errors were USCA11 Case: 25-13045 Document: 29-1 Date Filed: 05/04/2026 Page: 3 of 6 4 Opinion of the Court 25-13045 “some of the most egregious things” she had seen from a pro se litigant,” and that she had given him many chances to comply with theLocalRulesandcourtorders, andhadtoldhimwherehecould findthem. Themagistratejudgeultimatelystayedthelitigationsua sponte to consider the arguments presented at the hearing.

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