Courts on AI / Fabricated or misquoted citations
Kisha Peters v. Banner Health
United States Court of Appeals for the Fifth Circuit · Federal courts of appeals · · No. 26-20035 · order
On 2026-06-04, in Kisha Peters v. Banner Health, the Fifth Circuit struck the defective appellate filings, admonished the appellant, and warned that additional violations could draw sanctions. A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.
- Disposition
- The court struck the defective appellate filings, admonished the appellant, and warned that additional violations could draw sanctions.
- Recorded conduct
- A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities. — 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.
motions and other papers that “strain[ed] the [district] [c]ourt’s ability to manage its docket efficiently.” After a four-month span in which she filed fifty-five motions, the court ordered that Peters “must request leave of court before filing any Motion, Notice, Request, or any other document.” Peters repeatedly violated this and other explicit court orders by filing discovery requests without seeking leave of court and filing motions exceeding a court- orderedpagelimit.Shealsoignoredcourtinstructionstoceasefilingmotions containing legal citations and quotations hallucinated by generative artificial intelligence. The court repeatedly struck her motions and discovery filings for failing to comply with its orders. Peters’ conduct was so disruptive that the magistrate judge observed in a December 2025 discovery hearing that Peterswas“excessivelyusingCourtresources”andhadmadeit“impossible to litigate this case.” Peters’conductculminatedinDecember2025whensherefusedtosit for a court-ordered follow-up deposition. She had sat for an initial deposition on December 3, 2025, but continually objected and refused to answer questions in what the court described as a “calculated campaign of obstruction.” At a hearing on December 8, the magistrate judge ordered Peters to sit for a follow-up deposition on December 12 and extended the discovery deadline to that date. Peters refused to appear for the follow-up deposition and invited Banner to seek dismissal.