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Courts on AI / Fabricated or misquoted citations

Michael Wayne Singletary v. SWBC Mortgage Corporation et al.

U.S. Court of Appeals for the Fifth Circuit · Federal courts of appeals · · No. 25-20441 Lyle W. Cayce · opinion

On 2026-03-17, U.S. Court of Appeals for the Fifth Circuit affirmed dismissal and warned that further failure to check cited authority before filing could lead to sanctions. A self-represented party submitted an opposition brief with multiple fabricated or nonexistent authorities, including Cervantes v. New Century Mortg. Corp.

Disposition
The court affirmed dismissal and warned that further failure to check cited authority before filing could lead to sanctions.
Recorded conduct
The opposition brief used multiple fabricated or nonexistent authorities, including Cervantes v. New Century Mortg. Corp, which the court found nonexistent, misquoted, or unsupported. — 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.

is void for failure to record the transfer in county property records, vitiating his indebtedness. However, he relies heavily on AI- hallucinated case law, and his theory finds no support in our actual case law. 2 Further failure to check the accuracy of cited authority before filing with the Court may result in sanctions. 3 Singletary also raises several arguments which were not asserted below in his Amended Complaint or his opposition to Defendants’ motion to dismiss. For example, he argues that (1) he received inconsistent statements about the “active” status of his loan which violates federal statutory servicing requirements, and (2) he was deprived of his Seventh Amendment right to a jury trial. These contentions are not persuasive, and again Singletary relies predominantly on non-existent case law. Moreover, the arguments were not developed before the district court and are therefore not properly before us. 4 Finally, we see no abuse of discretion 5 in the district court’s finding that _____________________ See Cervantes v. New Century Mortg. Corp., 633 F. App’x 290, 291 (5th Cir. 2016) (per curiam) (“[T]he failure to record a transfer of a mortgage note does not

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