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Courts on AI / Fabricated or misquoted citations

United States v. Farris

U.S. Court of Appeals for the Sixth Circuit · Federal courts of appeals · · No. Name: 26a0105p.06 · opinion

On 2026-04-03, U.S. Court of Appeals for the Sixth Circuit disqualified counsel, denied compensation for time served, locked the briefs, directed notice of the opinion, and referred counsel for discipline. Counsel submitted a brief with nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including United States v. Washington and United States v. Anthony.

Disposition
The court disqualified counsel, denied compensation for time served, locked the briefs, directed notice of the opinion, and referred counsel for discipline.
Recorded conduct
The brief used nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including United States v. Washington and United States v. Anthony, which the court found nonexistent, misquoted, or unsupported. — outcome: referral; actor: lawyer
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.

even when new tools are sponsored by trusted legal technology providers. See Varun Magesh et al., Hallucination-Free? Assessing the Reliability of Leading AI Legal Research Tools, J. of Empirical Legal Stud. 9–16 (2025). No. 25-5623 United States v. Farris Page 5 Further, attorneys who choose to use artificial-intelligence tools must do so in a manner consistent with their ethical obligations. See A.B.A. Task Force on L. & A.I., Addressing the Legal Challenges of AI: Year 2 Report on the Impact of AI on the Practice of Law, 47–48 (2025), https://perma.cc/4JES-DGMU (compiling state bar ethics rules and guidance on generative artificial intelligence). We do not purport to exhaust the full scope of ethical considerations here. But relevant steps may include reviewing and validating content produced by artificial intelligence; considering whether to disclose the use of artificial intelligence to clients or obtain informed consent; safeguarding confidential client information and preserving attorney-client privilege; implementing firm-wide policies governing the use of artificial intelligence; adhering to ethical billing practices when using artificial-intelligence tools; and keeping current with jurisdiction-specific guidelines. New technologies, moreover, are no substitute for tried-and-true safeguards managed by practicing attorneys. Attorneys have an

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