Courts on AI / Fabricated or misquoted citations

Nikko D’Ambrosio v. Meta Platforms Inc.

United States Court of Appeals for the Seventh Circuit · Federal courts of appeals · 2026-05-15 · No. 25-2231 · order

On 2026-05-15, in Nikko D’Ambrosio v. Meta Platforms Inc, the Seventh Circuit ordered counsel to show cause by June 5, 2026, why sanctions should not issue for citations to cases that do not exist. Counsel filed a motion using quotations that did not appear in the cited source, at least one nonexistent or hallucinated authority, authorities.

Disposition: The Seventh Circuit ordered counsel to show cause why sanctions should not issue for a brief bearing hallmarks of generative AI.
Recorded conduct: Counsel’s filing contained nonexistent authority, fabricated quotations, mischaracterized authority, and a nonexistent legal standard. The court found hallmarks of generative AI and issued an order to show cause. — outcome: pending; 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.

both practice, boasts of the ﬁrm’s extensive incorporation of artiﬁcial intelligence into all areas of its representation. See How Marc Trent Uses AI to Deliver Cutting-Edge Legal Solutions, MarcTrent.ai (Dec. 3, 2025), https://perma.cc/6UHF-ABK2. Without making any broad judgments about the use of artiﬁ- cial intelligence for help in drafting briefs, however, regard- less of how these particular errors came about, “submission of a brief with numerous ﬁctitious citations and quotations is a serious dereliction of counsel’s duty to serve as an oﬃcer of the court. ‘Citing nonexistent case law or misrepresenting the holdings of a case is making

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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