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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 · · 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 court ordered counsel to show cause by June 5, 2026, why sanctions should not issue for citations to cases that do not exist.
Recorded conduct
Counsel filed a motion using quotations that did not appear in the cited source, at least one nonexistent or hallucinated authority, authorities used for propositions they did not support, and a nonexistent rule or legal standard. — 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.

Rajala referred to is not in the com- plaint, but the secondisasfollows, withexpletivescleanedup for this opinion: Speak for yourself you ugly vial [sic] fake whore. Your ego matches that fake f****** face where you can’t even smile in pictures because your teethare sof*****.The truthhurtsb**** and my message will stay with you forever c***. The manner in which Ms. Rajala took the screenshot did not reveal D’Ambrosio’s alternate phone number or any other identifying information. Despite several opportunities, D’Ambrosio never disputed that he sent this last message un- til oral argument in this appeal. Several users responded to Ms. Rajala’s comments with messages of support and consolation. At least one unidenti- fieduser askedfor informationaboutD’Ambrosio’semployer for the stated purpose of trying to have him fired, but D’Am- brosio does not allege that Ms. Rajala or anyone else disclosed any such information. Another unidentified user with the screenname “Monica Tska” responded with a link to a news article about a man 4 No. 25-2231 charged with sexual assault. ... Rajala, her parents, the STT defendants, and Meta each filed separate motions under Federal Rule of Civil Pro- cedure 12(b)(6) to dismiss the Second Amended Complaint for failure to state a claim. The district court granted the mo- tions, concluded that any further amendment would be futile, and dismissed the case with prejudice. D’Ambrosio appeals. The operative complaint asserts di- versity jurisdiction under 28 U.S.C. § 1332(a).

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