Courts on AI / Fabricated or misquoted citations

Doe 1, et al. v. Shirley Lai, et al.

United States District Court for the Central District of California · Federal district courts · CA · 2026-02-17 · No. EDCV 25-3485 JGB (DTBx) · memorandum opinion

Fabricated or misquoted citations

Central District of California on 2026-02-17 found defense counsel attributed a quotation to Headley that the court could not locate and cited Dann for a proposition the court could not find. The court denied the motion to dismiss, granted judicial notice, and ordered defense counsel to produce authorities or explain why sanctions should not issue.

Disposition: The court ordered defense counsel to provide sources and show cause why sanctions should not issue for false quotations and citations.
Recorded conduct: Lai’s motion contained false quotations and citations, including quotations from Headley and propositions from Dann that were not in the cited cases. — 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.

As an initial matter, Defendant’s Motion appears to contain false citations and quotations. Specifically, Defendant provides at least one false quotation that the Court can nowhere identify in the cited case, nor any other case. Defendant also cites cases for propositions found nowhere in those cases. Such misquotations, miscitations, and misrepresentations often indicate the presence of artificial intelligence-generated hallucinations.

Authorities cited in the passage: Rule 11(b)

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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