Courts on AI / Fabricated or misquoted citations
Jabbari v. Omidvar
United States District Court for the Central District of California · Federal district courts · CA · · 2026 WL 2227350 · No. 2:26-cv-03553-FLA (DTBx) · order
The Central District of California manages a transferred pro se case by striking improper filings and imposing filing limits. The court says Jabbari’s papers contain AI hallmarks and fabricated legal authorities, then orders him to show cause why Rule 11 or inherent-authority sanctions should not issue.
- Disposition
- The court struck improper filings, restricted further filings, and ordered Jabbari to show cause why sanctions should not issue.
- Recorded conduct
- Self-represented plaintiff filed vexatious papers with fabricated and unsubstantiated legal authorities showing hallmarks of generative-AI use. — outcome: pending; 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.
The court also ORDERS Plaintiff to Show Cause (“OSC”) in writing, on or before August 17, 2026, why sanctions should not be imposed under Federal Rule of Civil Procedure Rule 11 and the court's inherent authority, for Plaintiff's submission of frivolous and vexatious filings and/or false and fabricated legal citations. ... Plaintiff's filings bear hallmarks often associated with the use of generative AI programs, including the prompts Plaintiff used to generate results from these programs, tonal and textual inconsistencies, and the inclusion of fabricated and unsubstantiated (commonly referred to as “hallucinated”) legal authorities. ... Plaintiff is reminded that generative AI tools are known to “hallucinate” and fabricate legal citations and case law that do not exist or are incorrectly applied. Plaintiff bears the duty to verify the accuracy, existence, and validity of every legal citation and reference submitted to the court, and is warned that the submission of false, fabricated, and AI “hallucinated” legal authorities will result in the imposition of sanctions, which could include: (a) monetary sanctions to compensate Defendants for any and all attorney's fees and costs reasonably incurred in responding to documents that contain such statements; (b) monetary sanctions exceeding $1,000 payable to the court; and sanctions under Rule 11(b).
Authorities cited in the passage: Fed. R. Civ. P. 11