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Courts on AI / Fabricated or misquoted citations

Lagac v. Capital One, N.A.

United States District Court for the Central District of California · Federal district courts · CA · · 2026 WL 1454205 · No. 2:26-cv-02964-RGK-MAA · order

Fabricated or misquoted citationsGAI

On 2026-05-22, in Lagac v. Capital One, N.A, the Central District of California warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed opposition papers using quotations that did not appear in the cited source.

Disposition
The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
A self-represented litigant filed opposition papers using quotations that did not appear in the cited source. — outcome: warning; 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.

“Although courts make some allowances for the pro se Plaintiff's failure to cite to proper legal authority, courts may not condone actions by a party who cites to false, nonexistent, or misleading authorities.” Meriland Keith Dillard v. CBS Studios, Inc., 2026 WL 790882, at * 11 (C.D. Cal. Mar. 16, 2026) (internal quotation marks omitted). Plaintiff is reminded that all litigants, including those proceeding pro se, are expected to ensure the validity of all sources cited in their filings. See Fed. R. Civ. P. 11(b); Munoz v. United States, 28 F.4th 973, 978 (9th Cir. 2022) (“[I]t is axiomatic that pro se litigants, whatever their ability level, are subject to the same procedural requirements as other litigants.”). Government Works.

Authorities cited in the passage: Meriland Keith Dillard v. CBS Studios · Munoz v. United States, 28 F · Fed. R. Civ. P. 11(b)

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