Meriland Keith Dillard v. CBS Studios, Inc.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

(denying leave to amend where it “would unduly prolong resolution of this protracted litigation, and it would unduly prejudice Defendants by forcing them to continue to defend against meritless claims”). Plaintiff’s submissions in this case may have been prepared by using generative artificial intelligence. Plaintiff’s filings have misrepresented the Works at issue here and have mischaracterized Defendant’s conduct and the prior orders issued in this case. See Goddard v. Sares-Regis Grp. Inc.., No. 25-CV- 5882, 2025 WL 2969295, at *3 (N.D. Cal. Oct. 21, 2025) (systematic factual misrepresentations are indicia of generative artificial intelligence). Plaintiff’s unauthorized supplemental briefing contains images that appear to have been created by generative artificial intelligence. 12 See Dkt. 64. Plaintiff’s 12 The images in this brief contain nonsensical spellings that are characteristic of images generated by artificial intelligence. See Dkt. 64 at 12 (“Twombly/idqal + Three Bays”); id. (“Access need not be proven beyond doubt– only alausibly.”); id. at 11 (“Comedie Freeze”); id. at 11 (“cafeteira tone”); id. at 11 (“Misúrstranding”); see also Amanda Silberling, Why Is AI So Bad At Spelling? Because Image Generators Aren’t Actually Reading Text, Page 12 of 18 Case 8:25-cv-02091-JAK-KES Document 73 Filed 03/16/26 Page 13 of 18 Page ID #:760 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES – GENERAL Case No. 8:25-cv-02091-JAK (KESx) Date March 16, 2026 Title Meriland Keith Dillard v. CBS Studios, Inc. opposition also cites to several opinions that do not exist, 13 which is a hallmark of the “hallucinations” observed in the use of generative artificial intelligence to conduct legal research and drafting. See United States v. Hayes, 763 F. Supp. 3d 1054, 1065 (E.D. Cal. 2025) (“The citation has all the markings of a hallucinated case created by generative artificial intelligence (AI) tools such as ChatGPT and Google Bard that have been widely discussed by courts grappling with fictitious legal citations and reported by national news outlets.”). 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. James v. Wadas, 724 F.3d 1312, 1315 (10th Cir. 2013); see also 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.”). Like every other person who appears before a federal court, Plaintiff has an obligation under Rule 11 to confirm that his arguments are supported by the facts and the law. Plaintiff failed to meet that obligation here. The unsupported theories and legal contentions advanced by Plaintiff, which appear to be the result of his use of generative artificial intelligence, further confirm that granting leave to amend will allow Plaintiff to raise additional unsupported allegations. See, Alexande

Authorities cited in the passage: Jorgensen v. CBS, Inc., 728 F.2d 958 (8th Cir. 1984) · Lamon v. Godbolt, 2015 WL 13647670 (C.D. Cal. Mar. 30, 2015) · Twombly/idqal + Three Bays · Comedie Freeze · F.2d 953 is United States v. Johns · See United States v. Hayes · James v. Wadas · Munoz v. United States · Rule 11