Courts on AI / Fabricated or misquoted citations

Harris v. Elementis Specialties, Inc.

United States District Court for the Central District of California · Federal district courts · CA · 2026-04-17 · 2026 WL 1104324 · No. No. EDCV 26-00171-KK-DTBx · order

Fabricated or misquoted citations

The Central District of California on 2026-04-17 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Robert Harris v. Elementis Specialties, Inc. Counsel filed a motion with one fabricated case citation and one mischaracterized case citation.

Disposition: Plaintiff’s motion for sanctions against Elementis and its counsel was denied, but the court warned that it would note the incident if similar AI-related mistakes occur in future litigation.
Recorded conduct: Elementis’s counsel used AI in a motion to dismiss and produced several citation errors, including a completely hallucinated citation and other authorities that did not support the asserted propositions; counsel failed to alert the court after discovering the misrepresentations. — outcome: warning; 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.

Plaintiff argues Defendant's Motion to Dismiss was filed “without reliable legal support” and cites “multiple authority defects. ” Mot. at 11. Among other things, Plaintiff cites (and Defendant has confirmed) its use of AI resulted in several citation errors, including a completely hallucinated cite and other cites that do not support the proposition Defendant's claimed they did. See id. at 11-13. While the Court agrees with Plaintiff that Defendant's failure to verify authority it cited in its filing before a federal court is inexcusable, the Court cannot conclude Defendant “knowingly or recklessly raise[d] a frivolous argument. ”1 In re Keegan Mgmt.

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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