Courts on AI / Fabricated or misquoted citations
Robert Harris v. Elementis Specialties, Inc.
United States District Court for the Central District of California · Federal district courts · CA · · 2026 WL 1104324 · No. EDCV 26-00171-KK-DTBx · order
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
- The court warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
- Recorded conduct
- Counsel filed a motion with one fabricated case citation and one mischaracterized case citation. — 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.
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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