Courts on AI / Fabricated or misquoted citations
Lohbeck v. Amazon.com Services, LLC
United States District Court for the Eastern District of California · Federal district courts · CA · · No. 2:26-cv-02007-DC-CSK · report and recommendation
The Eastern District of California recommends dismissal of Stephen Lohbeck’s claims and considers Amazon’s Rule 11 argument. The magistrate judge finds two quotations in Lohbeck’s sanctions motion do not appear in the cited cases, declines sanctions because he is self-represented, and warns that future false authority may be sanctionable.
- Disposition
- The magistrate judge recommended dismissal and warned the self-represented plaintiff about misquotations suggesting AI use.
- Recorded conduct
- Self-represented plaintiff’s sanctions motion attributed quotations to two cases, but the quoted language did not appear in either opinion. — 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.
Defendant argues Plaintiff has violated Federal Rule of Procedure 11 by misusing generative artificial intelligence (“generative AI”). See Def. Sanctions Opp. at 6-7 (ECF No. 21). Specifically, Defendant argues Plaintiff’s writing contains generative AI hallmarks and that for each case Plaintiff cites with a parenthetical, the quoted language is absent from the cited opinion. ... Defendant is correct that in Plaintiff’s motion for sanctions, Plaintiff attributes quotations to two different cases, but the language Plaintiff quoted does not actually appear in either case. See Def. Sanctions Opp. at 6-7; Pl. Sanctions Mot. at 1. The Court has concerns that Plaintiff’s submissions to the Court have misquotations of cases, which suggest an irresponsible use of generative AI. “Such misquotations, miscitations, and misrepresentations often indicate the presence of artificial intelligence-generated hallucinations.” Doe 1 v. Lai, 2026 WL 1004947, at *1 (C.D. Cal. Feb. 17, 2026). ... Though the Court is concerned by Plaintiff’s misquotations in his sanctions motion that indicate the irresponsible use of generative AI, given Plaintiff’s pro se status, the Court declines at this time Defendant’s invitation to impose sanctions.
Authorities cited in the passage: Fed. R. Civ. P. 11 · Doe 1 v. Lai, 2026 WL 1004947 (C.D. Cal. Feb. 17, 2026) · Lohbeck v. CSL Plasma, Inc., No. 2:26-cv-01493-DJC-CSK
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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