Courts on AI / Fabricated or misquoted citations

Pyle v. Glenn County Sheriff's Department

United States District Court for the Eastern District of California · Federal district courts · CA · 2026-05-12 · No. 2:24-cv-02940-TLN-CSK · order

Fabricated or misquoted citations

The Eastern District of California on 2026-05-12 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Pyle v. Glenn County Sheriff's Department. The self-represented plaintiff filed a submission with one fabricated or AI-like submission item and one fabricated factual or other assertion, including Sheriff Owens.

Disposition: The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct: The self-represented plaintiff filed a submission with one fabricated or AI-like submission item and one fabricated factual or other assertion, including Sheriff Owens. — 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.

, 559 F. 3d 1061, 1071 (9th Cir. 2009). The Court notes that Plaintiff’s SAC appears to have been drafted with the help of generative artificial intelligence (“GenAI”) or similar tools because it contains apparent GenAI responses to prompts. See SAC at 2:19-21, 3:26-28, 4:25-28, 6:22-24, 7:11-13. Of particular concern is an apparent reference to “Sheriff Owens” in one of the responses, who is not named elsewhere in the SAC. See SAC at 3:26-27. This raises concerns that the SAC may contain facts that the generative AI “hallucinated,” that is, made up. The Court previously warned Plaintiff that a misuse of generative AI that includes hallucinations of facts or legal authority can violate Rule 11.

Authorities cited in the passage: Fed. R. Civ. P. 11

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: official copy pending

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