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Courts on AI / Fabricated or misquoted citations

Jones v. Department of the Army

United States Court of Appeals for the Federal Circuit · Federal courts of appeals · · No. 25-1822 · order

On 2026-05-13, in Jones v. Department of the Army, the Federal Circuit warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed a petition using nonexistent or hallucinated authorities. No monetary sanction was imposed in this document.

Disposition
The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
A self-represented appellant filed a petition using nonexistent or hallucinated authorities. — 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.

Jones included citations that appear to ref- erence cases that do not exist, or at the least contain sig- nificant errors, apparently resulting from the use of artificial intelligence. See, e.g., Pet’r’s Br. 20 (purporting to cite Riley v. Dep’t of Veterans Affs., 64 M.S.P.R. 42, 44–46 (1994), which does not appear to exist); Dkt. No. 14 at 13 (citing Lipscomb v. Dep’t of the Army, 301 F.3d 1356 (Fed. Cir. 2002), which does not appear to exist); Resp’t’s Br. 10–11 & n.5 (listing other apparently fraudulent cita- tions). Mr. Jones does not attempt to explain or justify the inclusion of these citations in his filings before this court in his reply. The use of these false citations is sanctionable, and repetition of this conduct can result in serious conse- quences, potentially including dismissal of his petition for review. JONES v. ARMY 7 We have considered Mr. Jones’s remaining arguments and find them unpersuasive.3 AFFIRMED-IN-PART, VACATED-IN-PART, AND REMANDED COSTS No costs. 3 Mr.

Authorities cited in the passage: Riley v. Dep’t of Veterans Affs., 64 M · Lipscomb v. Dep’t of the Army, 301 F · JONES v. ARMY 7 We have considered Mr. Jones’s remaining arguments and find

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