Courts on AI / Fabricated or misquoted citations

In re: Social Media Adolescent Addiction Litigation

United States District Court for the Northern District of California · Federal district courts · CA · 2026-02-17 · No. 4:22-md-03047-YGR; MDL No. 3047 · memorandum opinion

Fabricated or misquoted citations

Northern District of California on 2026-02-17 in In re: Social Media Adolescent Addiction Litigation found the expert's submission contained two citation defects involving mischaracterized authority. The court declined to exclude the expert but left the incorrect AI-generated citations for cross-examination.

Disposition: The court denied exclusion of the expert opinions based on corrected AI citation-tool miscites and allowed cross-examination on the issue.
Recorded conduct: Defendants asserted that articles cited by Dr. Osborne did not exist and that other incorrect citations were AI citation-tool miscites; plaintiffs said the citations were corrected. — outcome: noted, no consequence; actor: expert
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.

9 based on a lack of reliable methodology or on hearsay grounds. 10 3. AI-Generated Citations 11 Defendants contend that Osborne admitted at deposition that articles upon which he 12 purportedly relied do not exist, and that other incorrect citations were miscites generated by AI. 13 Plaintiffs respond that none of the academic articles were actually false, but rather that citations 14 were merely incorrectly formatted based on use of an AI citation tool, which was subsequently 15 corrected. The Court declines to exclude Osborne’s opinions on this basis. Defendants may, 16 however, raise the issue on cross-examination. 4. Not Qualified to Offer Opinions about Platform Design and Scientific 17 Literature on Social Media 18 Defendants maintain that Osborne’s conclusions that social media has adverse mental 19 health effects on youth, and that platforms are engineered to maximize attention, are outside of his

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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