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Courts on AI / Fabricated or misquoted citations

Saqib Kafeel v. Apple Inc., et al.

U.S. District Court for the Northern District of California · Federal district courts · CA · · No. 26-cv-00330-RFL · order

On 2026-04-01, U.S. District Court for the Northern District of California denied the preliminary-injunction motion and warned that future filings containing nonexistent cases may be stricken from the docket. A self-represented party submitted a motion with fabricated or nonexistent authorities, including In re Grand Jury Subpoena.

Disposition
The court denied the preliminary-injunction motion and warned that future filings containing nonexistent cases may be stricken from the docket.
Recorded conduct
The motion used fabricated or nonexistent authorities, including In re Grand Jury Subpoena, which the court found nonexistent, misquoted, or unsupported. — 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.

(Dkt. No. 29-2 at 13; Dkt. No. 31 at 9.) However, Apple confirmed that it is complying with its preservation duties in this lawsuit “notwithstanding any contractual right to delete materials.” (See Dkt. No. 29 at 15; Dkt. No. 29-5 at 7.) Apple’s preservation duties in this lawsuit would clearly prohibit deletion of Kafeel’s e-books, so there is no reason to believe they are subject to imminent deletion. For the foregoing reasons, Kafeel’s motion is DENIED. Additionally, Apple raised that Kafeel’s motion may contain hallucinations created by generative artificial intelligence tools. (Dkt. No. 29 at 7, 18–19.) Kafeel’s reply did not address this point, but purports to have links to each citation. Nevertheless, some of the reply’s citations do not exist. (See, e.g., Dkt. No. 31 at (citing “In re Grand Jury Subpoena, 972 F.2d 1474 (9th Cir. 1992),” which does not exist).) Use of generative artificial intelligence tools is permitted, but an individual must personally confirm for themselves the accuracy of any research regardless of the source. Kafeel is warned that if his future filings contain nonexistent cases, they may be stricken from the docket. IT IS SO ORDERED. Dated: April 1, 2026 RITA F. LIN United States District Judge

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