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Courts on AI / Fabricated or misquoted citations

Keirton Inc. v. Mersad Rahmanovic

U.S. Bankruptcy Court for the District of Colorado · Federal bankruptcy courts · CO · · 2026 WL 787397 · No. 25-12622 MER are incorrect or nonexistent · other

On 2026-03-19, U.S. Bankruptcy Court for the District of Colorado dismissed the debtor’s counterclaims with leave to amend and warned that nonexistent AI-hallucinated citations did not save deficient pleading. A self-represented party submitted a complaint with several false quotations and fabricated or nonexistent authorities, including Gullickson v. Brown.

Disposition
The court dismissed the debtor’s counterclaims with leave to amend and warned that nonexistent AI-hallucinated citations did not save deficient pleading.
Recorded conduct
The complaint used several false quotations and fabricated or nonexistent authorities, including Gullickson v. Brown, 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.

for declaratory judgment is duplicative of his defenses to Keirton Inc. Plaintiff, Keirton's § 727(a)(4) claim.3 Keirton also asserts that several v. of Rahmanovic's case citations do not exist and are the result Mersad Rahmanovic Defendant. of A.I. hallucinations. In response, Rahmanovic asserts that he sufficiently pled both claims and that even if his citations Case No. 25-12622 MER are incorrect or nonexistent, his counterclaims should not be | dismissed or stricken. Additionally, Rahmanovic asserts he Adversary No. 25-01338 MER should be permitted to amend his counterclaims. | Filed:03/19/2026 ANALYSIS Chapter 7 A. Dismissal Is Warranted Under Rule 12(b)(6) Pursuant to Fed. R. Civ. P. 12(b)(6) (incorporated by Fed. R. ORDER GRANTING MOTION TO DISMISS WITH Bankr. P. 7012), a complaint may be dismissed for failure LEAVE TO AMEND to state a claim upon which relief can be granted. When considering a motion to dismiss under Rule 12(b)(6), the Michael E. Romero, Judge United States Bankruptcy Court Court accepts as true all well-pled factual allegations in the complaint and views them in the light most favorable THIS MATTER comes before the Court on the Motion to the plaintiff.4 A complaint will be dismissed unless it to Dismiss Defendant's Counterclaims (“Motion”) filed by “contains sufficient factual matter, accepted as true, to state

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