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Courts on AI / Fabricated or misquoted citations

McDowell et al. v. Turpen

United States Bankruptcy Court for the District of Colorado · Federal bankruptcy courts · CO · · No. No. 25-12572 MER · order

United States Bankruptcy Court for the District of Colorado on 2026-02-17 in McDowell et al. v. Turpen found the self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. — 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.

not act with malice are factual disputes that are inappropriate for consideration on a motion to dismiss. D. Warning to Turpen Concerning Artificial Intelligence Turpen has elected to proceed in this case without counsel. He may do so, but he is warned that he will be held to the same standards as parties who appear with counsel. Turpen’s Motion to Dismiss contains what appears to be prompts from some artificial intelligence guidance.45 He also cited a fake case: In re Raspanti, 414 B.R. 263 (Bankr. D. Colo. 2009). Turpen states the incorrect citation was an error, but he is cautioned that he, like all the attorneys who appear in this Court, is subject to all the requirements of Fed. R. Bankr. P. 9011. The Court further cautions Turpen that the use of artificial intelligence for research or drafting of pleadings, whether by attorneys or pro 42 Fowler, 91 F.3d at 1371. 43 McCreary v. Kichler (In re Kichler), 226 B.R. 910, 913 (Bankr. D. Kan. 1998) (“Unless there exists some additional fact, section 523(a)(4), as it relates to a debtor acting in a fiduciary capacity, does not apply to

Authorities cited in the passage: In re Raspanti, 414 B.R. 263 (Bankr. D. Colo. 2009) · F.3d at 1371. 43 McCreary v. Kichler · Fed. R. Bankr. P. 9011 · B.R. 263 · B.R. 910

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