Courts on AI / Fabricated or misquoted citations
Adams v. Matrix Providers Inc.
United States District Court for the District of Colorado · Federal district courts · CO · · No. 1:23-cv-01996-CNS-KAS · order
The District of Colorado denies Adams’s post-judgment motions and addresses counsel’s response to a show-cause order over a nonexistent Ricks v. Starbucks citation and other inaccurate authorities. The court admonishes counsel about possible AI-assisted research errors and separately imposes a $1,000 sanction for rule violations.
- Disposition
- The court denied post-judgment motions, admonished counsel over questionable citations, and sanctioned counsel $1,000 for rule violations.
- Recorded conduct
- Counsel included a nonexistent Ricks v. Starbucks citation and numerous inaccurate citations; the court said possible AI use was unclear. — outcome: fine; actor: lawyer; $1,000
- 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.
In her response to the show cause order, Ms. Pearson represents that the nonexistent case, Ricks v. Starbucks, was included in Plaintiff’s briefing inadvertently. By way of explanation, Ms. Pearson offers that at the time briefing was due, she was handling a significant family emergency and required additional help from an unnamed “colleague” and her paralegal to assist in finalizing the briefing. ... However, Ms. Pearson’s response also notes that, with respect to the other legal citations in her briefing, “[o]f these thirty-six [cases cited in the response to Matrix’s summary judgment motion], Ricks is the only case that the Court and [Matrix] believe is fake and potentially AI-generated.” ... Whether these misstatements were the result of the use of an AI legal search, or simply poor and unexacting legal judgment, is unclear. Regardless, they are highly concerning to the Court nonetheless.
Authorities cited in the passage: Ricks v. Starbucks · Amarsingh v. Frontier Airlines, Inc., No. 24-1391, 2026 WL 352016 (10th Cir. Feb. 9, 2026) · Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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