Courts on AI / Fabricated or misquoted citations
Saunders v. Albertsons/Safeway, LLC
United States District Court for the District of Colorado · Federal district courts · CO · · 2026 WL 1040465 · No. No. 1:24-cv-00814-PAB-SBP · order
The District of Colorado on 2026-04-16 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jamie Lee Saunders v. Albertsons/Safeway, LLC. The self-represented party filed a reply brief with one fabricated case citation.
- Disposition
- The motion for costs was granted in part and denied in part, Safeway was ordered to pay $1,125 to the expert, the motion for a ruling was granted, and the motion to strike the former attorney’s lien was denied.
- Recorded conduct
- Saunders’s reply brief relied on a fictional AI-generated case; she acknowledged the error and apologized to the court and opposing counsel. — 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.
72(a) (“When a pretrial matter not dispositive of a party's claim or defense is referred to a magistrate judge to hear and decide, the magistrate judge must promptly conduct the required proceedings and, when appropriate, issue a written order stating the decision. ”). 3 As a preliminary matter, in its surreply, Safeway includes an embedded motion to strike the Motion for Costs on grounds that Ms. Saunders's reply brief was not timely filed and that she relied on a fictional, AI-generated case. See ECF No. 86 at 3; see also ECF No. 77 at 3 (citing Lampe v. United States, 18 F.
Authorities cited in the passage: Lampe v. United States, 18 F
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
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