Courts on AI / Fabricated or misquoted citations
Maloit v. Maloit
United States District Court for the District of Colorado · Federal district courts · CO · · No. 24-cv-02383-PAB-KAS · report and recommendation
The District of Colorado magistrate judge recommends summary judgment and grants discovery-fee sanctions in part. The order separately finds Maloit’s briefs contain misquotations, misstatements, and seven nonexistent cases likely from generative AI, then orders her to show cause about additional sanctions.
- Disposition
- The magistrate judge recommended summary judgment, granted discovery-fee sanctions in part, and ordered Maloit to show cause over defective citations.
- Recorded conduct
- Self-represented plaintiff filed response briefs with misquoted language, misstated legal concepts, and at least seven nonexistent case citations. — outcome: pending; 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.
Finally, it has come to the Court’s attention that Plaintiff’s Response briefs in opposition to the instant Motion for Summary Judgment [#91] and Motion for Sanctions [#87] contain defective citations to case law. These defects include (1) misattributed or inaccurately quoted language from cases, (2) misrepresentations of legal concepts associated with the cited cases, and, most concerningly, (3) citations to cases that do not exist. Plaintiff appears to have used generative artificial intelligence to prepare her briefs. At this juncture, many generative AI tools are incapable of distinguishing between legitimate precedent and fabricated legal fiction. ... Defendant pointed out some of these deficiencies in his Reply in Support of Motion for Sanctions [#118], stating that the hallucinated citations to legal authority “forced [him] to incur yet further attorney fees to verify the falsity of [Plaintiff’s] citations.” ... The submission of legal argument premised on nonexistent law generated by artificial intelligence is a flagrant Rule 11 violation. ... In conducting a thorough inquiry, the Court believes that the following legal authorities that Plaintiff cited in her briefs do not exist: Mastro v. Rigby, 767 F.3d 934 (10th Cir. 2014) ... United States v. Kitchen, 57 F.3d 916 (10th Cir. 1995) ... Somlo v. S.C. Johnson & Son, Inc., 7 F.3d 1334, 1338 (10th Cir. 1993) ... Mikulski v. Center for Psychiatric Rehabilitation, 789 F.3d 1205, 1213 (10th Cir. 2015) ... Chavez v. Young, 880 F.2d 299, 302-03 (10th Cir. 1989) ... Mobley v. McCormick, 40 F.4th 1199, 1205 (10th Cir. 2022) ... Shen v. Express Scripts, Inc., 2019 WL 4741257, at *3. ... Accordingly, the Court orders that, no later than August 26, 2026, Plaintiff shall SHOW CAUSE in writing why the Court should not further sanction her for her submission of defective legal citations.
Authorities cited in the passage: Fed. R. Civ. P. 11 · Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025) · Coomer v. Lindell, 2025 WL 1865282 (D. Colo. July 7, 2025) · Ferris v. Amazon.com Servs., LLC, 778 F. Supp. 3d 879 (N.D. Miss. 2025) · Mastro v. Rigby, 767 F.3d 934 (10th Cir. 2014) · United States v. Kitchen, 57 F.3d 916 (10th Cir. 1995) · Somlo v. S.C. Johnson & Son, Inc., 7 F.3d 1334 (10th Cir. 1993) · Mikulski v. Center for Psychiatric Rehabilitation, 789 F.3d 1205 (10th Cir. 2015) · Chavez v. Young, 880 F.2d 299 (10th Cir. 1989) · Mobley v. McCormick, 40 F.4th 1199 (10th Cir. 2022) · Shen v. Express Scripts, Inc., 2019 WL 4741257
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