Skip to content

Courts on AI / Fabricated or misquoted citations

Ulish Kerry Terrace Booker, III v. U.S. Bank National Association

United States District Court for the District of Connecticut · Federal district courts · CT · · No. 25-CV-1205 (VDO) · order

Fabricated or misquoted citationsSelf-represented litigants using AIGemini Pro, Perplexity, Cetient Legal AI, and ChatGPT

The District of Connecticut admonishes self-represented debtor Ulish Booker in a bankruptcy appeal. After a show-cause hearing, the court finds his briefs contained fabricated cases, erroneous citations, and incorrect quotations produced with Gemini Pro, Perplexity, Cetient Legal AI, and ChatGPT.

Disposition
The court admonished Booker for violating Rule 11, warned him, and affirmed the bankruptcy court orders on appeal.
Recorded conduct
Self-represented appellant filed briefs with at least two inaccurate quotations, four erroneous citations, and six fabricated cases generated through AI tools. — 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.

On June 25, 2026, this Court issued an Order to Show Cause after discovering that Booker III’s briefs were riddled with cases that do not exist, incorrect quotes, and erroneous citations. Specifically, in its Show-Cause Order, the Court identified the following hallucinations: ... BCB Contracting Services, LLC v. United States, 104 B.R. 771, 775 (S.D. Ariz. 2021) [was a] Nonexistent case. Page 771 of Volume 104 of the Bankruptcy Reporter lands in the middle of In re Crouch, a bankruptcy case from West Virginia (104 B.R. 770). ... Mathews v. Dillon, 489 U.S. 567 (1989) [was a] Nonexistent case. Page 567 lands in the middle of a case called Coit Independence Joint Venture v. Federal Sav. and Loan Ins. Corp. (489 U.S. 561). That case explicitly does not discuss due process. The Court could not find any case called “Mathews v. Dillon.” ... In sum, the Court was able to identify at least two inaccurate quotes, four erroneous citations, and six fabricated cases. These hallucinations clearly indicated to the Court the use of generative artificial intelligence (“AI”) in the preparation of these briefs. ... At the hearing, Booker III again apologized to the Court and admitted that he had used several generative AI programs—including Gemini Pro, Perplexity, Cetient Legal AI, and ChatGPT—to prepare his filings. ... For the foregoing reasons, Booker III is ADMONISHED for violating Rule 11 and is WARNED that any future filing containing fabricated authorities, inaccurate quotations, erroneous citations, or other AI-generated hallucinations—or any future failure to conduct a reasonable, human-based verification of authorities before filing—may result in substantially more severe sanctions, including monetary sanctions, the striking of filings, dismissal of claims or appeals, or any other sanction authorized by Rule 11 or the Court’s inherent authority.

Authorities cited in the passage: Fed. R. Civ. P. 11 · Fed. R. Bankr. P. 9011 · BCB Contracting Services, LLC v. United States, 104 B.R. 771 · Mathews v. Dillon, 489 U.S. 567 · Coit Independence Joint Venture v. Federal Sav. and Loan Ins. Corp., 489 U.S. 561 · Mata v. Avianca, Inc. · Mattox

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub