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Courts on AI / Fabricated or misquoted citations

Christopher A. Ambrose v. Bandy X. Lee

U.S. District Court for the District of Connecticut · Federal district courts · CT · · No. 1 at 19 · order

Fabricated or misquoted citations

On 2026-03-31, U.S. District Court for the District of Connecticut cautioned the self-represented defendant that severe AI-assisted misreadings of law could lead to sanctions under Rule 11. A self-represented party submitted a brief with fabricated or nonexistent authorities and mischaracterized authorities, including Tyler v. Tyler and Martin v. Hearst Corp.

Disposition
The court cautioned the self-represented defendant that severe AI-assisted misreadings of law could lead to sanctions under Rule 11.
Recorded conduct
The brief used fabricated or nonexistent authorities and mischaracterized authorities, including Tyler v. Tyler and Martin v. Hearst Corp, which the court found nonexistent, misquoted, or unsupported. — 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.

334 F.3d 204, 206 (2d Cir. 2003) (per curiam); S. New Eng. Tel. Co. v. Glob. NAPs Inc., Given Defendant’s serious misreading of Tyler, the Court suspects she used artificial intelligence (“AI”) to draft at least that portion of her brief. The Court cautions Defendant that the use, without verification, of the accuracy of the information AI platforms generate—like any other shoddy research method from other sources or tools—implicates Federal Rule of Civil Procedure 11, the central purpose of which is to deter baseless filings in district court and thus to streamline the administration and procedure of the federal courts. Rule 11 applies fully to pro se litigants. Therefore, all parties are on notice that the Court has a no-tolerance policy for any briefing (AI-assisted or not) that hallucinates legal propositions or otherwise severely misstates the law. Such filings will often result in sanctions absent reasonable excuse. See generally Willis v. U.S. Bank Nat’l Ass’n et al, No. 3:25-CV-516-BN, 2025 WL 1408897 (N.D. Tex. May 15, 2025). Defendant makes no separate argument that the service was improper, as opposed to the service of process being improper. Thus, the Court does

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