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Courts on AI / Fabricated or misquoted citations

Jacobs v. Payward, Inc.

U.S. District Court for the District of Connecticut · Federal district courts · CT · · No. 45 at 7 · order

On 2026-03-30, U.S. District Court for the District of Connecticut admonished the plaintiff that hallucinated citations and excessive exhibits waste judicial resources and undermine the validity of his filings. A self-represented party submitted a brief with The brief relied on hallucinated or irrelevant CUTPA authorities, including Hottle and Wyndham citations that did not support the propositions asserted.

Disposition
The court admonished the plaintiff that hallucinated citations and excessive exhibits waste judicial resources and undermine the validity of his filings.
Recorded conduct
The brief relied on hallucinated or irrelevant CUTPA authorities, including Hottle and Wyndham citations that did not support the propositions asserted. — 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.

to the undersigned, is a hallucinated case citation.6 Third, Hottle v. BDO Seidman, LLP, does not discuss CUTPA at all. 268 Conn. 694 (2004). Finally, F.T.C. v. Wyndham Worldwide Corp. is an out-of-circuit case entitled to nothing more than The Court takes this opportunity to address Plaintiff’s inclusion of hallucinated case citations and excessive inclusion of exhibits. Even though Plaintiff is proceeding pro se, Plaintiff still has the responsibility to ensure, to the best of his knowledge, that his pleadings are accurate and that he, or any potential drafting tool he may have used, cites to existing legal authority for his claims. When Plaintiff includes hallucinated case citations in his briefing, it calls into question the validity not only of his arguments, but also the validity of all materials he submits to the Court, including the exhibits he attaches to his pleadings. This concern is compounded when Plaintiff insists on including numerous verbose, redundant, and even irrelevant exhibits. The effect of these superfluous filings, which the Court must review to ensure their accuracy, is a waste of limited judicial resources. persuasive weight and, in any event, by Plaintiff’s own admission,

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