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Courts on AI / Fabricated or misquoted citations

Andre Lamont Goddard, Jr. v. City University of Seattle

United States District Court for the District of Columbia · Federal district courts · DC · · No. Case 1:25-cv-01881-JMC · memorandum opinion

District of Columbia on 2026-03-06 in Andre Lamont Goddard, Jr. v. City University of Seattle found the self-represented party's motion contained five citation defects involving mischaracterized authority, incorrect statutory or rule text. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.

Disposition
The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.
Recorded conduct
The self-represented party's motion contained five citation defects involving mischaracterized authority, incorrect statutory or rule text. — 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.

includes citation to several cases that do not appear to exist. 8 The cases bear the stamp of having been invented by artificial intelligence, given that they resemble authentic case citations, but when the reporter numbers are searched, turn up entirely unrelated cases that do not match the same name, date, or jurisdiction cited in the complaint, let alone support the propositions for which they are cited. Acknowledging that Plaintiff is a pro se litigant, Plaintiff is reminded that they have an obligation to comply with Rule 11, which imposes an affirmative duty to conduct a “‘reasonable [inquiry]’ into the substance of a filing before it is presented to the Court, including verifying that every citation is real.” Rubio v. District of Columbia, No. 23-cv-719, 2024 WL 4957373, at *4 (D.D.C. Dec. 3, 2024) (quoting Fed. R. Civ. P. 11(b)(2)). The failure to do so has led some courts to impose Rule 11 sanctions for the improper use of AI assistance. See id. The Court finds this admonition to abide by Rule 11 highly relevant given that Plaintiff has represented that they are a law student set to graduate this spring. ECF 1-2 at 6. Accordingly, it is hereby ORDERED that Defendant’s partial motion to dismiss, ECF 6, is DENIED as to Plaintiff’s CPPA claim, and GRANTED as to Plaintiff’s claims for (1) breach

Authorities cited in the passage: s proposition. || Fabricated: Case Law | Court could not locate the cited case and found it likely fabricated; citation does not support plaintiff · Rubio v. District of Columbia, No. 23-cv-719, 2024 WL 4957373 · Fed. R. Civ. P. 11(b)(2) · Rule 11

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