Courts on AI / Fabricated or misquoted citations

Zavadovsky v. Republic of Austria

United States District Court for the District of Columbia · Federal district courts · DC · 2026-03-31 · No. 25-1008 (RC) · memorandum opinion

Fabricated or misquoted citations

On 2026-03-31, U.S. District Court for the District of Columbia warned the plaintiffs after cataloging fake quotations, nonexistent cases, and misrepresented holdings that appeared to be AI-generated. A self-represented party submitted a filing with fake quotations, nonexistent cases, and misrepresented procedural rules in support of strike and response arguments.

Disposition: The court granted the principal dismissal and service motions, dismissed claims against the attorney and individual federal defendants with prejudice, quashed service on the Austrian defendants with leave to re-serve, and warned plaintiffs about Rule 11 and prefiling consequences.
Recorded conduct: Plaintiffs filed motions and briefs with nonexistent cases, fake quotations, and misrepresented rules or holdings, including Young v. District of Columbia, Beaucage v. Beaucage, a fake Miller quotation, Foremost-McKesson, and Wheat; plaintiffs denied AI generation. — 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.

id. at (citing a fake quotation from Thomas v. Patton, 939 So. 2d 139 (Fla. Dist. Ct. App. 2006)); id. (citing a case, Young v. District of Columbia, 752 F. Supp. 2d 1 (D.D.C. 2010), that does not exist); Pls.’ Mot. Strike Response at 3 (misrepresenting the effect of Fla. R. App. P. 9.110(b)); id. (citing a case, Beaucage v. Beaucage, 583 So 2d 846 (Fla. 5th DCA 1991), that does not exist); id. (citing a fake quotation from Miller v. Fortune Ins. Co., 484 So. 2d 1221 (Fla. 1986)); Pls.’ Opp’n to Austrian Defs.’ Mot. at 10–11 (misrepresenting a holding from Foremost-McKesson, Inc. v. Islamic Republic of Iran, 905 F.2d 438 (D.C. Cir. 1990)); id. at 13 (misrepresenting a holding from Wheat v. United States, 486 U.S. 153 (1988)). Plaintiffs’ citations to hallucinated authorities bear the hallmarks of reliance on an artificial intelligence (“AI”) tool. See Williams v. Cap. One Bank, N.A., No. 15 24-cv-2032, 2025 WL 843285, at *7 (D.D.C. Mar. 18, 2025) (“Courts have recently seen increasing reliance on artificial intelligence in legal proceedings, leading to the use of nonexistent citations in court documents.”). Plaintiffs insist that

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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