Courts on AI / Fabricated or misquoted citations
Zavadovsky v. Republic of Austria, et al.
U.S. District Court for the District of Columbia · Federal district courts · DC · · No. 25-1008 (RC) · memorandum opinion
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 warned the plaintiffs after cataloging fake quotations, nonexistent cases, and misrepresented holdings that appeared to be AI-generated.
- Recorded conduct
- The filing used fake quotations, nonexistent cases, and misrepresented procedural rules in support of strike and response arguments. — 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