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Courts on AI / Fabricated or misquoted citations

Jurkowski v. Berkowitz

Superior Court of the District of Columbia · State trial courts · DC · · 2026 WL 1345470 · No. 2025-CAB-8255. April 21, 2026 · opinion

The Superior Court of the District of Columbia on 2026-04-21 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jurkowski v. Berkowitz. The self-represented plaintiff filed a pleading with one fabricated case citation and one mischaracterized case citation.

Disposition
The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct
The self-represented plaintiff filed a pleading with one fabricated case citation and one mischaracterized case citation. — 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.

4 Because the Court is granting Plaintiff an additional opportunity to move to amend the Complaint, the Court will at this time deny the pending Motions to Dismiss as moot, and without prejudice. The Defendants may renew their motions to dismiss at a later date, if the motions remain relevant. F. Use of Artificial Intelligence Multiple Defendants have suggested that Plaintiff has used artificial intelligence tools to draft her pleadings. In particular, the District Defendants assert that Plaintiff's use of artificial intelligence resulted in Plaintiff submitting nonexistent or spurious case citations to this Court. District. Def. 's Opp'n to Second Mot. Am.

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