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Courts on AI / Fabricated or misquoted citations

SWSZ Holding v. SZ Global

Supreme Court of Delaware · State supreme courts · DE · · 2026 WL 1482293 · No. N25C-05-105 SSA · memorandum opinion

On 2026-05-27, in SWSZ Holding v. SZ Global, Supreme Court of Delaware denied the sealing motion without prejudice and directed the movant to refile using only existing, accurately quoted authorities. A self-represented appellant filed a motion using several nonexistent or hallucinated authorities.

Disposition
The court denied the sealing motion without prejudice and directed the movant to refile using only existing, accurately quoted authorities.
Recorded conduct
A self-represented appellant filed a motion using several nonexistent or hallucinated authorities. — 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.

Motion,hemoved“tosealorredactimproperanddefamatory material” within the Third-Party Complaint, under Superior Court Civil Rules 5(g), 12(f), “and the Court's inherent equitable authority to seal or redact specific portions....”6 WithintheattachedMemorandumofLawinSupport,Movant asserted four defenses.7 However, he did not object to the Court'sexerciseofjurisdictionoverhisperson.Instead,while seeking dismissal or alternative relief on other grounds, he challenged the merits,8 even noting he “stands prepared to introduce [preserved evidence] at deposition or trial if necessary.”9 *2 At this point, an issue arose regarding Movant's citation to nonexistent legal authorities to this Court. The Court convened an in-person hearing on October 15, 2026. The Court could not verify or locate quoted language from seven casescitedbyMovantintheFirstMotion.Thehearing'sfocus was to clarify that despite Movant's pro se status, the Court will not tolerate citation to nonexistent authorities. Therefore, the First Motion to Dismiss was denied, without prejudice.10 Recognizing Movant's pro se status, the Court provided leave to refile by November 14.11 But Movant took other routes first. Within days of his in- person appearance at the hearing, Movant filed a Letter asserting his intention to seek sanctions.12 Movant argued the Third-Party Complaint was filed while the corporate charter was “forfeited.”13 Movant sought discovery concerning the Third-Party Complaint's filing and Defendant's corporate status.14 On the same day, Movant filed what he deemed a “Supplemental Motion” (hereinafter the “Second Motion”) challenging this litigation on several fronts.15 This new filing raised entirely distinct arguments for dismissal, centering on SWSZ HOLDING INC., Plaintiff, Counterclaim Defendant, v.

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub