Courts on AI / Fabricated or misquoted citations
Zena L. Powell v. The Borough of Bergenfield
United States District Court for the District of New Jersey · Federal district courts · NJ · · No. 2:23-cv-21399-EP-JRA · opinion
The District of New Jersey on 2026-05-12 ordered the self-represented plaintiff to show cause why sanctions or corrective action should not issue for the defective authorities in Zena L. Powell v. The Borough of Bergenfield. The self-represented plaintiff filed an opposition with one false case quotation and one misstated record or submission point.
- Disposition
- The court ordered the self-represented plaintiff to show cause why sanctions or corrective action should not issue for the defective authorities.
- Recorded conduct
- The self-represented plaintiff filed an opposition with one false case quotation and one misstated record or submission point. — outcome: pending; 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.
But Powell does not make any allegations regarding her plans to return to Bergenfield, including the definiteness of her plan to return and the frequency of traveling there. Therefore, the Court will GRANT Defendant’s Motion and DISMISS Plaintiffs claim for injunctive relief as pled. D. Plaintiff’s Apparent Use of Generative Artificial Intelligence Finally, when reviewing Plaintiff’s Opposition, the Court, like Defendants, identified several inaccurate quotations and citations. Namely, Plaintiffincludes quotations from real cases, but the quotations are fabricated. Defendants list numerous examples. See Reply at 2-3. The presence of fabricated quotations in a brief is a sign that the brief’s author may have used generative artificial intelligence (“GAI”). Pursuant to Section I(B) of the Undersigned’s Judicial Preferences, if a party uses GAI in any court filings, they must include a mandatory disclosure that: “(1) identifies the GAI program: (2) identifies the portionofthe filing drafted by the GAI;