Courts on AI / Fabricated or misquoted citations
James v. Conley
United States District Court for the Southern District of Florida · Federal district courts · FL · · No. 1:23-cv-24467-KMM · report and recommendation
The Southern District of Florida recommends denying Miami-Dade County’s Rule 11 motion against James on safe-harbor grounds but says counsel relied for months on unverified AI-generated IACP Training Keys. The recommendation calls the Keys AI hallucinations and recommends referral of four signing attorneys.
- Disposition
- The magistrate judge recommended denying Rule 11 sanctions on safe-harbor grounds but referring plaintiff's counsel for disciplinary review.
- Recorded conduct
- Plaintiff’s counsel pleaded and relied on unverified AI-generated IACP Training Keys that could not be confirmed to exist. — outcome: referral; actor: lawyer
- 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.
In his Response, Plaintiff concedes that the Keys in the Fifth Amended Complaint that are the subject of the Motion were based on unverified AI-generated research, and although Plaintiff does not state so explicitly, the Keys were AI hallucinations. See id. at 6-7. As explained below, the Court finds Plaintiff’s counsel’s use of and repeated reliance on unverified AI-generated research to be irresponsible and in dereliction of counsel’s responsibilities as officers of the Court. ... While the Court declines to award Defendant monetary sanctions for the procedural reason noted above, the Court cannot ignore that Plaintiff’s counsel admitted to filing the Fifth Amended Complaint without first verifying whether the Keys — documents discovered through unverified AI-generated research — indeed existed and continued their reliance on the Keys for months, despite being unable to confirm their content.
Authorities cited in the passage: Fed. R. Civ. P. 11 · Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enters., LLC, No. 17-CV-81140, 2025 WL 1440351 (S.D. Fla. May 20, 2025) · R. Regulating Fla. Bar 4-1.1
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