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Courts on AI / Fabricated or misquoted citations

Zea v. National Association of REALTORS

United States District Court for the Southern District of Florida · Federal district courts · FL · · No. 25-cv-81016-DIMITROULEAS/MATTHEWMAN · report and recommendation

On 2026-03-24, U.S. District Court for the Southern District of Florida recommended dismissal without prejudice and admonishment after finding that the plaintiff’s quotations and legal concepts were AI-hallucinated. A self-represented party submitted an opposition brief with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

Disposition
The magistrate judge recommended granting the motion to dismiss and warned plaintiff about AI-hallucinated law.
Recorded conduct
Plaintiff's response relied on AI hallucinations and invented law about antitrust concepts, including nonexistent concerted-action law. — 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.

Response in opposition to all of Defendants’ arguments. As noted in Defendants’ Reply, Plaintiff has cited in large part to artificial intelligence (“AI”)-hallucinated law. While the cases Plaintiff relies on do exist, the quotations, and even most of the legal concepts, are fake. Plaintiff filed a Notice of Spoliation in which he apologizes to the court, Defendants, and Defendants’ counsel for his AI-related mistakes. [DE 71 at 3]. However, Plaintiff only acknowledges that one citation was incorrectly included in his Response and that “two drafting errors in which quotation marks were mistakenly used around paraphrased statements rather than direct quotations.” Id. at 2. The hallucination issue is more prevalent than Plaintiff admits. The Court has determined that hallucinated law appears on pages 5, 9, 10, 11, 13, 14, 15, and 17 of the Response. Therefore, while Plaintiff has conceded that he made a mistake, and sanctions are likely not appropriate, the Court simply cannot trust the legal arguments of Plaintiff. And, Plaintiff is doing himself a great disfavor by relying on fake legal arguments, which further weaken his position. The Court will further discuss the hallucinated law below. ii. Plaintiff’s

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