Courts on AI / Fabricated or misquoted citations
Jorge A. Zea v. National Association of REALTORS
U.S. 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 dismissal without prejudice and admonishment after finding that the plaintiff’s quotations and legal concepts were AI-hallucinated.
- Recorded conduct
- The opposition brief used multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — 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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