Courts on AI / Fabricated or misquoted citations
Juandel Pena and Martina Ruiz v. Wells Fargo Bank, N.A.
United States District Court for the Southern District of Florida · Federal district courts · FL · · No. Case 0:25-cv-62431-MD · report and recommendation
Southern District of Florida on 2026-02-19 in Juandel Pena and Martina Ruiz v. Wells Fargo Bank, N.A. found the self-represented parties' reply misread Holden and cited a nonexistent page beyond the end of the Eleventh Circuit opinion. The magistrate judge recommended denying the renewed preliminary-injunction motion and warned that further false AI citations could require a sanctions hearing.
- Disposition
- The magistrate judge recommended denying the renewed preliminary-injunction motion and warned that further false AI citations could require a sanctions hearing.
- Recorded conduct
- The self-represented parties' reply misread Holden and cited a nonexistent page beyond the end of the Eleventh Circuit opinion. — outcome: sanctions; 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.
the FCRA. Indeed, Holden never discusses or mentions injunctive relief. At worst, Plaintiffs have obtained their Holden analysis and citation from an unreliable source, such as artificial intelligence (“AI”). The best indication of this possibility is Plaintiffs’ citation to page 1371 of Holden. Holden, 4 Case 0:25-cv-62431-MD Document 37 Entered on FLSD Docket 02/19/2026 Page 5 of 5 however, ends on page 1369. No level of misreading would cause Plaintiffs to cite to a non-existent page. This Court previously admonished Plaintiffs for potentially using AI hallucinated legal citations. DE 11 at 2. The Court should not have to warn Plaintiffs again. If Plaintiffs include any other false or inaccurate legal citations in briefing that the Court suspects were generated by AI, the Court will order Plaintiffs to appear in person to explain those citations and why they should not be sanctioned for their conduct. III. Recommendation Because Plaintiffs cannot obtain injunctive relief under the FCRA, the Court
Authorities cited in the passage: Plaintiffs cited Holden v. Holiday Inn Club Vacations