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Courts on AI / Fabricated or misquoted citations

Chamberlain v. City of Albany

United States District Court for the Middle District of Georgia · Federal district courts · GA · · No. 1:25-CV-123 (LAG) · order

The Middle District of Georgia on 2026-05-01 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Chamberlain v. City of Albany. The self-represented plaintiff filed a submission with one fabricated case citation.

Disposition
The motion to strike was denied and Chamberlain was cautioned that fake opinions are not permitted.
Recorded conduct
Chamberlain’s pro se filing cited nonexistent cases. The court cautioned that AI may be used only if authorities are verified and fake opinions are not filed. — 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.

(2) the claims, defenses, and other legal contentions therein are warranted by existing law or by a nonfrivolous argument for the extension, modification, or reversal of existing law or the establishment of new law; [and] (3) the allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary support after a reasonable opportunity for further investigation or discovery[. ] Fed. R. Civ. P. 11(b). “While there is no general prohibition on using [artificial intelligence] during the course of litigation, Plaintiff [must] ensure he is not citing to fake opinions in his filings. ” Gordon v. Wells Fargo Bank N. A. Inc. , No. 5:24-CV-388 (CAR), 2025 WL 1057211 (M. D. Ga.

Authorities cited in the passage: Gordon v. Wells Fargo Bank N. A. Inc. , No. 5:24-CV-388 (CAR · Fed. R. Civ. P. 11

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