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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 · order

Fabricated or misquoted citations

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 court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct
The self-represented plaintiff filed a submission with one fabricated case citation. — 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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