Courts on AI / Fabricated or misquoted citations
Moore v. MC Architects Inc., et al.
United States District Court for the District of Hawaii · Federal district courts · HI · · No. 24-00367 JMS-KJM · order
The District of Hawaii on 2026-05-05 ordered counsel to pay $1,000 after oppositions contained multiple record- and case-citation errors tied to AI use. Counsel accepted responsibility for filing the client’s AI-assisted material, and the court imposed the sanction for inadequate verification duties.
- Disposition
- The court ordered counsel to pay $1,000 for filing unverified or fabricated authorities.
- Recorded conduct
- Counsel filed oppositions with multiple record- and case-citation errors tied to AI use by the client and accepted responsibility for filing them. — outcome: fine; actor: lawyer; $1,000
- 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.
S. 544, 570 (2007)). The complaint “may not simply recite the elements of a cause of action,” and instead “must contain sufficient allegations of underlying facts to give Before the April 8, 2026 hearing, the court issued an order identifying a number of record- and case-citation issues in Moore’s oppositions and directing Moore’s counsel to be “prepared to explain these issues, and in particular, whether they resulted from the use of artificial intelligence (‘AI’) tools. ” ECF No. 75. During the hearing, Moore’s counsel explained that Moore (that is, the client) had taken a lead role in preparing the oppositions and had used AI tools in the process of doing so. ECF No.
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