Courts on AI / Fabricated or misquoted citations

Burnside v. Verdick

United States District Court for the Southern District of Iowa · Federal district courts · IA · 2026-04-30 · No. 3:25-cv-00134-SMR-SBJ · order

Fabricated or misquoted citations

The Southern District of Iowa on 2026-04-30 ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities in Burnside v. Verdick, et al. The self-represented party filed a pleading with six fabricated case citations, including Jones v. County of Los Angeles.

Disposition: The court ordered Burnside to show cause and amend within 30 days, reserving dismissal and sanctions if he failed to comply.
Recorded conduct: Burnside’s pro se complaint cited six erroneous authorities whose citations pointed to different cases or non-case material. The court found the errors suggested artificial-intelligence drafting and ordered him to show cause and amend. — outcome: pending; 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.

Genuine Parts Co. , 463 F. Supp. 2d 928, 934 (E. D. Wis. 2006). These erroneous citations suggest that artificial intelligence was used to draft the complaint, producing the phenomenon known as “hallucinations,” i. e. , fabricated cases that do not exist. Unfortunately, this has become an unwelcome fixture in court filings across the country. The Court recognizes that artificial intelligence has the potential to expand access to the courts, but it also presents very serious dangers that are “fundamentally incompatible with our justice system” predicated on “integrity and honesty from parties. ” Mills v. City of St. Louis, No. 4:25- cv-1219-MTS, 2025 WL 3470293, at *1 (E. D.

Authorities cited in the passage: Mills v. City of St. Louis, No. 4:25- cv-1219-MTS, 2025 WL 3470293, at *1 (E · Plaintiffs cited 'Jones v. County of Los Angeles, 802 Fed. App’x 282 (9th Cir. 2020)' · Plaintiffs cited 'Thompson v. Hong, 2020 IL App (2d) 190551' · Fay v. Fifty K Corporation, No. 2-19-0551, 2020 WL 2095845 (Ill. App. Ct. Apr. 29, 2020) (alt. 2020 IL App ( · Plaintiffs cited 'Wallace v. County of Los Angeles, 479 F. Supp. 3d 1088 (C.D. Cal. 2020)' · Curtis v. Oliver, 479 F. Supp. 3d 1039, 1088 (D.N.M. 2020) instead, indicating mismatch/nonexisten · Plaintiffs cited 'Estate of Smith v. Shulz, 2018 WL 2192187 (N.D. Iowa)' · Cabrera v. N.Y. Fresh Meat Inc., 2018 WL 2192187 (S.D.N.Y. May 14, 2018), not a N.D. Iowa decision · Plaintiffs cited 'Yates v. Mansfield, 2014 WL 11535036 (S.D. Iowa)' · Plaintiffs cited 'Doe v. United States, 463 F. Supp. 2d 934 (N.D. Iowa 2006)'

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

United States court documents are public domain; the topic coding, disposition line and summary are SafeLegalAI's reading of the document for comparison, not a finding about any person named in it. This record summarises a public court document or official publication and reports what it says; SafeLegalAI makes no findings of its own. Individuals and organisations are named only as they appear in that public record. Anyone named may send a right of reply, correction or contextual update (for example an appeal, vacatur or later disposition) via /report; we add a dated note where appropriate. Reply or correct this record.

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub