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Courts on AI / Fabricated or misquoted citations

Burnside v. Verdick, et al.

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

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 the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities.
Recorded conduct
The self-represented party filed a pleading with six fabricated case citations, including Jones v. County of Los Angeles and Thompson v. Hong. — 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)'

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub