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Courts on AI / Fabricated or misquoted citations

Feldman & Trost v. District 6 Board of Education

U.S. District Court for the Central District of Illinois · Federal district courts · IL · · No. d: 03/31/26 · other

On 2026-03-31, U.S. District Court for the Central District of Illinois resolved the motion to dismiss and warned counsel that further false quotations or unsupported legal authorities could trigger sanctions. Counsel submitted a complaint with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Rost v. Steamboat Springs RE-2 Sch. Dist and Busse v. Motorola, Inc.

Disposition
The court resolved the motion to dismiss and warned counsel that further false quotations or unsupported legal authorities could trigger sanctions.
Recorded conduct
The complaint used false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Rost v. Steamboat Springs RE-2 Sch. Dist and Busse v. Motorola, Inc, which the court found nonexistent, misquoted, or unsupported. — outcome: warning; actor: lawyer
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.

true and construing all reasonable inferences in the plaintiff’s favor. Id. at 458. To state a claim for relief, a plaintiff need only provide a short and plain statement of the claim showing he is entitled to relief and giving defendants fair notice of the claims. Maddox v. Love, 655 F.3d 709, 718 (7th Cir. 2011). However, the complaint must set forth facts that plausibly demonstrate a claim for relief. Bell Atl. Corp v. Twombly, 550 U.S. 544, 547 (2007). A plausible claim is one that alleges factual content from which the Court can reasonably infer that defendants are liable for the misconduct alleged. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Merely reciting the elements of a cause of action or supporting claims with conclusory statements is insufficient to state a claim. Id. The complaint must do more than assert a right to relief that is “speculative.” Virnich v. Vonvald, 664 F.3d 206, 212 (7th Cir. 2011). B. Analysis4 Throughout their response Plaintiffs cite nonexistent cases or contend that cases, although real, stand for wholly unsupported or undiscussed legal conclusions. For example, Plaintiffs cite “Doe v. Madison Metro. Sch.

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