Courts on AI / Fabricated or misquoted citations
Allen v. Hunt
United States District Court for the Northern District of Illinois · Federal district courts · IL · · No. 25-cv-02275 · order
The Northern District of Illinois on 2026-04-13 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Allen v. Hunt. The self-represented plaintiff filed a brief with two fabricated case citations, including LLC v. Sotera Health Co.
- 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 brief with two fabricated case citations, including LLC v. Sotera Health Co. — 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.
Hunt may re-raise his statute of limitations argument in a motion for summary judgment, if this action progresses to that stage. But a motion to dismiss can only be granted on a statute of limitations argument if the plaintiff’s own complaint makes evident that her claim falls outside of the prescribed time period. Allen’s complaint does not do that. III. Motion for Sanctions Hunt asks this Court to impose sanctions on Allen for submitting a brief citing a fabricated case. In her response to Hunt’s motion to stay, Allen included a citation to “Sterigenics U. S. , LLC v. Sotera Health Co. , 2020 WL 5645683 (N.
Authorities cited in the passage: LLC v. Sotera Health Co. , 2020 WL 5645683 (N · LLC v. Sotera Health Co., 2020 WL 5645683 (N.D. Ill. Sep. 22, 2020)", which the Court found does not exist