Courts on AI / Fabricated or misquoted citations

Allen v. Hunt

United States District Court for the Northern District of Illinois · Federal district courts · IL · 2026-04-13 · No. No. 25-cv-02275 · order

Fabricated or misquoted citations

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: Hunt’s motion to dismiss was granted without prejudice, Allen was allowed to amend by May 1, 2026, and Hunt’s sanctions motion was denied with a warning to Allen.
Recorded conduct: Allen’s pro se response to Hunt’s motion to stay cited fabricated Sterigenics U.S., LLC v. Sotera Health Co., 2020 WL 5645683 (N.D. Ill. Sep. 22, 2020); she admitted the citation was fabricated, withdrew reliance, and apologized. — 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.

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.D. Ill. Sep. 22, 2020).” No such case exists. Allen admits as much; she filed a notice of correction admitting that the citation was fabricated, withdrawing reliance on it, and apologizing to the Court. ... Magistrate Judge McShain noted such citations in her January 21, 2026 order, and stated that “each party must include an affidavit or declaration along with any filing in this case that was written or drafted using generative AI tools certifying that the filing party has verified the correctness and accuracy of the factual information and legal citations present in the filing.”

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

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).

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