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Courts on AI / Fabricated or misquoted citations

DeVore v. McCombie

United States District Court for the Northern District of Illinois · Federal district courts · IL · · No. 1:25-cv-00323 · memorandum opinion

Fabricated or misquoted citationscourt does not name AI

The Northern District of Illinois on 2026-05-11 ordered defense counsel to file a declaration explaining how the brief was generated and how Beecham and Alvarez were located in DeVore v. McCombie. Counsel filed a motion with one fabricated case citation and one mischaracterized case citation, including Alvarez v. City of Chicago with page cites.

Disposition
The motion to dismiss was granted, the complaint was dismissed with prejudice, and counsel was ordered to file a declaration explaining the bad citations.
Recorded conduct
Defense counsel cited nonexistent Beecham authority and miscited or misrepresented Alvarez. The court ordered counsel to file a declaration explaining how the cases were generated or located. — outcome: pending; 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.

3 Because the Court dismisses Plaintiff’s only count for failure to state a claim, the Court declines to address Defendants’ arguments that Plaintiff’s allegations should be stricken as time-barred and that Defendant is protected by qualified immunity. Plaintiff failed to adequately address any of the deficiencies previously identified, so the FAC is dismissed with prejudice. D. Defendant’s citations Despite having granted Defendant’s motion to dismiss, the Court notes with some concern that Defendant appears to have cited a non-existent case in support of her argument. While arguing that Plaintiff’s claim was time barred, Defendant cited to Beecham v. City of Anniston, 42 F. 4th 1130, 1135 (11th Cir. 2022) for the proposition that “discrete acts of speech deletion must occur within limitations period.

Authorities cited in the passage: Defendant cited Alvarez v. City of Chicago with page cites

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