Courts on AI / Fabricated or misquoted citations

Faisal Rahman v. Michael J. Burton

United States District Court for the Northern District of Illinois · Federal district courts · IL · 2026-04-30 · No. 25 CV 8489 · memorandum opinion

Fabricated or misquoted citationscourt does not name AI

The Northern District of Illinois on 2026-04-30 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Faisal Rahman v. Michael J. Burton, et al. The self-represented plaintiff filed an opposition with two fabricated case citations.

Disposition: The motions to dismiss were granted and the case was dismissed with prejudice on the merits, with a warning about future sanctions for nonexistent authorities.
Recorded conduct: Rahman’s pro se complaint and opposition cited nonexistent Swayne and Kitchen authorities. The court warned that future Rule 11 sanctions could include dismissal, monetary sanctions, or filing restrictions. — 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.

R. Civ. P. 11(b) (emphasis added). Rule 11 applies to pro se plaintiffs, and filing documents containing citations to nonexistent cases or arguments wholly unsupported by the record violates Rule 11. In both his complaint and his opposition to defendants’ motions to dismiss, Rahman cites cases that do not exist. See, e. g. , [38] at 4 (citing a case supposedly called Swayne that does not exist at plaintiff’s citation), [38] at 51 (citing a case supposedly from the Seventh Circuit Court of Appeals called Kitchen, that does not exist at plaintiff’s citation). Case: 1:25-cv-08489 Document #: 51 Filed: 04/30/26 Page 4 of 15 PageID #:1179 Failure to comply with Rule 11 obligations in the future will result in sanctions, including dismissal of lawsuits, monetary sanctions, and a restriction on filing any new cases with the court. Rahman must not submit any filing to the court that contains false or misrepresented citations (cases that do not exist or cases that do not say what Rahman claims they say), and Rahman cannot repeat the results of computer-assisted research without personally certifying and verifying the truthfulness and accuracy of his briefs.

Authorities cited in the passage: Fed. R. Civ. P. 11

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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