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Courts on AI / Fabricated or misquoted citations

Pittman v. Hazel and Olive, Inc.

U.S. District Court for the Northern District of Illinois · Federal district courts · IL · · No. 25 C 7791 · order

On 2026-03-19, U.S. District Court for the Northern District of Illinois dismissed the case with prejudice, struck the AI-generated response brief, and ordered counsel to pay defense fees and costs. Counsel submitted a response brief with fabricated or nonexistent authorities.

Disposition
The court dismissed the case with prejudice, struck the AI-generated response brief, and ordered counsel to pay defense fees and costs.
Recorded conduct
The response brief used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — outcome: costs order; 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.

10. 4. Reliance on AI-Generated Case Citations Defendant moved to dismiss at R. 21 and Plaintiff’s counsel responded at R. 32. Defendant then moved to strike at R. 35 on the basis that Plaintiff’s counsel’s response brief was generated by artificial intelligence and cited fake cases. At R. 38, Plaintiff’s counsel admitted that he relied on artificial intelligence, that Plaintiff’s counsel failed to cite check, and that Plaintiff’s counsel submitted fake cases to the Court. The Court finds that Plaintiff’s counsel violated Federal Rule of Civil Procedure 11 when filing his response. 5. Sanctions Given the above issues—Plaintiff’s counsel’s bad faith motion to enforce the settlement agreement, Plaintiff’s counsel’s repeated lack of candor toward the Court, Plaintiff’s counsel’s disingenuous use of discovery to generate fees, and Plaintiff’s counsel’s negligent reliance on artificial intelligence that cited fake cases—the Court orders the following sanctions. First, Plaintiff’s counsel shall cover all costs and fees incurred by Defendant in defending this lawsuit. The parties are ordered to meet and confer to determine the total costs and fees and to arrange for the payment. Any fees incurred by Defendant during this meet and confer process

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