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Courts on AI / Fabricated or misquoted citations

Snisko v. Cascade Funding Mortgage Trust HB4

United States District Court for the Northern District of Illinois · Federal district courts · IL · · No. 25 CV 13339 · memorandum opinion

The Northern District of Illinois affirms a bankruptcy abstention order and identifies false quotations and erroneous legal statements in Peter Snisko’s appellate brief. The court says counsel doubled down after appellee flagged the errors and orders attorney Martin Spencer to show cause regarding fabricated citations and other misrepresentations.

Disposition
The court affirmed the bankruptcy court and ordered appellant's counsel to show cause why he should not be sanctioned.
Recorded conduct
Appellant’s counsel filed false quotations and erroneous statements of law, then repeated them in reply after appellee identified the errors. — 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.

Appellant’s brief is replete with false quotations and erroneous statements of law. By way of example, appellant cites In re Chi., Milwaukee, St. Paul & Pac. R.R. Co., 6 F.3d at 1188, for the proposition that the applicable standard of review is de novo. [17] at 18. True, a bankruptcy court’s legal conclusions are reviewed de novo. But this proposition cannot be found in the cited case. To the contrary, In re Chi., Milwaukee, St. Paul & Pac. R.R. Co. makes clear that the proper standard of review for a permissive-abstention case is abuse of discretion. 6 F.3d at 1188. Another example includes apparent quotations that do not appear in the cited cases. See, e.g., [17] at 32 (falsely quoting In re Tarnow, 749 F.2d 464, 465 (7th Cir. 1984)); [17] at 23 (falsely quoting In re Aguirre, 37 F.4th 427, 431 (7th Cir. 2022)); [17] at 26 (falsely quoting In re Boughton, 60 B.R. 373, 376 (N.D. Ill. 1986)); [17] at 39 (falsely quoting In re Chi., Milwaukee, St. Paul & Pac. R.R. Co., 6 F.3d at 1192)). ... I order appellant’s counsel, Martin Spencer, to show cause why he should not be sanctioned for the fabricated legal citations and other misrepresentations.

Authorities cited in the passage: In re Chi., Milwaukee, St. Paul & Pacific Railroad Co., 6 F.3d 1184 (7th Cir. 1993) · In re Tarnow, 749 F.2d 464 (7th Cir. 1984) · In re Aguirre, 37 F.4th 427 (7th Cir. 2022) · In re Boughton, 60 B.R. 373 (N.D. Ill. 1986) · In re Pajian, 785 F.3d 1161 (7th Cir. 2015) · In re K&R Mining, Inc., 135 B.R. 269 (Bankr. N.D. Ohio 1991) · Secrease v. Western & Southern Life Insurance Co., 800 F.3d 397 (7th Cir. 2015)

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