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Courts on AI / Fabricated or misquoted citations

Tina Rose v. City of West Frankfort et al.

United States District Court for the Southern District of Illinois · Federal district courts · IL · · No. Case 3:25-cv-00845-JPG · order

Southern District of Illinois on 2026-03-10 in Tina Rose v. City of West Frankfort et al. found the self-represented party's filing contained one citation defect involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's filing contained one citation defect involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. — 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.

“A person commits a hate crime when, by reason of the actual or perceived . . . physical or mental disability . . . of another individual or group of individuals, regardless of the existence 3 The Court believes that Plaintiff may be using generative AI platforms, such as ChatGPT, to draft her filings. Plaintiff should be cautious when using these platforms. They are known to create fictitious citations and to misrepresent case holdings. Federal Rule of Civil Procedure 11 imposes a duty on pro se plaintiffs to ensure that all legal contentions are supported by existing law or a nonfrivolous argument for extending the law. Even if Plaintiff uses AI to draft her filings, she remains responsible for ensuring that they are accurate and do not include fabricated caselaw, citations, or quotations. The Court warns Plaintiff that failure to comply with Rule 11’s obligations may result in appropriate sanctions. 19 Case 3:25-cv-00845-JPG Document 75 Filed 03/10/26 Page 20 of 21 Page ID #589 of any other motivating factor or factors, he or she commits . . . intimidation . . . .” 720 ILCS 5/12-7.1(a). Intimidation occurs when a person, “with intent to cause another to perform or to

Authorities cited in the passage: Rule 11

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