Courts on AI / Fabricated or misquoted citations

Maldonado v. Professional Animal Retirement Center

United States District Court for the Northern District of Indiana · Federal district courts · IN · 2026-04-01 · No. 1:25-cv-00454-HAB-ALT · order

Fabricated or misquoted citations

On 2026-04-01, U.S. District Court for the Northern District of Indiana imposed a $1,500 sanction on counsel and directed the clerk to send the sanction orders to the Rhode Island disciplinary authority. Counsel submitted a brief with mischaracterized authorities, including Animals v. NIH and FEC v. Akins.

Disposition: The court granted judicial notice, dismissed the case for lack of Article III standing, denied two PARC motions as moot, ordered counsel to pay $1,500, and referred the opinion and show-cause order to Rhode Island disciplinary authorities.
Recorded conduct: Counsel Roger Roots filed the complaint and response to PARC’s motion to dismiss with misrepresented or nonexistent opinions and citations, including authorities that did not support asserted informational-injury propositions. — outcome: regulatory referral; actor: lawyer; $1,500
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.

Jackson v. Auto-Owners Ins. Co., No. 7-24-cv-136, 2025 WL 1932274, at *5 (M.D. Ga. July 14, 2025) (imposing a $1,000 fine for the submission of filings with hallucinated cases), and Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281, 2024 WL 4882651, at *3 (E.D. Tex. Nov. 25, 2024) (imposing $2,000 sanction on attorney who submitted a response “without reading the cases cited, or even confirming the existence or validity of the cases included therein”), with Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023) (sanctioning attorneys $5,000 for producing a filing with citation to an opinion which did not exist) and HoosierVac LLC, 2025 WL 1511211, at *2 (imposing sanction of $6,000 for filing briefs containing non-existent AI-generated legal citations). Second, the Court directs the clerk’s office to transmit a copy of this Opinion and Order— as well as a copy of the Show Cause Order (ECF No. 23) which more explicitly details counsel’s misconduct—to the appropriate attorney-disciplinary authority of the State of Rhode Island where Roots is licensed. See, e.g., Amarsingh v. Frontier Airlines, Inc., No. 24-1391, 2026 WL 352016, at *8 (10th Cir. Feb. 9,

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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