Courts on AI / Fabricated or misquoted citations
Joseph Maldonado v. Professional Animal Retirement Center
U.S. District Court for the Northern District of Indiana · Federal district courts · IN · · No. 1:25-cv-00454-HAB-ALT · opinion
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 imposed a $1,500 sanction on counsel and directed the clerk to send the sanction orders to the Rhode Island disciplinary authority.
- Recorded conduct
- The brief used mischaracterized authorities, including Animals v. NIH and FEC v. Akins, which the court found nonexistent, misquoted, or unsupported. — outcome: 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,