Courts on AI / Fabricated or misquoted citations
Cynthia White v. Walmart, Inc.
United States District Court for the Southern District of Indiana · Federal district courts · IN · · No. 1:25-cv-01120-RLY-TAB · order
The Southern District of Indiana on 2026-04-14 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Cynthia White v. Walmart, Inc. Counsel filed a submission with one fabricated or AI-like submission item and one misstated record or submission point.
- Disposition
- The court warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
- Recorded conduct
- Counsel relied on AI-generated discovery talking points that overstated every interrogatory response as deficient instead of conducting a real meet-and-confer. — outcome: warning; 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.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION CYNTHIAWHITE, ) ) Plaintiff, ) ) v. ) No. 1:25-cv-01120-RLY-TAB ) WALMART, INC. , ) ) Defendant. ) DISCOVERY ORDER FOLLOWING APRIL10, 2026, TELEPHONIC STATUS CONFERENCE Artificial intelligence can be a useful discovery tool. However, as discussed below,AI is not a substitute for attorneys and litigants exercising independent judgment and oversight in the discovery process. Relatedly, the Court once again reminds counsel of their obligation to meaningfully meet and confer with one another before seeking the Court's involvement in discovery disputes. Exclusive reliance onAI-generated discovery responses does not satisfy this obligation. I. Background Plaintiff Cynthia White alleges that Defendant Walmart wrongfully terminated her in retaliation for making a worker's compensation claim.