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Courts on AI / Fabricated or misquoted citations

Davis v. Marion County Juvenile Detention Center

United States District Court for the Southern District of Indiana · Federal district courts · IN · · No. 1:24-cv-01918-JRO-MJD · report and recommendation

On 2026-05-20, in Davis v. Marion County Juvenile Detention Center, the Southern District of Indiana magistrate judge recommended a $2,000 sanction against counsel for two AI-generated non-existent citations. Counsel filed a motion using multiple nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Disposition
The magistrate judge recommended a $2,000 sanction against counsel for two AI-generated non-existent citations.
Recorded conduct
Counsel filed a motion using multiple nonexistent or hallucinated authorities and authorities used for propositions they did not support. — outcome: sanctions; actor: lawyer; $2,000
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.

The Magistrate Judge has recommended that the Undersigned personally sanction Plaintiff’s counsel, Tae Sture, for including two non-existent legal citations in a brief responding to a motion to compel. The legal citations were hallucinations generated by an artificial intelligence (“AI”) research tool. The Magistrate Judge found Mr. Sture’s conduct violated the Indiana Rules of Professional Conduct as well as Federal Rule of Civil Procedure 11(b). For the Rule 11 violation, the Magistrate Judge recommends that Mr. Sture be personally sanctioned in the amount of $7,500.00. Mr. Sture has objected to DAVIS v. MARION COUNTY SUPERIOR COURT JUVENILE DETENTION CENTER et al Doc. 127 Dockets.Justia.com the R&R’s findings regarding violation of the Indiana rules as well as the amount of the recommended monetary sanction. See Fed. R. Civ. P. 72(b). As further explained below, the Court respectfully REJECTS the Magistrate Judge’s R&R insofar as it concludes Mr. Sture violated the Indiana Rules of Professional Conduct. Those issues have been referred to the Indiana Disciplinary Commission by the Chief Judge.

Authorities cited in the passage: Mr. Sture has objected to DAVIS v. MARION COUNTY SUPERIOR COURT JUVENILE DETENTION CENTER et al Doc · Federal Rule of Civil Procedure 11(b) · Rule 11 · Fed. R. Civ. P. 72(b)

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