Courts on AI / Fabricated or misquoted citations
Elbert Coleman, III; Elbert Coleman, IV v. Nexo Capital Inc.
U.S. District Court for the Southern District of Indiana · Federal district courts · IN · · 2026 WL 994492 · No. 106 at · opinion
On 2026-03-31, U.S. District Court for the Southern District of Indiana granted summary judgment to the defendant and warned the self-represented plaintiffs that their contract-voiding authorities were inaccurate. A self-represented party submitted a motion with nonexistent or misstated legal provisions and fabricated or nonexistent authorities, including Kramer v. Trans-Lux Corp., 24 F.3d 1001 and Indiana Code § 23-2-1-2.
- Disposition
- The court granted summary judgment to the defendant and warned the self-represented plaintiffs that their contract-voiding authorities were inaccurate.
- Recorded conduct
- The motion used nonexistent or misstated legal provisions and fabricated or nonexistent authorities, including Kramer v. Trans-Lux Corp., 24 F.3d 1001 and Indiana Code § 23-2-1-2, which the court found nonexistent, misquoted, or unsupported. — 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.
opposing Defendant's summary judgment motion, so the Court need not address it. In support of their argument that the contract is void, Plaintiffs cite “Indiana Code § 23-2-1-2” and “Kramer v. Trans-Lux Corp., 24 F.3d 1001 (7th Cir. 1994)” for the proposition that transactions involving unregistered securities are void. (Docket No. 107 at ECF p. 3). These citations are inaccurate. A search of the Indiana Code statute reveals that it has been repealed, and no such case exists at the Seventh Circuit, though there is one with the same name from the District of Connecticut. Kramer v. Trans-Lux Corp., No. 3:11- cv-1424, 2012 WL 4444820 (D. Conn. Sept. 25, 2012). It is unclear whether Plaintiffs’ citations are fabricated or erroneously cited. Regardless, all parties, including those proceeding pro se, must conduct a reasonable inquiry to determine that all factual and legal allegations contained in court filings are supported as required by Federal Rule of Civil Procedure 11. A party's failure to adhere to this rule authorizes sanctions, including the dismissal of the case. See Fed. R. Civ. P. 11(c). Although sanctions are not imposed here in light of the present Motion's disposition, the Court cautions all parties to adhere to this rule, especially where artificial intelligence (“AI”) may have been used to assist parties in preparing filings. See Jones v. Kankakee Cnty. Sheriff's Dep't, No. 25-1251, 2026 WL 157661, at *3 (7th Cir. Jan. 21, 2026) (“As pro se litigants employ AI to assist with court filings, a basic reminder seems wise. Accuracy and honesty matter.”).
Authorities cited in the passage: Fed. R. Civ. P. 11(c)