Courts on AI / Fabricated or misquoted citations
Harris v. Wray
United States District Court for the Southern District of Indiana · Federal district courts · IN · · 2026 WL 2374808 · No. 1:26-cv-01342-JRO-MG · order
The Southern District of Indiana dismisses Darryl Harris’s complaint without prejudice and warns him about an incorrect citation in a service-extension motion. The court says the Walsh docket number linked to a different case, the Westlaw citation led nowhere, and future Rule 11 violations may be sanctioned.
- Disposition
- The court dismissed the complaint without prejudice, allowed amendment, and warned Harris about Rule 11 and AI-policy compliance.
- Recorded conduct
- Self-represented plaintiff cited Walsh v. Kreiger with a docket number linked to another case and a Westlaw citation that led nowhere. — 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.
In Harris's motion for extension of time to effect service of process, he cites Walsh v. Kreiger, No. 19-cv-1764, 2020 WL 6325983, at 2 (E.D. Wis. Oct. 28, 2020) (citing United States v. McLaughlin, 470 F.3d 698, 700 (7th Cir. 2006)), for the proposition that “good cause” not the stricter “excusable neglect” standard is the appropriate test for Fed. R. Civ. P. 4(m) extensions. Dkt. 15 at 3. While the Court has found McLaughlin and Walsh to be real cases, the Walsh citation is wholly incorrect. The docket number listed following Harris's Walsh cite is linked to a different case in the Eastern District of Wisconsin, and the Westlaw citation leads to nowhere. While Walsh v. Kreiger appears to be a real case and there is an October 28, 2020, order referencing Mclaughlin, the incorrect cite gives the Court pause. ... Because the Court dismisses Harris's complaint in its entirety, it will not order him to show cause at this time. However, Harris is accordingly warned of the possibility of sanctions if any future filings violate Rule 11(b).
Authorities cited in the passage: Walsh v. Kreiger, No. 19-cv-1764, 2020 WL 6325983 (E.D. Wis. Oct. 28, 2020) · United States v. McLaughlin, 470 F.3d 698 (7th Cir. 2006) · Fed. R. Civ. P. 4(m) · Fed. R. Civ. P. 11
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
Hugging Face