Courts on AI / Fabricated or misquoted citations

Harris v. Wray

United States District Court for the Southern District of Indiana · Federal district courts · IN · 2026-08-14 · No. 1:26-cv-01342 · order

Fabricated or misquoted citations Self-represented litigants using AI Court rules adopted by opinion or 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.

Further, the Court notes that it entered a supplemental notice to pro se litigants regarding the use of artificial intelligence on June 24, 2026. Dkt. 7. This notice and the Practices and Procedures of this Court require all litigants to tell the Court if they used artificial intelligence (AI) to help write their complaint, a motion, or any other documents they file into the case. ... Harris did file a certification of artificial intelligence use stating that "despite reliance on an AI tool, I have independently reviewed this document to confirm the accuracy and legitimacy of all cited authority"... Despite this assurance, the Court still found an incorrect citation.

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

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting. Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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