Courts on AI / Fabricated or misquoted citations
James v. National Board of Osteopathic Examiners Inc.
United States District Court for the Southern District of Indiana · Federal district courts · IN · · 2026 WL 772373 · No. 1:23-cv-01607-JPH-TAB · order
On 2026-03-19, U.S. District Court for the Southern District of Indiana warned that future filings with nonexistent cases or unsupported authorities would result in Rule 11 sanctions. A self-represented party submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Knakmuhs v. Minneapolis Pub. Sch and Cooper v. Tokyo Elec. Power Co.
- Disposition
- The court granted summary judgment to defendant and warned James that future non-existent or unsupported cases will result in sanctions.
- Recorded conduct
- James filed materials containing non-existent cases or cases that did not stand for the propositions claimed. — 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.
stating that Ms. James would not receive in the U.S. Navy. Id. at 656. The Seventh Circuit held that accommodations on the COMAT exam because NBOME "[plaintiff's] marred record is a continuing harm for which denied her testing accommodations. Dkt. 98-2 at 9. This he [could] seek redress." Id. at 666. On remand, the district only shows, however, past harm. Ms. James does not explain court found that he adequately alleged standing for injunctive how ATSU's past reliance on NBOME's accommodation relief because he alleged that his career in the Navy would be determination imminently threatens her future rights—she available to him if his guilty finding was expunged. Doe v. has not designated evidence, or even alleged, that she plans Purdue Univ., No. 2:17-cv-33, 2020 WL 2542674, at *9 (N.D. to re-enroll in ATSU, or any other medical school. See Simic, Ind. May 19, 2020). 851 F.3d at 738 ("Unlike with damages, a past injury is insufficient to establish standing for purposes of prospective Here, Ms. James does not designate any evidence that the relief."); Perry L. v. Milwaukee Montessori Sch., No. 22- records of her two failed COMLEX-USA Level
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