Courts on AI / Fabricated or misquoted citations

Maxwell v. Michael

United States District Court for the Southern District of Indiana · Federal district courts · IN · 2026-05-26 · No. 1:24-cv-01365 · order

Fabricated or misquoted citations

On 2026-05-26, in William C. Maxwell v. Dakota Michael & Chelsey Smith, the Southern District of Indiana imposed a $1,000 Rule 11 sanction for non-existent citations and denied the motion for preliminary injunction. A self-represented litigant filed a motion using quotations that did not appear in the cited source and at least 37 nonexistent or hallucinated authorities.

Disposition: The court sanctioned plaintiff $1,000 payable to the Clerk and also ordered $886.80 in deposition costs payable to defendants.
Recorded conduct: The pro se plaintiff fabricated names, case numbers, citations, pincites, courts, and other identifying information for fake authorities at least thirty-seven times. The court imposed a $1,000 Rule 11 sanction for the fake citations. — outcome: fine; actor: litigant in person; $1,000
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.

163.] The Court further directed Plaintiff to file a statement showing why he should not be subject to Federal Rule of Civil Procedure 11(c) sanctions for citing and quoting non-existent cases. Plaintiff responded to the Court's order onApril 9, 2026. [Filing No. 165.] Plaintiff does not dispute that certain citations were incorrect, but claims his errors were not intentionally fabricated or designed to mislead the Court. Plaintiff argues his errors fell into two categories: (1) citations he could not locate and failed to correct, and (2) quotations that paraphrased, rather than cited, authority. [Filing No. 165, at ECF p. 2.] He argues that no additional sanctions are Plaintiff filed two motions for reconsideration of the Court's order adopting the report and recommendation. Those motions remain pending with the district judge. [Filing Nos. 173; 176.] warranted, or alternatively, that any sanction imposed be proportionate to the conduct and limited to a formal verified citation requirement going forward. In contrast, Defendants argue significant sanctions are warranted because Plaintiff acted in either bad faith or in reckless reliance on artificial intelligence by citing fake cases or quotations on at least 37 instances throughout this litigation. [Filing No.

Authorities cited in the passage: Federal Rule of Civil Procedure 11(c)

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: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. 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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