Courts on AI / Fabricated or misquoted citations

Ford v. Sherwin-Williams

United States District Court for the District of Kansas · Federal district courts · KS · 2026-03-31 · No. 25-1022-DDC-GEB · memorandum opinion

Fabricated or misquoted citations

On 2026-03-31, U.S. District Court for the District of Kansas denied the plaintiff’s review and default motions and warned that future fabricated or incorrect legal authority could bring sanctions or dismissal. A self-represented party submitted a filing with false quotations and fabricated or nonexistent authorities, including Clark v. City of Shawnee, Kansas, No. 21-2223-EFM.

Disposition: The court struck plaintiff's supplemental complaint for pleading defects, granted in part and denied in part Sherwin-Williams's motion to dismiss, denied default judgment, and warned plaintiff about future fabricated or incorrect authority.
Recorded conduct: Plaintiff's brief attributed a quotation to Clark v. City of Shawnee, Kansas, but the Westlaw number returned a California Court of Appeals case and the case number was for different parties; the court also found fictitious citations and quotations in the brief. — 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.

The court located fictitious citations and quotations in plaintiff’s brief. See Doc. 42 at 3. For example, plaintiff attributes a quotation to a case with this citation: “Clark v. City of Shawnee, Kansas, No. 21-2223-EFM, 2021 WL 4129476 (D. Kan. Sept. 9, 2021).” Id. That Westlaw number—2021 WL 4129476—returns a case from the California Court of Appeals. And the case number, No. 21-2223, is for a case with different parties than plaintiff represents. The court suspects that plaintiff used artificial intelligence to produce this citation. ... The court cautions plaintiff that he will face sanctions—including possibly “monetary sanctions” or dismissal of this case—if he submits future filings containing “fabricated or incorrect legal authority.”

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 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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