Courts on AI / Fabricated or misquoted citations
Justin Spiehs v. Erik Smith
United States District Court for the District of Kansas · Federal district courts · KS · · No. 5:25-cv-04067-JWB-BGS · opinion
The United States District Court for the District of Kansas on 2026-04-29 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Justin Spiehs v. Erik Smith. Counsel filed a brief with one false case quotation.
- Disposition
- The court warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
- Recorded conduct
- Counsel filed a brief with one false case quotation. — outcome: warning; actor: lawyer
- 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.
Second, the court will allow Plaintiff’s excessive force complaint against Defendants Byttner and Manker to move forward as he alleges that they unnecessarily kneed him and struck Defendants point out to the court that three cases cited and quoted by Plaintiff in support of this proposition are defective as the quotes used in Plaintiff’s brief are not present in the cited cases. (Doc. 39 at 6. ) The court has confirmed this contention. The court strongly suspects this is a product of the use of artificial intelligence, given that a Westlaw search for these precise quotes turned up no exact results. While the court declines to enter a show cause order at this time, Plaintiff’s counsel is strongly warned that the any further incorrect quotations could result in sanctions under Fed. R. Civ. P. 11 and D.
Authorities cited in the passage: 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
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