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Courts on AI / Fabricated or misquoted citations

Roger Patel et al. v. Chandresh Patel et al.

United States District Court for the Western District of Kentucky · Federal district courts · KY · · No. 4:24-CV-00053-GNS · memorandum opinion

Fabricated or misquoted citationsgenerative artificial intelligence

On 2026-05-28, in Roger Patel et al. v. Chandresh Patel et al, the Western District of Kentucky warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. Counsel filed a response using quotations that did not appear in the cited source and authorities used for propositions they did not support.

Disposition
The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
Counsel filed a response using quotations that did not appear in the cited source and authorities used for propositions they did not support. — 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.

RESPONDENTS MEMORANDUM OPINION AND ORDER In reviewing Petitioners’ Response to Respondents’ Motion to Dismiss (DN 61), the Court identified a series of citations and quotations that appear to be generative artificial intelligence (“AI”) hallucinations. Petitioners’ counsel—Daniel N. Thomas and Mary E. Jocelyn—were ordered to show cause why they should not be sanctioned pursuant to Fed. R. Civ. P. 11(b)(2) and (c), and the inherent power of the Court. (Show Cause Order, DN 65). Fed. R. Civ. P. 11 requires lawyers to certify that their “claims, defenses, and other legal contentions are warranted by existing laworby a nonfrivolous argument for extending,modifying, or reversing existing law or for establishing new law.” Fed. R. Civ. P. 11(b)(2). “If, after notice and a reasonable opportunity to respond, the court determines that Rule 11(b) has been violated, the court may impose an appropriate sanction upon any attorney, law firm, or party that violated the rule or is responsible for the violation.” Fed. R. Civ. P. 11(c)(1). Whether to impose sanctions under Fed. R. Civ. P. 11 “is a matter of judicial discretion.” LinearGrp.Servs., LLC v. Attica Automation,Inc.,No.13-10108,2014WL 3400714,at *14(E.D. Mich. July 11, 2014) (collecting federal authorities).

Authorities cited in the passage: LLC v. Attica Automation · Fed. R. Civ. P. 11(b)(2) · Fed. R. Civ. P. 11 · Rule 11(b) · Fed. R. Civ. P. 11(c)(1)

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