Courts on AI / Fabricated or misquoted citations

Patel v. Patel

United States District Court for the Western District of Kentucky · Federal district courts · KY · 2026-07-07 · No. 4:24-cv-00053 · memorandum opinion

Fabricated or misquoted citations Competence, fees and billing

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 found the show-cause order satisfied and declined to impose sanctions.
Recorded conduct: Petitioners’ counsel filed a response with a series of citations and quotations that appeared to be generative-AI hallucinations. The court found counsel’s responses satisfied the show-cause order and declined sanctions. — 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)

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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