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Courts on AI / Fabricated or misquoted citations

Burches v. Equifax Information Services, LLC

United States District Court for the Eastern District of Louisiana · Federal district courts · LA · · No. 25-804 · order

Fabricated or misquoted citationscourt does not name AI

The Eastern District of Louisiana on 2026-05-11 ordered the self-represented plaintiff to pay $500 for filing unverified or fabricated authorities in Burches v. Equifax Information Services, LLC, et al. The self-represented plaintiff filed a reply brief with two fabricated case citations, one false case quotation, and one mischaracterized case citation, including Hays v. HCA Holdings.

Disposition
The court imposed a $500 sanction payable to the Clerk for repeated fabricated or unverifiable citations.
Recorded conduct
After prior warnings, Burches again submitted fabricated, inaccurate, or unverifiable citations in pro se filings. The court imposed a $500 sanction payable to the Clerk. — outcome: fine; actor: litigant in person; $500
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.

m. BACKGROUND Plaintiff has repeatedly filed briefs containing fabricated, inaccurate, or unverifiable legal citations. The issue first arose in connection with Plaintiff’s Motion for Leave to File a Third Amended Complaint,1 when Defendant Trans Union LLC (“Trans Union”) filed an Ex Parte Motion for Leave to File a Surreply,2 representing that “[a] closer examination of Plaintiff’s Motion reveals Plaintiff’s reliance on fabricated and/or non-existent legal authorities. ”3 The Court granted the Motion,4 and Trans Union’s Surreply was filed onto the record. 5 The Court then set oral argument on the Motion. 6 Before oral argument, Plaintiff filed a Notice of Clarification admitting the citations in his Reply were fabricated and apologizing for the error.

Authorities cited in the passage: Plaintiff cited a purported holding from Hays v. HCA Holdings, Inc · Plaintiff cited Turner v. Murphy Oil USA, Inc., 2006 WL 1984362 (E.D. La. July 13, 2006)

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