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Courts on AI / Fabricated or misquoted citations

In re: Telexfree Securities Litigation

United States District Court for the District of Massachusetts · Federal district courts · MA · · 2026 WL 412550 · No. No. 4:14-md-2566-NMG · memorandum opinion

District of Massachusetts on 2026-02-13 in In re: Telexfree Securities Litigation found counsel's filing contained four citation defects, including Jensen v. Phillips Screw Co, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

Disposition
The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
Recorded conduct
Counsel's filing contained four citation defects, including Jensen v. Phillips Screw Co, involving nonexistent authorities, fabricated or misattributed quotations. — outcome: pending; 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.

purpose of securing Attorney Bonsignore's status as lead Furthermore, this is not the first time that Attorney counsel and (2) any evidence supporting Dos Santos’ claims Passatempo has misrepresented the law to this Court, and is so obviously absent from the record that her attorneys must such misrepresentations bear the clear hallmark of artificial have known that her claims were frivolous. intelligence hallucinations. 1 Wadsworth v. Walmart Inc., The record is not, however, as deficient as defendants suggest. 348 F.R.D. 489, 493 (D. Wyo. 2025) (“A hallucination First, defendants point to the Court's entry of summary occurs when an AI database generates fake sources of judgment against plaintiff (Docket No. 2292) as support information.”). Plaintiff's counsel should be prepared to for the argument that her claims were baseless from the address these misrepresentations at the status conference outset. A ruling of summary judgment does not, however, scheduled for February 19, 2026, and to show cause why the automatically render the losing claims so frivolous as to Court should not impose sanctions and/or refer the matter to entitle the prevailing party to attorneys’ fees. See Nelson v. the Massachusetts Board of Bar Overseers.

Authorities cited in the passage: l Co. v. Rochem Int · Wadsworth v. Walmart Inc

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