Courts on AI / Fabricated or misquoted citations

Jessica Fuller v. Hyde School

United States District Court for the District of Maine · Federal district courts · ME · 2026-05-05 · No. 2:25-cv-00354-SDN · order

Fabricated or misquoted citationsClaude or ChatGPT

The District of Maine on 2026-05-05 struck the defective opposition, ordered counsel to serve the order on the client, complete CLE, and certify firm AI procedures in Jessica Fuller v. Hyde School, et al. Counsel filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation.

Disposition: The response was struck, an amended opposition was ordered, and counsel was ordered to complete AI CLE, implement procedures, give client notice, and certify compliance.
Recorded conduct: Counsel used Claude or ChatGPT to generate citations in a response and errata, producing inaccurate citations and descriptions. The court imposed non-monetary sanctions including AI CLE, firm procedures, client notice, and certification. — outcome: sanctions; 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.

An attorney who chooses to use such tools must ensure that every citation and quoted passage has been independently confirmed using reliable legal sources, and that any limitations of AI tools are fully understood and accounted for. Here, the Courtfinds that several specific aspects of counsel’s conductdid notsatisfy thestandard required by Rule 11. She relied on generative AI to produce case citations and descriptions but did not confirm that those authorities existed or accurately stated the law before filing. After Defendants identified significant errors in the original filing, she did not promptly withdrawor correctit, and it remains on the docket. In her Noticeof Errata,sherepeated and extended some of the same problems instead of fully remedying them. She has not <pageID> shown that she reimbursed her client for time spent on the faulty filings.

Authorities cited in the passage: Fed. R. Civ. P. 11

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: 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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