Skip to content

Courts on AI / Fabricated or misquoted citations

McNeil v. Bisignano

United States District Court for the District of Maine · Federal district courts · ME · · No. 2:25-cv-00292-SDN · order

Fabricated or misquoted citationsSelf-represented litigants using AI

The District of Maine grants summary judgment to the Social Security Commissioner and dismisses Alexander McNeil’s amended complaint. A footnote flags several nonexistent or fabricated legal authorities in the pro se pleadings and cautions McNeil to personally verify each future citation.

Disposition
The court granted summary judgment for the Commissioner and cautioned McNeil to personally check future citations.
Recorded conduct
Self-represented plaintiff filed pleadings with several citations to nonexistent or fabricated legal authority. — outcome: warning; actor: litigant in person
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.

The Court notes the presence of several citations to nonexistent or fabricated legal authority in Plaintiff's pleadings. “Although courts are solicitous toward pro se litigants, there are reasonable limits”—“a pro se litigant must not provide the Court with erroneous and factitious citations and has an obligation to review documents filed with the Court to make certain they are scrupulously accurate.” Everett J. Prescott, Inc. v. Beall, No. 1:25-cv-00071, 2025 WL 2084353, at *2 (D. Me. July 24, 2025) (quotation modified). Should Plaintiff continue to litigate matters before this Court, he is cautioned that he bears an obligation to personally check each citation to ensure it is “accurate and stands for its asserted proposition.” Id. ... For these reasons, the Commissioner’s motion for summary judgment, ECF No. 22, is GRANTED. Plaintiff’s amended complaint, ECF No. 20, is DISMISSED.

Authorities cited in the passage: Everett J. Prescott, Inc. v. Beall, No. 1:25-cv-00071, 2025 WL 2084353 (D. Me. July 24, 2025) · 42 U.S.C. § 405(g)

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub