Courts on AI / Fabricated or misquoted citations

Boyle v. Kramer

United States District Court for the Eastern District of Michigan · Federal district courts · MI · 2026-05-28 · No. 25-13857 · order

Fabricated or misquoted citations

On 2026-05-28, in Boyle, et al. v. Steven Kramer, the Eastern District of Michigan warned that future filings containing fabricated legal authorities may lead to sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Disposition: The court overruled plaintiffs’ objections and warned that future factitious citations will not be tolerated and may be sanctioned.
Recorded conduct: The pro se plaintiffs attributed a quotation to Scheuer v. Rhodes that did not appear in that case and appeared factitious. The court overruled objections and warned about future citations. — 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.

Many cases discuss the phenomenon of fabricated citations and quotations that appear to be created by generative artificial intelligence (“AI”) tools.

Authorities cited in the passage: Evans v. Robertson, No. 24-13435, 2025 WL 3126852, at *4 (E.D. Mich. Nov. 7, 2025) · Ali v. IT People Corp

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
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 Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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