Courts on AI / Fabricated or misquoted citations

Pizzimenti v. City of Detroit

United States District Court for the Eastern District of Michigan · Federal district courts · MI · 2026-03-27 · No. 25-11506 · order

Fabricated or misquoted citations

On 2026-03-27, U.S. District Court for the Eastern District of Michigan dismissed the claims and warned that factitious citations in the complaint and motion could be treated as AI-created hallucinations. A self-represented party submitted a complaint with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Williams v. City of Cleveland, No. 1:18-CV-2911 and Jensen v. Utah Cnty.

Disposition: The court adopted the reports and recommendations, dismissed the case, and warned plaintiff to review authorities before filing.
Recorded conduct: Plaintiff's response brief and complaint contained multiple factitious citations to authorities that did not exist or did not support the proposition offered. — 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.

Court has noticed factitious citations in other filings by Plaintiff, such as the complaint. 4 The Court is concerned by these factitious citations, which may be created by generative artificial intelligence (“AI”) tools. See United States v. Hayes, 763 F. Supp. 3d 1054, 1065 (E.D. Cal. 2025). “It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, Plaintiff’s complaint (ECF No. 1) contains factitious citations. As previously mentioned, see supra n.2, Plaintiff’s reference to Opulent Life Church, 697 F.3d 279, related to his Eighth Amendment claim does not make sense. (See ECF No. 1, PageID.10.) Additionally, the complaint makes repeated references to “Thaxton v. City of Pontiac, No. 298862, 2011 WL 522951 (Mich. Ct. App. Feb. 15, 2011),” (ECF No. 1, PageID.8, 9), but this case does not exist. Similarly, the complaint references “Smith v. State, 26 N.E.3d 1167 (Ind. 2015)” (ECF No. 1, PageID.3, 5, 6, 17, 18), but the Court is unable to find a case resembling this citation that has any relevance to the issues raised in this case. courts have seen a rash of cases in

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: 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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