Courts on AI / Fabricated or misquoted citations
Pizzimenti v. City of Detroit, et al.
U.S. District Court for the Eastern District of Michigan · Federal district courts · MI · · No. 25-11506 · opinion
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 dismissed the claims and warned that factitious citations in the complaint and motion could be treated as AI-created hallucinations.
- Recorded conduct
- The complaint used 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, which the court found nonexistent, misquoted, or unsupported. — 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
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