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Courts on AI / Fabricated or misquoted citations

Randolph v. Erick Berscheid Trucking, LLC et al

United States District Court for the District of Minnesota · Federal district courts · MN · · No. 17. Accordingly, the Court treated EB Trucking · order

The District of Minnesota on 2026-05-05 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Randolph v. Erick Berscheid Trucking, LLC et al. The self-represented party filed a motion with one fabricated case citation and one false case quotation.

Disposition
The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct
The self-represented party filed a motion with one fabricated case citation and one false case quotation. — 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.

7. 1(j). Because Randolph failed to obtain prior permission, his motions are unauthorized and are therefore denied. The Court notes that Randolph’s motions contain citations to non‐existent cases as well as quotes that do not appear in the cited case, suggesting that he used generative AI to create his memoranda and did not verify that his citations were accurate. By filing motions and other papers, a litigant “certifies that to the best of [his] knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . -2- the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law. ” Fed.

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