Courts on AI / Fabricated or misquoted citations
Quinones v. Love
United States District Court for the Eastern District of Missouri · Federal district courts · MO · · No. 4:25-cv-01202-SEP · memorandum opinion
On 2026-03-31, U.S. District Court for the Eastern District of Missouri ordered the plaintiff to show cause by April 17, 2026 why Rule 11 sanctions should not issue for nonexistent cases and mischaracterized authorities. A self-represented party submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Egelhoff v. Egelhoff and Wilkerson v. Wilkerson.
- Disposition
- The court dismissed the case without prejudice on initial review, denied plaintiff's pending motions as moot, ordered redaction and re-docketing of one filing, and ordered plaintiff to show cause why he should not be sanctioned for fake and mischaracterized authority.
- Recorded conduct
- Plaintiff cited at least three fake cases in an exhibit and misreported holdings of real cases, including Egelhoff, Wilkerson, Robinson, Haig v. Agee, and a purported U.S. v. Bigelow citation that resolved to a different case. — outcome: pending; 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.
P. 11(b). “Every filing in a federal court that contains citations to phony case law amounts to a violation of Rule 11(b) of the Federal Rules of Civil Procedure.” Turnage, 2025 WL 3052638, at *3; see also Mills v. City of St. Louis, 2025 WL 3470293, at *1 (E.D. Mo. Dec. 3, 2025) (“Providing the Court with fake cases and forged quotations cannot be squared with Rule 11(b).”). Plaintiff is ordered to show cause by April 17, 2026, why he should not be sanctioned under Rule 11(b) for citing non-existent cases and mischaracterizing existing ones. Though the Court will not decide whether or how to sanction Plaintiff until it reviews his response to this Order, it notes that it has “broad discretion in the choice of sanctions.” Vallejo v. Amgen, Inc., These are not the only examples. See also, e.g., Doc. [1-1] at 13 (citing case called U.S. v. Bigelow with case reporter cite 620 F.2d 911 for the proposition that “states must recognize the constitutional rulings of other jurisdictions when determining enforceability.” That reporter cite is to real case Precious Metals Assocs., Inc. v. Commodity Futures Trading Comm’n, 620