Courts on AI / Fabricated or misquoted citations
AndDone, LLC v. Gaines
United States District Court for the Western District of Missouri · Federal district courts · MO · · No. 4:25-cv-00346-RK · order
The Western District of Missouri enters default judgment against Shante Gaines and recounts an earlier Rule 11 show-cause order over citations to nonexistent cases and quotations in a November 2025 filing. The court notes Gaines did not respond to the show-cause order or comply with discovery obligations.
- Disposition
- The court granted Rule 37 fees and default judgment against Gaines, and denied alternative default-judgment motions as moot.
- Recorded conduct
- Self-represented defendant filed a November 2025 submission with misrepresentations, citations to nonexistent cases, and quotations, then did not answer a Rule 11 show-cause order. — 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.
On November 21, 2025, AndDone filed a motion requesting an order that Gaines show cause why she should not be sanctioned for violations of Federal Rule of Civil Procedure 11 for misrepresentations to the Initial Court including citations to nonexistent cases and quotations contained in a November 18 filing, (Doc. 53). (Doc. 57.) ... The Initial Court also ordered Gaines to show cause why she should not be sanctioned for the Rule 11 violations identified in AndDone’s motion for order to show cause by December 12, 2025. (Doc. 59.) Gaines did not provide further written discovery responses as ordered, she did not appear for her deposition, and she did not respond to the Initial Court’s show cause order.
Authorities cited in the passage: Fed. R. Civ. P. 11 · Fed. R. Civ. P. 37
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