Courts on AI / Fabricated or misquoted citations
Smith v. TD Auto Finance LLC
United States District Court for the Northern District of Mississippi · Federal district courts · MS · · No. No. 3:25-cv-00312-JDM-RP · memorandum opinion
The Northern District of Mississippi on 2026-04-14 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Brian Smith v. TD Auto Finance LLC, et al. The self-represented party filed a motion with one fabricated case citation.
- Disposition
- Smith’s motion for reconsideration was denied, TD Auto was directed to initiate arbitration, and the case remained stayed.
- Recorded conduct
- Smith’s pro se reconsideration motion cited AI-hallucinated cases; the court noted this was not the first time his filings cited fictitious authorities but that the motion predated the prior admonishment. — 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.
Smith’s claims against the non-signatories—SBI, A & A, and B & C—must be hashed out in arbitration. The Court declines to lift the stay as to the non-signatory defendants. Artificial Intelligence Though the Court has found good reason to deny Smith’s motion, it pauses to address Smith’s use of generativeAI. In response to the motion, the non-signatory defendants directed the Court’s attention to AI-hallucinated cases in Smith’s motion. This is not the first time Smith’s filings cited fictitious legal authorities. And the Court has admonished Smith against further fictitious citations. [40] But the Court does note Smith had already filed his motion for reconsideration before the Court’s admonishment.
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
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