Courts on AI / Fabricated or misquoted citations
Brian Smith v. TD Auto Finance LLC, et al.
United States District Court for the Northern District of Mississippi · Federal district courts · MS · · No. 19-12130,2020WL3832606, at · 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
- 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. — 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.