Courts on AI / Fabricated or misquoted citations

Harris v. Bank of America

United States District Court for the Northern District of Mississippi · Federal district courts · MS · 2026-07-30 · No. 3:25-cv-00328-MPM-JMV · memorandum opinion

Fabricated or misquoted citations Self-represented litigants using AI

The Northern District of Mississippi dismisses a pro se FCRA suit without prejudice for lack of standing. A footnote identifies two Northern District opinions that the court could not locate, calls them likely AI-generated fictitious citations, declines immediate sanctions, and warns Harris.

Disposition: The court dismissed Harris's FCRA claims without prejudice for lack of standing and warned him about hallucinated case law.
Recorded conduct: Self-represented plaintiff cited two likely fictitious Northern District of Mississippi opinions in opposition briefing. — 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.

While not touched on by the current opinion due to lack of standing, the Court will note that Mr. Harris cited “Allen v. Equifax Info. Services, LLC, 2020 WL 2155673, at 3 (N.D. Miss. Apr. 1, 2020) and LeBlanc v. TransUnion, LLC, 2021 WL 1243659, at 5 (N.D. Miss. Mar. 19, 2021)” to support his claims against BANA. These two cited Northern District of Mississippi Opinions were unable to be found by this Court, and are likely fictitious citations generated by artificial intelligence. Neither a search of the Westlaw citations or the party names brings up any corresponding case in the Northern District. Citations to and reliance on fraudulent authorities severely undermines the credibility of any of Mr. Harris’ allegations. Due to his pro se nature, the Court will not sanction Mr. Harris, but he is put on notice and will not be given the same grace if he refiles his lawsuit and cites to hallucinated case law again.

Authorities cited in the passage: Allen v. Equifax Info. Services, LLC, 2020 WL 2155673 (N.D. Miss. Apr. 1, 2020) · LeBlanc v. TransUnion, LLC, 2021 WL 1243659 (N.D. Miss. Mar. 19, 2021)

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.

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