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Courts on AI / Fabricated or misquoted citations

Withers v. City of Aberdeen

United States District Court for the Northern District of Mississippi · Federal district courts · MS · · No. 1:24-CV-218-SA-RP · order

On 2026-06-08, in Withers v. City of Aberdeen, the Northern District of Mississippi revoked pro hac vice admission, disqualified resident counsel, fined counsel $8,000, and referred the matter to bar authorities. Counsel filed opposition papers using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Disposition
The court revoked pro hac vice admission, disqualified resident counsel, fined counsel $8,000, and referred the matter to bar authorities.
Recorded conduct
Counsel filed opposition papers using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support. — outcome: referral; actor: lawyer; $8,000
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 December 10, 2025, the Court entered an Order to Show Cause [110] directing all counsel of record in this case to show cause as to why the Court should not impose sanctions against them pursuant to Rule 11 of the Federal Rules of Civil Procedure, the Court’s Local Rules, and/or its inherent authority for filing legal memoranda containing hallucinated case citations. The four attorneys, namely Kathleen M. Wilson, Shauncey Hunter Ridgeway, Kathryn Y. Williams, and Mark C. McClinton, appeared before the Court on January 20, 2026 for a hearing on this matter. Following entry of the Order to Show Cause [110], both parties submitted Motions for Leave [112, 113] to file corrected versions of the legal memoranda in issue. Having considered the record, the applicable law, and counsels’ explanation presented at the hearing, the Court is prepared to rule on the sanctions issue, as well as on the related pending Motions [112, 113]. Relevant Factual and Procedural Background A brief recitation of the facts underlying this case provides helpful context. This action involves a contractual dispute between Withers and the City of Aberdeen (“the City”) over legal fees. Withers is a licensed attorney in the State of Louisiana whose Complaint [1] brings a single breach of contract claim against the City. He is represented in this case by Kathleen M.

Authorities cited in the passage: Rule 11

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