Courts on AI / Fabricated or misquoted citations
Curry v. Capital One Auto Finance
United States District Court for the Eastern District of North Carolina · Federal district courts · NC · · No. 5:25-CV-164-BO-KS · order
On 2026-03-26, U.S. District Court for the Eastern District of North Carolina denied leave to amend because the proposed amended complaint’s additional fabricated citations showed bad faith and amendment would be futile. A self-represented party submitted a complaint with nonexistent or misstated legal provisions and fabricated or nonexistent authorities.
- Disposition
- The court granted the motion to dismiss, denied leave to amend, and directed the clerk to close the case.
- Recorded conduct
- Plaintiff's proposed amended complaints relied on fictitious ITPA provisions and fabricated citations after a warning. — outcome: dismissal; 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.
noting that it sought to assert new claims based on fictitious provisions of the North Carolina Identity Theft Protection Act (ITPA), and concluding that plaintiff likely used artificial intelligence to draft her first proposed amended complaint. That order cautioned plaintiff that the Court will not tolerate "computer generated morass that only serves to waste court time and resources ." Id.