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Courts on AI / Fabricated or misquoted citations

Derence V. Fivehouse v. United States Department of Defense et al.

United States District Court for the Eastern District of North Carolina · Federal district courts · NC · · No. No. 2:25-CV-00041-M · memorandum opinion

Eastern District of North Carolina on 2026-03-02 in Derence V. Fivehouse v. United States Department of Defense et al. found counsel's motion contained seven citation defects involving fabricated or misattributed quotations, incorrect statutory or rule text. The court admonished counsel to verify cited authorities and avoid repeating the citation defects.

Disposition
The court admonished counsel to verify cited authorities and avoid repeating the citation defects.
Recorded conduct
Counsel's motion contained seven citation defects involving fabricated or misattributed quotations, incorrect statutory or rule text. — outcome: warning; actor: lawyer
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.

v. Sullivan, 915 F.2d 129, 130 (4th Cir. 1990). 4. The inclusion of a fabricated quotation from 32 C.F.R. § 199.21(d) in Defendants’ response opposing Fivehouse’s motion for a preliminary injunction (D.E. 39). 5. The inclusion of a fabricated quotation from 32 C.F.R. § 199.21(d) in Defendants’ response opposing Fivehouse’s motion for summary judgment (D.E. 90). 2 Case 2:25-cv-00041-M-RN Document 119 Filed 03/02/26 Page 2 of 4 6. Making false or misleading statements regarding how and why the fabricated quotations and misstatements appeared in D.E. 86. If established, such conduct may implicate North Carolina Rules of Professional Conduct 3.3(a)(1), 8.4(c), and 8.4(d). If a violation is established, the court may impose any sanction authorized by Rule 11, its

Authorities cited in the passage: n v. Sullivan in Defendants · D.E.86 attributing holdings to Ohio Valley Environmental Coalition v. Aracoma Coal Co · LLC v. National Marine Fisheries Service · D.E.86 attributing holdings to Sierra Club v. United States Dept. of the Interior · Rule 11 · 32 C.F.R. § 199.21(d)

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