Anthony Josue Grajales v. Santander Consumer USA Inc., et al.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

149.) In addition, it appears Plaintiff has also been using some form of generative artificial intelligence resulting in citations which are hallucinations or other improper citations. (See Doc. 223 at 6-7 and 12-16). Defendants identify that in one of Plaintiff’s numerous responses, he made a total of “one hundred fifteen false citations.” (Doc. 186 at 4 n.2 (emphasis omitted).) This included “twenty-nine of the cases cited by - 7 - Plaintiff [that] do not exist as cited,” an “additional four cases [that] have been overturned, five cases [that] were cited for quotations that do not appear therein, and seventy-seven [that] do not contain the proposition for which they were cited.” (Id. (emphasis omitted); see also Doc. 186-1 (compiling the false citations).) “[W]hether created by generative artificial intelligence or not,” Plaintiff “submitting a filing containing false submissions . . . is unacceptable.” Simpson v. Portfolio Recovery Assocs., LLC, No. 24-CV-00094, 2025 WL 3684541, at *6 n.6 (W.D. Va. Dec. 19, 2025). ... This court finds that under the fourth factor in Cromer an alternative sanction will not “suffice[] to deter [Plaintiff] from making future filings” because, as Defendants explain, “after [Defendants] identified eight false citations in Plaintiff’s Final Amended Complaint, Plaintiff not only failed to correct these discrepancies, but still cited an additional - 8 - sixteen cases that either do not exist or fail to include the quoted language or cited propositions.” (Doc. 223 at 13 (emphasis omitted).) At the hearing, Plaintiff had no non- frivolous excuse for his continued use of irrelevant or non- existent citations.

Authorities cited in the passage: Simpson v. Portfolio Recovery Assocs