Bank of America v. Mapp

What the court wrote

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

Rule 11(b)(2) provides that by signing a filing, an attorney or unrepresented party certifies that, to the best of his knowledge and after a reasonable inquiry, “the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law.” The rule permits courts to sanction litigants for citations to non-existent case law, misrepresentations of case law, or frivolous legal arguments, regardless of the filer’s pro se status. See, e.g., Ferris v. Amazon.com Servs., LLC, 778 F. Supp. 3d 879, 882 (N.D. Miss. 2025) (ordering a pro se plaintiff to pay the defendant’s costs incurred in responding to fabricated citations). “Courts across the country have issued sanctions against attorneys and pro se parties for submitting fictitious case citations, fictitious quotations, and related misrepresentations to the court.” United States v. Hayes, 763 F. Supp. 3d 1054, 1071 (E.D. Cal. 2025) (emphasis added) (collecting cases). This court has seen an increased use of Artificial Intelligence in briefs, especially by pro se filers. Any user of such tools, including a pro se filer, is still “obligated to read the legal authority he intends to rely upon, confirm its existence and validity, and confirm that it supports his legal contentions, before citing to that authority in any submission to this Court.” Allen v. W. Governors Univ., No.

Authorities cited in the passage: Ferris v. Amazon.com Servs · United States v. Hayes, 763 F · Allen v. W. Governors Univ., No · Rule 11(b)(2)