Courts on AI / Fabricated or misquoted citations

Curtin v. Watts

United States District Court for the Middle District of North Carolina · Federal district courts · NC · 2026-05-20 · No. 1:25CV782 · memorandum opinion

Fabricated or misquoted citations

On 2026-05-20, in Curtin v. Watts, et al, the Middle District of North Carolina warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a brief using quotations that did not appear in the cited source and authorities used for propositions they did not support.

Disposition: The motions to dismiss were granted, the amended complaint was dismissed, and Curtin was warned that future fabricated legal authority may lead to sanctions.
Recorded conduct: Curtin’s pro se complaint contained fabricated quotations, fictitious citations, and misstatements of law that the court described as likely the product of artificial intelligence. The court warned him not to submit fabricated legal authority again. — outcome: warning; 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.

...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) (collecting cases) (emphasis added). It is not clear whether Curtin’s complaint and briefs are the product of artificial intelligence. To be sure, this court has 16 Case 1:25-cv-00782-TDS-JGM Document 66 Filed 05/20/26 Page 16 of 18 seen an uptick in the use of artificial intelligence in complaints and briefs, especially by pro se filers. Whether or not Curtin used such tools, he is admonished that every filer, including a pro se filer, is “obligated to read the legal authority he intends to rely upon, confirm its exist...

Authorities cited in the passage: Sinochem International Co. Ltd. v. Malaysia International Shipping Corp., 549 U · Rule 11(b)

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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