Courts on AI / Fabricated or misquoted citations
Curtin v. Watts, et al.
United States District Court for the Middle District of North Carolina · Federal district courts · NC · · No. 1:25-cv-00782-TDS-JGM · memorandum opinion
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 court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
- Recorded conduct
- 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. — 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.
Rule 11(b) and Fabrication of Legal Authority Finally, Curtin points to reprimands issued against Cyberlux in other litigation, specifically an order to pay attorneys’ fees and a show-cause order for fabricating or misrepresenting legal authorities. (Doc. 48 at 9.) He contends that Cyberlux has engaged in a “persistent pattern of deception and obstruction” that undermines Cyberlux's argument that the complaint’s “well- documented facts” are implausible. (Id.) There is a certain irony in all of this. Curtin’s brief contains fabricated quotations that directly contradict the actual holdings of the cited cases – the same misconduct he invokes to discredit Cyberlux. Cyberlux’s conduct has already been addressed by those courts.6 Meanwhile, this court must address Curtin’s conduct in the present case. Curtin represents that in Sinochem International Co. Ltd. v. Malaysia International Shipping Corp., 549 U.S. 422, 430 (2007), the United States Supreme Court held that “[a] court lacking jurisdiction . . . must dismiss, it cannot transfer.” (See Doc. 29 at 7.) This quotation is a fabrication.
Authorities cited in the passage: Sinochem International Co. Ltd. v. Malaysia International Shipping Corp., 549 U · Rule 11(b)
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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