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Courts on AI / Fabricated or misquoted citations

Ebony Sherisse Lucas v. Charles W. Scharf, et al.

United States District Court for the Western District of North Carolina · Federal district courts · NC · · 2026 WL 642917 · No. CIVIL ACTION NO. 3:25-CV-01015-KDB-WCM · order

Western District of North Carolina on 2026-02-24 in Ebony Sherisse Lucas v. Charles W. Scharf, et al. found the self-represented party's brief contained 13 citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court ordered the self-represented party to show cause why sanctions, striking, or referral should not issue for the defective authorities.

Disposition
The court ordered the self-represented party to show cause why sanctions, striking, or referral should not issue for the defective authorities.
Recorded conduct
The self-represented party's brief contained 13 citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. — outcome: pending; 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.

Court.1 10. Lindner v. Countrywide Hom Loans, Inc., 447 F. Supp. 2d 999 (D. Minn. 2006) AI can be a powerful tool for pro se plaintiffs. However, the (Doc. No. 7). In her reply, Plaintiff cites two more fake cases Court cannot blindly ignore its risks, including the increased (Eaton v. Am. Bankers Life Assurance Co., 2020 U.S. Dist. LEXIS 150102 (W.D.N.C.), and Cox v. Chase Bank, N.A., likelihood of factual and legal hallucinations.2 2015 WL 13654749) and cites a real case for a proposition that the case does not support (Marash v. Morrill, 496 F.2d IT IS, THEREFORE, ORDERED that Plaintiff must show 1138 (2d Cir. 1974)). (Doc. Nos. 7, 9). cause as to why her complaint should not be dismissed with prejudice for failing to comply with this Court's Standing Plaintiff's AI generated pleading violates this Court's standing Order Regarding Use of Artificial Intelligence. Within 21 order and attempts to mislead the Court. The Court days of this Court's Order, Plaintiff shall (1) file a brief with understands that Plaintiff is proceeding pro se, but that does the Court explaining her fraudulent case citations, (2) file a not allow her to flaunt the Court's rules and haphazardly motion to amend her non-compliant pleadings, and (3) certify file pleadings without completing any due diligence. Even to the Court—in each motion or brief filed—that she has and a cursory Google search would reveal that these cases do will comply with this Court's Standing Order Regarding Use not exist. Furthermore, AI's limitations at this point are well- of Artificial Intelligence. Failure to do so will result in the documented, and its proclivity for hallucinating case citations dismissal of Plaintiff's complaint with prejudice. is broadly known. A pro se litigant doing the minimum due diligence would discover that fact. *3 Signed: February 24, 2026 The Court has been extremely lenient on pro se plaintiffs filing AI-generated pleadings in this Court and has generally 1 The Court notes that this is not Plaintiff's first warning with respect to these issues. See 3:25-cv-832, Doc. No. 10. Further, at least one other case reflects similar problems. See 3:25-cv-1008, Doc. No. 5. Plaintiff is forewarned that if she continues to file documents without the required AI certification or with AI hallucinations, then the Court may, without further warning, order that documents lacking in AI certification be returned to her without filing. Also, documents containing AI hallucinations (notwithstanding a certification) may be summarily stricken and not considered. 2 Pro se parties should also be aware that their “conversations” with AI tools such as ChatGPT are not privileged and may be subject to discovery. Government Works.

Authorities cited in the passage: s reply as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff · s response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff · Eaton v. Am. Bankers Life Assurance Co · Cox v. Chase Bank · Marash v. Morrill

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