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Courts on AI / Fabricated or misquoted citations

Wayne K. Smith, Sr. v. Polk County, et al.

United States District Court for the Western District of North Carolina · Federal district courts · NC · · No. 1:24-cv-00037-MR-WCM · order

On 2026-06-03, in Wayne K. Smith, Sr. v. Polk County, et al, the Western District of North Carolina ordered plaintiff's counsel to show cause about two fabricated quotations and compliance with the court's AI-use standing order. Counsel filed an opening brief using quotations that did not appear in the cited source.

Disposition
The court ordered plaintiff's counsel to show cause about two fabricated quotations and compliance with the court's AI-use standing order.
Recorded conduct
Counsel filed an opening brief using quotations that did not appear in the cited source. — outcome: pending; actor: lawyer
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.

Artificial Intelligence The Defendants contend that the Plaintiff’s memorandum in support of the instant motion contains two fabricated quotations, along with multiple quoted statements lacking citation to any authority, and that such deficiencies suggest that the memorandum was drafted using artificial The Plaintiff complains that the Defendants tookthe “position” throughout discovery “that neither the vehicular pursuit nor policies are at issue in this case.” [Doc. 63 at 4]. The Court notes, however, that neither the vehicular pursuit nor the county’s policies are, in fact, at issue in this case. The Plaintiff’s counsel has also failed to show proper conferral or attempt to confer regarding one motion to compel and two motions for sanctions that are currently pending in this matter. LCvR 7.1(b); see generally [Docs. 46, 61, 68]. intelligence and without adequate human verification. [Doc. 60 at 2, 4 n.1, 9 n.3, 14 n.4]. The Defendants further note that the Plaintiff did not file the required certification regarding use of artificial intelligence with the memorandum, in violation of the Court’s Standing Order Regarding the Use of Artificial Intelligence, No. 3:24-mc-00104-MR (W.D.N.C.

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