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Courts on AI / Fabricated or misquoted citations

In re Nicholia Cherry-Crockette

United States Bankruptcy Court for the District of New Jersey · Federal bankruptcy courts · NJ · · No. 25-21600 · order

On 2026-05-20, in In re Nicholia Cherry-Crockette, the District of New Jersey Bankruptcy Court denied the sanctions motion and rejected authorities that were nonexistent or did not support the debtor's position. A self-represented litigant filed a motion using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Disposition
The bankruptcy court denied the requested sanctions while addressing the AI-generated phantom authority issue.
Recorded conduct
The self-represented debtor relied on nonexistent or unsupported legal authority, including a phantom case the court described as generated by AI. The court denied the sanctions request in this document. — outcome: noted, no consequence; 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.

...tween debtors and creditors outside of the bankruptcy case. Here, the Debtor cites the case of In re Diamond, 346 B.R. 51 (Bankr. S.D.N.Y. 2006). That citation is incorrect, and the Court was unable to find the case using the name, date, or any other identifying information, leading the Court to conclude that this is likely a phantom case generated by AI. Another nonexistent citation by the Debtor is to In re Lisenby, 374 B.R. 271 (Bankr. M.D. Ala. 2007). Upon further research, the Court found a similar case: In re Lisenby, 2006 WL 802392 (Bankr. M.D. Ala. Feb. 22, 2006), which involved a request for default judgment on a willful violation of the automatic stay and a violation of the Fair Debt Collection Practices Act. Assuming that was the case the Debtor intended to cite, it is still unhelpful because that case did not, as the Debtor suggests, hold...

Authorities cited in the passage: Sears Roebuck & Co. v. Epperson

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