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Courts on AI / Fabricated or misquoted citations

Kurelko v. Ballard

United States District Court for the District of New Jersey · Federal district courts · NJ · · No. 3:25-cv-11917-ZNQ-JBD · order

The District of New Jersey denies Kurelko’s motions to disqualify state counsel and notes his first motion contained inaccurate or nonexistent case citations and quotations. The court declines sanctions at that time, admonishes the self-represented plaintiff, and warns that similar conduct may bring monetary penalties.

Disposition
The court denied Kurelko's motions to disqualify the New Jersey Office of the Attorney General.
Recorded conduct
Self-represented plaintiff filed a disqualification motion with inaccurate or nonexistent case citations and quotations. — 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.

Plaintiff’s first motion to disqualify contains several inaccurate or non-existent case citations and quotations. See [Dkt. 15.] “‘[I]t is improper and unacceptable for litigants—including pro se litigants—to submit ‘non-existent judicial opinions with fake quotes and citations.’” Fagan v. Barnhiser, Civ. No. 24-06012 (CCC), 2025 WL 2654994, at *2 (D.N.J. Sept. 17, 2025) (quoting Anonymous v. New York City Dep’t of Educ., Civ. No. 24-4232, 2024 WL 3460049, at *7 (S.D.N.Y. July 18, 2024) (further citations omitted)). “While some Courts have opted to sanction pro se litigants for this conduct, others have chosen to warn, rather than sanction, in these situations.” Id. (citation omitted). At this time, the Court will not impose sanctions. But plaintiff is now on notice: The Court “admonishes [p]laintiff for his improper conduct and warns that he will be subject to sanctions, including monetary penalties, should he [engage in similar conduct] again in the future.” Id.

Authorities cited in the passage: Fagan v. Barnhiser, Civ. No. 24-06012 (CCC), 2025 WL 2654994 (D.N.J. Sept. 17, 2025) · Anonymous v. New York City Dep’t of Educ., Civ. No. 24-4232, 2024 WL 3460049 (S.D.N.Y. July 18, 2024)

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