Courts on AI / Fabricated or misquoted citations
Lawand Hill v. Sloppy Vinyl, LLC, et al.
United States District Court for the District of New Jersey · Federal district courts · NJ · · No. Case 2:25-cv-15238-BRM-AME · memorandum opinion
District of New Jersey on 2026-03-05 found the self-represented party's motion contained three citation defects, including Duff v. Trenton Beverage Co and Jordan v. Fox, involving fabricated or misattributed quotations, incorrect statutory or rule text. The court granted defendants' motion to dismiss, dismissed the complaint without prejudice, and reminded the plaintiff that false authorities may draw Rule 11 sanctions.
- Disposition
- The court granted defendants' motion to dismiss, dismissed the complaint without prejudice, and reminded the plaintiff that false authorities may draw Rule 11 sanctions.
- Recorded conduct
- The self-represented party's motion contained three citation defects, including Duff v. Trenton Beverage Co and Jordan v. Fox, involving fabricated or misattributed quotations, incorrect statutory or rule text. — outcome: dismissal; 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.
now or heretofore owing or accrued. (Settlement Agreement ¶ 2.) To the extent Plaintiff used artificial intelligence in drafting her papers, the Court reminds Plaintiff “[w]hile courts afford pro se litigants considerable leeway, that leeway does not relieve pro se litigants of their obligation under Rule 11 to confirm the validity of any cited legal authority.” Robinson v. Oglala Sioux Tribe, Civ. A. No. 25-289, 2025 WL 2609573, at *4 (W.D. Okla. Sept. 9, 2025) (quoting Sanders v. United States, 176 Fed. Cl. 163, 169 (2025)); see also DeAngelo v. Freedom Mortg., Civ. A. No. 25-cv-13099, 2025 WL 4275514, at *3 n.4 (D.N.J. Nov. 12, 2025) (“Plaintiff is reminded that her pro se status does not shield her from sanctions under Federal Rule of Civil Procedure 11, which provides that any pleading, written motion or other paper submitted to the court must certify to the best of that person's knowledge, information and belief and formed after an inquiry reasonable under the circumstances that it is not being presented for an improper purpose, such as to harass, and that the claims and legal contentions are warranted by existing law or by a nonfrivolous argument that existing law should [not] apply.”). Therefore, in any future filings with the Court, Plaintiff is directed to read the cases she cites with greater care to ensure she is not only citing real cases but also accurately characterizing what those cases say.
Authorities cited in the passage: never becomes binding · may not consider matters extraneous to the pleadings · Robinson v. Oglala Sioux Tribe · Sanders v. United States · DeAngelo v. Freedom Mortg · Rule 11