Courts on AI / Fabricated or misquoted citations
Shaquan Pridgen v. Amazon.com Services LLC
United States District Court for the District of New Jersey · Federal district courts · NJ · · 2026 WL 735250 · No. No. 25cv7589 (EP) (JRA) · memorandum opinion
District of New Jersey on 2026-03-16 in Shaquan Pridgen v. Amazon.com Services LLC found the self-represented party's opposition cited Lewis v. City of Trenton, 2020 WL 6204330, a case the court found did not exist. The court warned the self-represented party to disclose AI use when required and to verify future citations.
- Disposition
- The court warned the self-represented party to disclose AI use when required and to verify future citations.
- Recorded conduct
- The self-represented party's opposition cited Lewis v. City of Trenton, 2020 WL 6204330, a case the court found did not exist. — 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.
12 Pridgen nevertheless argues that “[c]ourts routinely permit pro se plaintiffs to plead class claims ....” MTD Opp'n at 7. Pridgen cites “Lewis v. City of Trenton, 2020 WL 6204330” for this proposition. Id. The case Pridgen cites, however, does not exist. This Court does not tolerate hallucinated citations. Litigants who use generative artificial intelligence must disclose such use to this Court and litigants must review the filings for accuracy. See Section I.B of the Undersigned's Judicial Preferences. This Court warns Pridgen that if future filings include hallucinated citations, this Court will strike those filings and they will not be considered. Pridgen may also be subject to other sanctions. Pridgen's citation to non-existent authority bolsters the Court's conclusion that Pridgen could not adequately represent the interests of other litigants. 13 The Court reiterates that although Amazon does not contest the existence of any EEOC notice to sue, Pridgen did not attach one to his Complaint or MTD Opposition and the Court cannot determine which charge of discrimination was exhausted, if either.
Authorities cited in the passage: Lewis v. City of Trenton, 2020 WL 6204330