Courts on AI / Fabricated or misquoted citations

Pridgen v. Amazon.com Services LLC

United States District Court for the District of New Jersey · Federal district courts · NJ · 2026-03-16 · 2026 WL 735250 · No. 25cv7589 (EP) (JRA) · opinion

Fabricated or misquoted citations

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 granted Amazon's motion to dismiss in part, denied preliminary injunctive relief, and warned Pridgen that future hallucinated citations will be struck and may draw sanctions.
Recorded conduct: Pridgen cited Lewis v. City of Trenton, 2020 WL 6204330 for the proposition that pro se plaintiffs may plead class claims; the case does 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

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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