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Courts on AI / Fabricated or misquoted citations

Neri v. Board of Education for Albuquerque Public Schools

United States District Court for the District of New Mexico · Federal district courts · NM · · No. 1:19-cv-00008-JCH-SCY · memorandum opinion

Fabricated or misquoted citations

The District of New Mexico on 2026-05-07 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Neri v. Board of Education for Albuquerque Public Schools. The self-represented plaintiff filed a submission with one fabricated case citation and one fabricated or AI-like submission item, including United States v. Stone.

Disposition
The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct
The self-represented plaintiff filed a submission with one fabricated case citation and one fabricated or AI-like submission item, including United States v. Stone and Hall v. Western Production Co after using Centient AI. — 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.

262 at 1 (citing “United States v. Stone, 988 F. 2d 1056, 1061 (10th Cir. 1993). ”). The Court assumes Neri either erroneously combined a case name and legal citation or carelessly relied on an artificial intelligence program to craft this citation. 1 If this reference was indeed the product of artificial intelligence, then the Court issues a warning to Neri: courts “make some allowances for Upon review, the legal citation corresponds to Hall v. Western Production Co. , 988 F. 2d 1050 (10th Cir. 1993). the pro se plaintiff’s failure to cite proper legal authority,” but courts ordinarily do not coddle a plaintiff who cites to fake, nonexistent, or misleading authorities. Fomby v.

Authorities cited in the passage: United States v. Stone, 988 F · Hall v. Western Production Co. , 988 F · Tenth Circuit case 'United States v. Stone, 988 F.2d 1056, 1061 (10th Cir. 1993)' · Hall v. Western Production Co., 988 F.2d 1050 (10th Cir. 1993)

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub