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Courts on AI / Fabricated or misquoted citations

Rasheem Carter v. UZGlobal LLC

United States District Court for the District of New Mexico · Federal district courts · NM · · No. 1:23-cv-01013-MV-JHR · order

Fabricated or misquoted citations

The District of New Mexico on 2026-05-01 fined counsel $1,000 payable to the clerk, ordered bar reporting, required proof of AI CLE, and barred passing costs to clients in Rasheem Carter, et al. v. UZGlobal LLC, et al. Counsel filed a brief with four fabricated case citations.

Disposition
Counsel was fined $1,000, ordered to self-report to disciplinary authorities, complete AI CLE, and face possible fee motions.
Recorded conduct
Counsel Scherr conceded that sixteen fake cases across a response and two motions to compel were likely hallucinated by AI. The court ordered self-reporting to Texas and New Mexico disciplinary authorities and imposed a $1,000 fine. — outcome: regulatory referral; actor: lawyer; $1,000
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.

...ed these motions as well. Then, on June 12, 2025, Plaintiffs withdrew all three and the parties requested a status conference with the Court. [Doc. 95]. On June 20, 2025, the parties alerted the Court that Plaintiffs’ March response brief and motions to compel could contain fake cases. [Doc. 98 text only]. The parties believed these cases may have been “hallucinated” by an artificial intelligence (“AI”) drafting program. Id. On June 27, 2025, the Court issued its first show cause order, identifying three additional cases in the March response brief that it could not locate. [Doc. 101, at 2]. The Court ordered Plaintiffs to (1) produce PDF versions of every case cited in the March response brief and three motions to compel; (2) describe the actions of each attorney involved in the creation of the briefs; (3) describe how counsel became aware of the non-existen...

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