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Courts on AI / Fabricated or misquoted citations

Rasheem Carter, et al. v. UZGlobal LLC, et al.

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

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
The court fined counsel $1,000 payable to the clerk, ordered bar reporting, required proof of AI CLE, and barred passing costs to clients.
Recorded conduct
Counsel filed a brief with four fabricated case citations. — outcome: 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.

On June 27, 2025, theCourtissued its first showcauseorder,identifying threeadditionalcases in theMarch 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) describetheactionsofeachattorneyinvolvedinthecreationofthebriefs; (3)describehowcounsel became aware of the non-existent cases; (4) identify any other filings that could contain nonexistent cases; and (5) show cause why counsel should not be sanctioned. Id. at 3. II. BRIEFING SUMMARY Plaintiffs identified sixteen total cases across the March response brief and two motions to compel that did not exist. [Doc.

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