Courts on AI / Fabricated or misquoted citations
Reyes v. Bailey
United States District Court for the District of New Mexico · Federal district courts · NM · · No. 2:24-cv-00831-KG-KRS · memorandum opinion
The District of New Mexico denies self-represented plaintiff Charles Reyes’s Rule 11 motion. The court holds defendants reasonably said Reyes may have fabricated a case citation because Reyes admitted he miscited a case in his amended complaint, and the remaining alleged misrepresentations did not support sanctions.
- Disposition
- The court denied Reyes's motion for sanctions and denied a motion to strike as moot.
- Recorded conduct
- Self-represented plaintiff admitted misciting a case; defendants characterized the citation as possibly fabricated, and the court found that characterization reasonable. — outcome: other; 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.
Mr. Reyes appears to argue that Defendants have violated Rule 11 by “misrepresenting the record and the law.” Doc. 61 at 2. He contends that Defendants: (1) misrepresented that he hallucinated a case citation in his pleadings; (2) “failed to comply with 28 U.S.C. § 1446(a) by omitting critical state-court filings from the Notice of Removal”; (3) moved to quash the summons issued for improper service based on false factual assertions; (4) asserted an affirmative defense unsupported by existing law; and (5) failed to specifically controvert his statement of undisputed facts in their response to his motions for summary judgment, as required by Federal Rule of Civil Procedure 56. ... The Court rejects Mr. Reyes’s arguments and denies the motion. First, Mr. Reyes admits that he miscited a case in his Amended Complaint. See Doc. 65. Thus, Defendants’ contention that Mr. Reyes may have fabricated a case was reasonable.
Authorities cited in the passage: Fed. R. Civ. P. 11 · 28 U.S.C. § 1446(a) · Fed. R. Civ. P. 56
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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