Courts on AI / Fabricated or misquoted citations

Sample v. Hilton Worldwide Holdings, Inc.

United States District Court for the District of New Mexico · Federal district courts · NM · 2026-05-26 · No. 1:23-cv-00865 · order

Fabricated or misquoted citationscourt does not name AI

On 2026-05-26, in Sample et al v. Hilton Worldwide Holdings, Inc, the District of New Mexico warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a response using quotations that did not appear in the cited source.

Disposition: The court overruled plaintiffs’ Rule 72 objection, declined sanctions, and warned plaintiffs that future nonexistent citations could lead to sanctions.
Recorded conduct: The pro se plaintiffs cited Hernandez for an unrelated matter and cited a Gonzales database identifier not attached to an existing case; the quoted language did not appear in the case the court found. The court declined sanctions but warned them. — 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.

None of these grounds identifies a part of Although courts make some allowances for a pro se plaintiff's failure to cite to proper legal authority, courts do not excuse the use of fabricated or misleading authorities. Morgan v. Cmty. Against Violence, No. 23-cv-353-WPJ/JMR, 2023 WL 6976510, *7 (D.N.M. Oct. 23, 2023). Plaintiffs are cautioned that they must comply with this Court’s Local Rules, the Court’s Guidefor Pro Se Litigants, andthe Federal Rules of Civil Procedure. Any futurefilings thatcontain citations to nonexistent cases may result in sanctions, including the filing being stricken, filing restrictions being imposed, or dismissal of the case. See id at *8 (collecting cases where sanctions were deemed appropriate). Judge Sweazea’s November 19, 2025 Order that Plaintiffs seek to set aside, much less anything “clearly erroneous or contrary to law.” For at least the following reasons, Plaintiffs’ objection is denied. First, Judge Sweazea has not yet ruled on Plaintiffs’ requested accommodations. Judge Sweazea’s November 19, 2025 Order struck the Motion for Reasonable ADA Accommodation, but as the parties appear to agree, the relief requested in the Motion for Reasonable ADA Accommodation is not new. See Doc.

Authorities cited in the passage: Morgan v. Cmty. Against Violence, No. 23-cv-353-WPJ/JMR, 2023 WL 6976510, *7 (D.N.M. Oct. 23, 2023)

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

United States court documents are public domain; the topic coding, disposition line and summary are SafeLegalAI's reading of the document for comparison, not a finding about any person named in it. This record summarises a public court document or official publication and reports what it says; SafeLegalAI makes no findings of its own. Individuals and organisations are named only as they appear in that public record. Anyone named may send a right of reply, correction or contextual update (for example an appeal, vacatur or later disposition) via /report; we add a dated note where appropriate. Reply or correct this record.

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub