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Courts on AI / Fabricated or misquoted citations

Sample et al v. Hilton Worldwide Holdings, Inc

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

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 warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
A self-represented litigant filed a response using quotations that did not appear in the cited source. — 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)

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