Courts on AI / Fabricated or misquoted citations

Wolkenstein v. Heinrich

United States District Court for the District of Nevada · Federal district courts · NV · 2026-04-06 · No. Case No. 2:25-cv-01138-APG-NJK · order

Fabricated or misquoted citations

On 2026-04-06, U.S. District Court for the District of Nevada granted default judgment in part, denied paralegal costs, and warned the plaintiffs that fake AI-drafted cases may lead to sanctions. A self-represented party submitted a motion with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities.

Disposition: The court granted default judgment in part, declined to award some requested costs, and warned the plaintiffs about Rule 11 and fake AI-drafted citations.
Recorded conduct: The plaintiffs’ default-judgment motion cited Stanley, Shum, and a purported Boilermaker Vacation Trust case for propositions the cited authorities did not support or, for the Boilermaker citation, that did not exist at the cited citation. — 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.

in briefs, usually as the result of using generative AI software, like ChatGPT, to draft court filings. Johnson v. MINI of Las Vegas, No. 2:25-cv-00725-APG-EJY, 2025 WL 2718525, at *3 (D. Nev. Sept. 24, 2025). Generative AI often invents fake cases and legal precedent, and using it is no excuse to not verify the veracity of citations. Having to research fake authority and spend time chasing down what is not a real case wastes the court’s time and resources. Going forward, the plaintiffs are warned of their duty under Rule 11(b)(2) and that citing fake cases drafted by generative AI may violate this rule. Failure to comply in the future may result in sanctions, such as an order to pay a penalty into the court, or nonmonetary directives. Fed. R. Civ. P. 11(c)(4). Despite these shortcomings, the plaintiffs’ motion satisfies the factors set forth in Eitel v. McCool, 782 F.2d 1470, 1471-72 (9th Cir. 1986). Default has been entered against the defendants. ECF No. 12. I thus find good cause to grant the motion in part. I decline to award the plaintiffs their paralegal costs because those are ordinarily not

Authorities cited in the passage: Fed. R. Civ. P. 11(c)(4)

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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