Courts on AI / Fabricated or misquoted citations
Wallace v. PennyMac Loan Services, LLC
United States District Court for the District of Nevada · Federal district courts · NV · · 2026 WL 837418 · No. 2:25-cv-02297-APG-EJY · order
On 2026-03-26, U.S. District Court for the District of Nevada granted amendment in part, denied the motion to dismiss as moot, and warned that fake AI-drafted cases must be verified. A self-represented party submitted a complaint with false quotations and fabricated or nonexistent authorities.
- Disposition
- The court granted leave to amend in part, denied the motion to dismiss as moot, and warned Wallace to stop citing fake cases.
- Recorded conduct
- Wallace relied on fake cases in his response and at least one fake case in a later reply after being notified of the problem. — 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.
and as the result of using generative AI software, like ChatGPT, deny the motion to dismiss (ECF No. 6) as moot. to draft pleadings. Chavez-DeRemer v. NAB, LLC, No. 2:21- Wallace moves to amend and attaches a proposed second CV-00984-JAD-EJY, 2025 WL 2308676, at *3 (D. Nev. amended complaint. ECF No. 43-1. The defendants oppose, Aug. 11, 2025). Generative AI often invents fake cases and arguing amendment is futile and Wallace is repeatedly legal precedent in its drafting, and using it is no excuse for amending to prolong the proceedings and stave off not verifying the veracity of citations. See Whiting, 2026 foreclosure. WL 710568, at *4 (“Citing even a single fake case can be sanctionable because no brief, pleading, motion, or any *4 I must “freely give leave” to a plaintiff to amend his other paper filed in any court should contain any citations complaint “when justice so requires.” Fed. R. Civ. P. 15(a)(2). —whether provided by generative AI or any other source I am to apply this policy “with extreme liberality.” Eminence —that a lawyer [or pro se party] has not personally read Cap., LLC v. Aspeon, Inc.,