Skip to content

Courts on AI / Fabricated or misquoted citations

Edward C. Allen v. Western Governors University, et al.

U.S. District Court for the District of Nevada · Federal district courts · NV · · No. 2:25-cv-00325-RFB-NJK · order

On 2026-03-31, U.S. District Court for the District of Nevada dismissed the case with prejudice and imposed nominal monetary sanctions after finding fabricated authorities, factual misrepresentations, and bad faith. A self-represented party submitted a filing with false quotations and nonexistent or mischaracterized authorities, including Christian and Warren cases the court found did not contain the quoted language.

Disposition
The court dismissed the case with prejudice and imposed nominal monetary sanctions after finding fabricated authorities, factual misrepresentations, and bad faith.
Recorded conduct
The filing used false quotations and nonexistent or mischaracterized authorities, including Christian and Warren cases the court found did not contain the quoted language. — outcome: costs order; actor: litigant in person; $1
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.

were accurate or the result of benign typographical errors while simultaneously citing to additional misrepresented or fabricated authorities. The Court is left to assume that Mr. Allen either himself fabricated authorities and lied to the Court by claiming the inaccuracies were the result of typos or clerical errors, or enlisted the assistance of AI, which misrepresented and fabricated cases to support his assertions, failed to check their validity (even after being specifically instructed to do so), and then lied to the Court about their origins. Further, while Mr. Allen’s Response to the Court’s OSC asserted that he should be afforded lenience due to his status as a pro se litigant, the Court finds Mr. Allen is neither unsophisticated nor inexperienced in litigation even though he is proceeding pro se. Indeed, he purportedly has a juris doctorate degree, and claims he has “been in this business for eighteen years.” See Hr’g Tr. 3:8, Mar. 17, 2026, ECF No. 53. And even if that were not the case, “although courts make some allowances for a pro se [p]laintiff's failure to cite to proper legal authority, courts do not make allowances for a

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub