Courts on AI / Fabricated or misquoted citations

Kelly v. Financial Industry Regulatory Authority

United States District Court for the District of Nevada · Federal district courts · NV · 2026-08-19 · No. 2:25-cv-01195-APG-DJA · order

Fabricated or misquoted citations Self-represented litigants using AI

The District of Nevada dismisses William Lee Kelly’s second amended complaint against FINRA and warns him about AI-generated fake authority. The court finds several false quotes and nonexistent citations in his opposition and explains that future Rule 11 violations may lead to monetary or nonmonetary sanctions.

Disposition: The court dismissed the second amended complaint and warned Kelly that citing fake cases generated by AI can lead to sanctions.
Recorded conduct: Self-represented plaintiff’s opposition contained several nonexistent case citations and false quotations that did not appear in the cited cases. — 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.

FINRA states that Kelly’s opposition to its motion to dismiss contains several nonexistent case citations and quotations that do not appear in Kelly’s cited caselaw. I reviewed the citations in the first few pages of Kelly’s opposition and found several quotes that did not appear in the cited cases. These false quotes appear on page 2, lines 11-12; page 3, lines 3-4; and page 9, line 20 to page 10, line 5 of Kelly’s opposition. ... There has been a rise in fake authority cited in briefs, usually as the result of using generative AI software, like ChatGPT, to draft pleadings. Chavez-DeRemer v. NAB, LLC, No. 2:21-CV-00984-JAD-EJY, 2025 WL 2308676, at *3 (D. Nev. Aug. 11, 2025). Generative AI often invents fake cases and legal precedent in its drafting, and using it is no excuse for not verifying the veracity of citations. ... Going forward, Kelly is reminded of his duty under Federal Rule of Civil Procedure 11(b)(2) and that citing fake cases drafted by generative AI violates this rule. Failure to comply in the future may result in sanctions.

Authorities cited in the passage: Fed. R. Civ. P. 11 · Golden Eagle Distributing Corp. v. Burroughs Corp., 801 F.2d 1531 (9th Cir. 1986) · Whiting v. City of Athens, Tenn., 170 F.4th 455 (6th Cir. 2026) · Chavez-DeRemer v. NAB, LLC, 2025 WL 2308676 (D. Nev. Aug. 11, 2025)

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.

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