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Courts on AI / Fabricated or misquoted citations

Seeto v. Kendall

United States District Court for the District of Nevada · Federal district courts · NV · · No. 2:25-cv-00038-JAD-EJY · order

The District of Nevada on 2026-05-05 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Seeto v. Kendall. The self-represented plaintiff filed a brief with one false case quotation, one mischaracterized case citation, and one fabricated factual or other assertion, including Withrow v. Larkin.

Disposition
Summary judgment and reconsideration were denied, and Seeto was warned that repeated violations may lead to sanctions or dismissal.
Recorded conduct
Seeto’s pro se briefs contained unsupported case quotations and propositions that the court attributed to possible AI research or drafting. The court warned that repeated violations may invite sanctions or dismissal. — 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.

ECF No. 50 at 4. While AI tools can be useful, and this court does not prohibit litigants from using them, those services pull information from across the web—including from unreliable sources—and they often hallucinate (or make up fake) legal authority. Using AI to supply legal authority for briefs an unrepresented litigant or attorney signs any filing before this court, he certifies that “the claims, defenses, and other legal contentions are warranted by existing law. ”35 Parties must verify that the authorities they mention are accurate before presenting them to a court. Repeated violations of this sort may invite sanctions—including case dismissal. Conclusion IT IS THEREFORE ORDERED that plaintiff Ryne Seeto’s motion for summary judgment [ECF No.

Authorities cited in the passage: Withrow v. Larkin, but the court found that language does not appear in Withrow · Plaintiff cited Bittinger v. Tecumseh Products Co. for the proposition that voluntary engagemen

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