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 Denying Motions · 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
- The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
- Recorded conduct
- The self-represented plaintiff filed a brief with one false case quotation, one mischaracterized case citation, and one fabricated factual or other assertion. — 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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