Courts on AI / Fabricated or misquoted citations

Sims v. Souily-Lefave

United States District Court for the District of Nevada · Federal district courts · NV · 2026-04-07 · 2026 WL 948233 · No. Case No. 2:24-cv-00831-CDS-EJY · order

Fabricated or misquoted citations Discovery and AI-assisted review

On 2026-04-07, U.S. District Court for the District of Nevada denied the discovery motions and warned the plaintiff that unchecked AI-generated or unsupported citations could expose her to Rule 11 sanctions. A self-represented party submitted a motion with The motion cited fabricated or mischaracterized discovery cases, including Cruz and DuPont authorities, for propositions the cases did not support.

Disposition: The court resolved several discovery motions, held defendants’ sanctions request in abeyance, ordered Sims to appear for deposition, and cautioned her about checking case citations.
Recorded conduct: Sims’s pro se filings cited Cruz v. Fox and Barrow v. Greenville Independent School District for discovery-prematurity propositions, but the cited reporters corresponded to Green, Tweed and Pioneer Drive decisions that did not support the asserted propositions; a Seattle Times citation also did not discuss discovery sequencing. — 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.

is not an Motion; however, the Court finds such efforts would be futile attorney, offers arguments not germane to the issue of her and, thus, this failure is not a basis to deny Plaintiff's Motion. refusal to proceed with answering questions at her deposition, It is true that Defendants had previously filed a Motion to and contends defense counsel improperly made threats of Compel; however, Defendants offer no law supporting their sanctions (id. at 8-9), which the Court warned Plaintiff could contention that Plaintiff cannot file a motion for protective be sought if her deposition did not proceed. ECF No. 172 at order in response to a motion to compel. Plaintiff's Reply 13-14. (ECF No. 184) is off point (discussing defense counsel's pro hac vice filing, contending her Motion for Protective Plaintiff cites case law that must be AI generated. See EFC Order was “administrative,” and discussing the importance of No. 175 at 10 and compare Plaintiff's citations to (1) Cruz protective orders). ECF No. 184 at 3, 4, 6-8. To the extent v. Fox, 202 F.R.D. 419, 423 (N.D. Ill 2001) (allegedly Plaintiff contends she adequately met and conferred

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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