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Courts on AI / Fabricated or misquoted citations

Owens v. Select Portfolio Servicing, Inc.

United States District Court for the Eastern District of New York · Federal district courts · NY · · 2026 WL 1413883 · No. 14 · order

Fabricated or misquoted citationsGAI

On 2026-06-04, in Owens v. Select Portfolio Servicing, Inc, the Eastern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source and at least four nonexistent or hallucinated authorities.

Disposition
The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
A self-represented litigant submitted a filing using quotations that did not appear in the cited source and at least four nonexistent or hallucinated authorities. — 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.

The use of fake or misleading citations violates this rule and wastes the opposing party’s and the Court’s time by requiring them to parse through the citations to determine which points of law, if any, are accurate. See Perez v. Evans, 24-CV-356, 2025 WL 2726792, at *4 (S.D.N.Y. Sept. 25, 2025) (determining that a plaintiff’s use of “hallucinated” citations violated Rule 11). The plaintiff is warned that he must exercise caution in relying on AI software to draft court filings or to conduct legal research. The Court will impose sanctions for any further violations, including summary dismissal of his claims. SO ORDERED. ___________________________ ANN M. DONNELLY United States District Judge Dated: Brooklyn, New York June 4, 2026 s/Ann M.

Authorities cited in the passage: See Perez v. Evans, 24-CV-356, 2025 WL 2726792, at *4 (S.D.N.Y. Sept. 25, 2025) · Rule 11)

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