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 · 2026-06-04 · No. 25-CV-0622 · memorandum opinion

Fabricated or misquoted citations

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 dismissed all claims except one FDCPA claim and warned plaintiff that further fake or misleading citations would lead to sanctions, including possible summary dismissal.
Recorded conduct: The pro se plaintiff cited at least four cases that did not include the quoted language or support the propositions asserted, and two citations were not to decisions. The court warned that further fake or misleading citations would draw sanctions. — 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)

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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