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Courts on AI / Fabricated or misquoted citations

Polanco v. Himalayan Real Estate LLC

United States District Court for the Eastern District of New York · Federal district courts · NY · · No. 25-CV-6939 · order

Fabricated or misquoted citationscourt does not name AI

On 2026-05-27, in Polanco v. Himalayan Real Estate LLC, et al, 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 cited Moore v. Alliance Credit Union even though the court found the authority did not exist.

Disposition
The court dismissed some claims without prejudice and some with prejudice, denied leave to amend in part, and warned plaintiff that future non-existent authority may result in sanctions.
Recorded conduct
The pro se plaintiff cited fictitious Moore v. Alliance Credit Union for a mortgage-loan proposition. The court warned that future reliance on non-existent authority may lead to sanctions, filing restrictions, monetary penalties, 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.

Warning About Fake Citations Plaintiff cites a fictitious case, “Moore v. Alliance Credit Union,” which he falsely claims was decided by the United States Supreme Court on January 14, 2025, and “addressed the legality of mortgage loans based on fiat currency and its implications on constitutional rights.” ECF No. 1 at 4. He claims, falsely, that the Supreme Court held that “foreclosure proceedings based on a mortgage loan derived from fiat currency were deemed to violate Zachary Moore’s constitutional rights under the Fifth, Thirteenth, and Fourteenth Amendments.” Id. The Second Circuit has explained that a party’s attempt to persuade a court or oppose an adversary by relying on non-existent precedent “is an abuse of the adversary system.” Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024); see also Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 461 (S.D.N.Y.

Authorities cited in the passage: Moore v. Alliance Credit Union · Park v. Kim, 91 F · Mata v. Avianca

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