Courts on AI / Fabricated or misquoted citations
Polanco v. Himalayan Real Estate LLC, et al.
United States District Court for the Eastern District of New York · Federal district courts · NY · · No. 1:25-cv-06939-HG-JAM · order
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 warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
- Recorded conduct
- A self-represented litigant cited Moore v. Alliance Credit Union even though the court found the authority did not exist. — 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
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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