Courts on AI / Fabricated or misquoted citations
Terrance Anthony Norris v. JPMorgan Chase Bank N.A.
United States District Court for the Eastern District of New York · Federal district courts · NY · · No. 2:25-cv-03231-HG-JMW · order
The Eastern District of New York on 2026-05-06 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Terrance Anthony Norris v. JPMorgan Chase Bank N.A. The self-represented plaintiff filed an opposition with one fabricated case citation and two false case quotations, including Inc. v. Homestead Vill. Ltd. P’ship.
- Disposition
- The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
- Recorded conduct
- The self-represented plaintiff filed an opposition with one fabricated case citation and two false case quotations, including Inc. v. Homestead Vill. Ltd. P’ship and Diesel Props S.r.l. v. Greystone Bus. Credit II LLC. — 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.
Applewhite v. N. Y. C. Dep’t of Educ. , No. 24-cv-2131, 2025 WL 783650 (2d Cir. Mar. 12, 2025). Plaintiff is therefore denied a further opportunity to amend. III. Warning About Fake Quotes and Citations Defendant brings to the Court’s attention that Plaintiff’s Opposition includes citations to a nonexistent case, GAI Consultants, Inc. v. Homestead Vill. Ltd. P’ship, 961 F. Supp. 1437, 1445 (E. D. Pa. 1997), see Opp. at 16, and nonexistent quotations in several other cases. 7 See Reply at 9–10. 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.
Authorities cited in the passage: Applewhite v. N. Y. C. Dep’t of Educ. , No. 24-cv-2131, 2025 WL 783650 (2d Cir · Inc. v. Homestead Vill. Ltd. P’ship, 961 F · Inc. v. Homestead Vill. Ltd. P’ship, 961 F. Supp. 1437 (E.D. Pa. 1997) · Plaintiff attributes a quotation to Diesel Props S.r.l. v. Greystone Bus. Credit II LLC, 631 F.3d 42 (2d Cir. 2011) that does not appear in that opinion · Plaintiff attributes a quotation to Dalton v. Educ. Testing Serv., 87 N.Y.2d 384, 394 (1995) that does not exist in that opinion