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. 25-CV-03231 (HG) · memorandum opinion
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 motion to dismiss was granted, the second amended complaint was dismissed without prejudice, and Norris was warned about nonexistent authorities.
- Recorded conduct
- Norris’s pro se opposition cited a nonexistent GAI Consultants case and fake quotations from Diesel and Dalton. The court warned him, but the dismissal rested on jurisdiction and pleading defects. — 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
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