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Courts on AI / Fabricated or misquoted citations

Jeri'yah Ford v. Troy City School District, et al.

United States District Court for the Northern District of New York · Federal district courts · NY · · No. Case 1:25-cv-00364-AMN-DJS · memorandum opinion

Northern District of New York on 2026-03-04 in Jeri'yah Ford v. Troy City School District, et al. found counsel's response contained two citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

Disposition
The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
Recorded conduct
Counsel's response contained two citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. — outcome: pending; actor: lawyer
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.

rely. Indeed, we can think of no other way to ensure that the arguments made based on those authorities are “warranted by existing law,” Fed. R. Civ. P. 11(b)(2), or otherwise “legally tenable.” Cooter & Gell, 496 U.S. at 393[ ]. As a District Judge of this Circuit recently held when presented with non-existent precedent generated by ChatGPT: “A fake opinion is not ‘existing law’ and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law. An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” Mata v. Avianca, Inc., [678 F. Supp. 3d 443, 461 (S.D.N.Y. 2023)]. Park, 91 F.4th at 615 (additional citation omitted). A court may “initiate sanctions sua sponte by issuing an order ‘to show cause why conduct specifically described in the order has not violated Rule 11(b).’” Kyros Law, 78 F.4th at 543 (quoting Fed. R. Civ. P. 11(c)(3)). As such, Mr. Mills is hereby ordered to show cause, in writing by March 20, 2026, why he should not be sanctioned pursuant to Rule 11(b) for including and relying on fabricated caselaw in the Response. Dkt. No. 20 at ¶¶ 62-63. Mr. Mills is directed to address whether he used artificial intelligence in drafting the Response and what steps he took to confirm the existence and validity of the caselaw. V. CONCLUSION

Authorities cited in the passage: Mata v. Avianca · Fed. R. Civ. P. 11(b)(2) · Fed. R. Civ. P. 11(c)(3) · Rule 11(b)

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