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Courts on AI / Fabricated or misquoted citations

Fecteau v. Safety National Casualty Corporation

U.S. District Court for the Southern District of New York · Federal district courts · NY · · No. 25-CV-3821 · opinion

On 2026-03-25, U.S. District Court for the Southern District of New York imposed Rule 11 sanctions for repeated arguments that included fictitious statutory language and false legal support. A self-represented party submitted a complaint with one nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Conroy v. Aniskoff.

Disposition
The court imposed Rule 11 sanctions for repeated arguments that included fictitious statutory language and false legal support.
Recorded conduct
The complaint used one nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Conroy v. Aniskoff, which the court found nonexistent, misquoted, or unsupported. — outcome: other; 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.

National also requests sanctions on several different bases that essentially boil down to the following: Plaintiff has repeatedly made, without complying with the Court’s Individual Rules, seriatim filings that assert the same meritless arguments. (Dkt. No. 94 at 24– 27.) He persisted in doing so even after Safety National directed him to binding authority that foreclosed his arguments. (Id.) Several of these filings involve fabricated quotes and, in one case, statutory language that simply does not exist (as described above). (Id. at 15, 25–26.) In some of these filings, Safety National says, Plaintiff continued to make baseless representations in his filings as to the Defendants’ corporate citizenship. (Id. at 25–26.) Plaintiff has, indeed, filed an excessive number of repetitive motions without authorization. By the Court’s assessment, each of his primary arguments in favor of remand was raised in at least two Motions, as laid out further in footnotes.34 Many of these Motions were on “the intent of the potentially sanctionable conduct, not on its effect”). Plaintiff’s withdrawal of the direct claims further supports the conclusion that the filing of the Amended Complaint and Complaint alleging direct claims are not worth

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