Courts on AI / Fabricated or misquoted citations
Jason Wimberly v. Verizon New York Inc.
United States District Court for the Southern District of New York · Federal district courts · NY · · No. 1:26-cv-02341-LTS · order
On 2026-06-12, in Jason Wimberly v. Verizon New York Inc, the Southern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a reply brief using nonexistent or hallucinated authorities.
- 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 filed a reply brief using nonexistent or hallucinated authorities. — 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.
Courts have previously observed that a citation to a nonexistent case suggests that Plaintiff may have used a form of generative artificial intelligence (“genAI”) to draft submissions to the Court and that genAI hallucinated the phantom case citation. See Park v. Kim, 91 F.4th 610, 614 (2d Cir. 2024) (discussing case cited in a reply brief that the Second Circuit was unable to locate and attorney’s admission that the case was provided by ChatGPT). The Court reminds and warns Plaintiff that all litigants are subject to Rule 11(b)(2) of the Federal Rules of Civil Procedure, which provides, in relevant part, that “[b]y presenting to the court a . . . motion . . . an attorney or unrepresented party certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . the claims, defenses, and other legal contentions are warranted by existing law. . .
Authorities cited in the passage: See Park v. Kim, 91 F · Rule 11(b)(2)
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