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Courts on AI / Fabricated or misquoted citations

Mercy Wellington v. City of New York

United States District Court for the Southern District of New York · Federal district courts · NY · · No. 1:24-cv-08743-JLR · opinion

The Southern District of New York on 2026-04-30 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Mercy Wellington v. City of New York. The self-represented party filed an opposition with one fabricated case citation.

Disposition
The court warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct
The self-represented party filed an opposition with one fabricated case citation. — 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.

Nonexistent Legal Authority Before this Court begins its analysis, it must address Wellington’s pervasive citations to non-existent authority in her briefing. This is unacceptable. Defendants point out that Wellington’s initial opposition brief contains six “purported authorities that, on information and belief, do not appear in any legal database. ” Reply at 1-2. The Court was likewise unable to locate these authorities, which seem to be cases that were “hallucinated” using an artificial intelligence tool. “Without question, it is improper and unacceptable for litigants — including pro se litigants — to submit ‘non-existent judicial opinions with fake quotes and citations. ’” Anonymous v. New York City Dep’t of Educ. , No. 24- cv-04232 (JLR), 2024 WL 3460049, at *7 (S.

Authorities cited in the passage: Anonymous v. New York City Dep’t of Educ. , No. 24- cv-04232 (JLR

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