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Courts on AI / Fabricated or misquoted citations

Sana Hazina Butler v. Fidelity Management & Research Company LLC

United States District Court for the Southern District of New York · Federal district courts · NY · · No. 1:25-cv-09337-RA-RFT · 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. The self-represented party filed a pleading with one fabricated case citation, three false case quotations, and two mischaracterized case citations, including Inc. v. Neewra.

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 a pleading with one fabricated case citation, three false case quotations, and two mischaracterized case citations, including Inc. v. Neewra and Parisie v. Greer. — 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.

Y. 2008) exists, but it has nothing to do with removal, and none of the quoted language appears in the opinion; Whitaker v. Am. Telecasting, Inc. , 261 F. 3d 196 (2d Cir. 2001) exists and involves removal, but says nothing about whether a removed complaint may be filed as an exhibit to another document. due to Plaintiff’s use of generative AI tools. See, e. g. , Romero v. Goldman Sachs Bank USA, No. 25-CV-2857 (GHW), 2025 WL 1916119, at *1-2 (S. D. N. Y. June 25, 2025) (cautioning that “citations, quotations, and holdings that have been generated by generative artificial intelligence may be hallucinations”). But no matter what the cause, the “presentation of false citations, quotations, and holdings by a party .

Authorities cited in the passage: Whitaker v. Am. Telecasting · Romero v. Goldman Sachs Bank USA, No. 25-CV-2857 (GHW · Inc. v. Neewra, Inc. with quoted language the court determined does not appear in that opinion · Plaintiff cited Parisie v. Greer, which exists but the court noted it has nothing to do with removal (misstated re · Plaintiff cited Whitaker v. American Telecasting, which involves removal but does not support the specific proposition about filin · Plaintiff cited 'Rong Zhu v. BNP Paribas, 997 F. Supp. 2d 242 (S.D.N.Y. 2014)', which the court found does not exist · Plaintiff cited Azer v. Connell and included quoted language the court found does not appe

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