Courts on AI / Fabricated or misquoted citations

Bhagat v. Shah

United States District Court for the Southern District of New York · Federal district courts · NY · 2026-04-06 · No. 24-CV-1424 (VEC) (RFT) · order

Fabricated or misquoted citations

On 2026-04-06, U.S. District Court for the Southern District of New York admonished the self-represented defendant to verify that cited cases exist and support the propositions asserted in future AI-assisted filings. A self-represented party submitted a motion with false quotations and fabricated or nonexistent authorities, including In re SunEdison, Inc. Sec. Litig.

Disposition: The court denied plaintiff’s grievance-referral request, discharged an order to show cause, granted defendant’s expert-fee motion, denied other motions, unsealed an exhibit, and admonished defendant about the hallucinated citation.
Recorded conduct: Defendant cited In re SunEdison Sec. Litig. for a quotation about disclosure of corporate documents; the court found the quote in neither the cited SDNY case nor any Westlaw case and concluded it was an AI-generated hallucination. — 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.

motion to dismiss for failure to state a claim. Nor was I able to locate the quoted text in any case available on Westlaw. I therefore conclude that the citation is an AI-generated hallucination. I understand the difficulties of litigating pro se and the reasons why a pro se litigant might choose to use AI- generated filings. However, Defendant is admonished that pro se litigants are obligated to review the cases cited in their filings to confirm that they exist and stand for the proposition for which they are cited. 7. I issued an order (ECF 656) directing Plaintiff to refile his Exhibit 1 attached to ECF 652, which was to be a redacted version of the document at ECF 644-2. However, upon further examination of the voluminous docket, it appears that an unredacted version of the document is already on the docket and has been on the docket at ECF 572-32 since November 14, 2025. Nor did Plaintiff ever make an application to have ECF 572-32 sealed in the nearly five months it has been on the docket. Accordingly, the document at ECF 644-2 shall be unsealed. See Gambale

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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