Courts on AI / Fabricated or misquoted citations

Kassaw v. Wal-Mart Corporation

United States District Court for the Western District of New York · Federal district courts · NY · 2026-03-30 · No. 6:23-CV-06181 EAW · order

Fabricated or misquoted citations

On 2026-03-30, U.S. District Court for the Western District of New York struck the January 2026 filings and ordered the plaintiff to submit any future request to file additional papers as a motion. A self-represented party submitted a filing with fabricated or nonexistent authorities.

Disposition: The court granted summary judgment for Wal-Mart, denied Wal-Mart's motion to strike plaintiff's counterstatement, granted plaintiff leave to file excess pages, denied sanctions without prejudice except for striking Docket 79, entered judgment for Wal-Mart, and closed the case.
Recorded conduct: Plaintiff's January 2026 filings, including an unauthorized sur-reply and Docket 79, appeared to use artificial intelligence to present hallucinated cases and included misstatements of fact; Docket 79 appeared to include hallucinated cases at pages 2, 3, and 6. — outcome: filing struck; 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.

Defendant also identifies filings by Plaintiff in January 2026, including an unauthorized sur-reply Plaintiff filed on January 5, 2026, wherein Plaintiff appeared to use artificial intelligence to present “hallucinated cases” and made misstatements of fact. ... However, the Court will direct the Clerk of Court to strike from the docket Plaintiff’s memorandum of law in opposition to Defendant’s motion to strike, as that memorandum appears to include hallucinated cases. ... Defendant’s motion for sanctions (Dkt. 86) is denied without prejudice except that the Clerk of Court is directed to strike Docket 79 from the docket.

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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