Courts on AI / Fabricated or misquoted citations
Hong Chris Lu v. Capital One, N.A., et al.
U.S. District Court for the Northern District of Ohio · Federal district courts · OH · · No. 1:25-cv-1057 · memorandum opinion
On 2026-03-25, U.S. District Court for the Northern District of Ohio dismissed the case with prejudice and treated the repeated fake cases in successive filings as a factor supporting dismissal. A self-represented party submitted an opposition brief with fabricated or nonexistent authorities.
- Disposition
- The court dismissed the case with prejudice and treated the repeated fake cases in successive filings as a factor supporting dismissal.
- Recorded conduct
- The opposition brief used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — outcome: dismissal; 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.
conference, was not in compliance with the Court’s standing order regarding discovery and sanction motions, Doc. 36. Lu then filed, in opposition to Capital One’s dismissal motion, a brief which contained numerous fake cases and other troubling citation inconsistencies. Doc. 39. After Capital One pointed this out, Doc. 41, at 2, Lu submitted another filing with fake cases, Doc. 43. The Court issued a show cause order to Lu, non- document Order (filed October 22, 2025), and Lu apologized and withdrew or corrected his filings, Doc. 47. That same month, problems between Lu and HP began to surface. HP had asked for inspection of the allegedly defective computer that Lu purchased from HP, Doc. 50, but Lu refused to produce the computer for inspection, Doc. 51. The Court held a conference on October 29 and ruled that Lu must produce the computer for inspection. Doc. 52, at 1–2. The parties agreed that HP’s counsel would pick up the computer from Lu’s residence on November 3. Id. On October 29, Lu filed on the docket a “Notice regarding compliance” with the Court’s Minute Order, “confirm[ing] that HP would inspect the computer