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Courts on AI / Fabricated or misquoted citations

Arron v. Custer

United States District Court for the Southern District of Ohio · Federal district courts · OH · · No. 2:26-cv-390 · order

Fabricated or misquoted citationscourt does not name AI

On 2026-05-21, in Arron v. Custer, et al, the Southern District of Ohio magistrate judge treated the cited Ohio Supreme Court decision as unverified and recommended remand. A self-represented litigant filed a motion using unsupported or inaccurate legal authorities. The document links the problem to GAI.

Disposition
The court sustained in part and overruled in part objections to the initial screen, allowed limited recommittal, denied a temporary restraining order, and imposed no consequence for the unlocatable case.
Recorded conduct
The pro se plaintiff cited a purported Ohio Supreme Court case, Arron v. Arron, that the court could not locate or confirm. The court imposed no consequence for the citation issue. — outcome: noted, no consequence; 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.

Likewise, the Complaint does not appear to be attacking a state-court judgment so as to implicate the Rooker-Feldman doctrine. Beyond a vague reference to “court proceedings” (Compl, ECF No. 1-1, PAGEID # 3), Ms. Arron has not alleged the existence of any specific state judicial decision that she wants the Court to overturn.2 See, e.g., HPIL Holding, Inc. v. Zhang, 168 F.4th 944, 951 (6th Cir. 2026) (“Rooker and Feldman apply only to attempts to directly reverse a state court’s judgment.”) (emphasis added); cf. Exxon Mobil Corp., 544 U.S. at 284 (referencing “the narrow ground occupied by Rooker-Feldman”). 2 If it is found that such a state-court case does exist, however, reconsideration of subject-matter jurisdiction under the Rooker-Feldman doctrine may become appropriate. Even assuming that there was some qualifying state-court custody determination, the source of Ms. Arron’s injury is not that determination but rather Defendants’ allegedly improper conduct of detaining her, seizing her children without a warrant, and preventing her from being heard. (See Compl., ECF No. ... Arron’s application to proceed in forma pauperis and recommends dismissal for lack of subject-matter jurisdiction of Ms. Arron’s requested relief in the form of the “immediate reunification with [her] children” (Compl., ECF No. 1-1, PAGEID # 4). The Court further DENIES Ms. Aaron’s motion for a TRO (ECF No. 1-2). The Court otherwise REJECTS the OR&R and accordingly RECOMMITS the remainder of Ms. Arron’s Complaint to the Magistrate Judge for a further screening determination under 28 U.S.C. § 1915(e)(2). IT IS SO ORDERED. /s/ Sarah D. Morrison SARAH D.

Authorities cited in the passage: Inc. v. Zhang, 168 F

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub