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Courts on AI / Fabricated or misquoted citations

Brock et al. v. Hamilton County JFS Children Services et al.

United States District Court for the Southern District of Ohio · Federal district courts · OH · · No. 1:25-cv-685 · report and recommendation

On 2026-05-15, in Brock et al. v. Hamilton County JFS Children Services et al, the Southern District of Ohio warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a petition using nonexistent or hallucinated authorities.

Disposition
The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
A self-represented litigant filed a petition using nonexistent or hallucinated authorities. — 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.

To start it appears her objection on this front relies on hallucinated case law. Brock cites to Jansen v. City of Cincinnati, 904 F.3d 336, 349–50 (6th Cir. 2018), which she describes as specifically holding that “§ 1983 claims against child welfare workers for fabricating evidence are not barred by Rooker-Feldman.” (Doc. 21, #2408 (emphasis omitted)). She further says that the case is “directly on point and binding.” (Id. at #2409 (emphasis in original)). But there are a couple of problems with that. First, 904 F.3d 336 is the citation for Gilkers v. Vannoy, a Fifth Circuit case involving a habeas petition. Admittedly, there is a Jansen v. City of Cincinnati, 904 F.2d 336 (6th Cir. 1990). And as Brock is proceeding pro se, the Court could perhaps forgive her referring to F.3d, as opposed to F.2d. But that still leaves the second problem—that Jansen opinion likewise says nothing about childcare workers and § 1983. Rather, it involves a challenge to race-based quotas for city employment. Id. at 338–39.

Authorities cited in the passage: Brock cites to Jansen v. City of Cincinnati, 904 F · F.3d 336 is the citation for Gilkers v. Vannoy · Jansen v. City of Cincinnati, 904 F

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