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Courts on AI / Fabricated or misquoted citations

Kendle Mardis v. Dealer Loyalty Protection, Inc., et al.

United States District Court for the Southern District of Ohio · Federal district courts · OH · · No. No. 2:25-cv-1237 · memorandum opinion

Southern District of Ohio on 2026-02-18 found the self-represented party's brief contained one citation defect, including Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) and Johnson v. Mitchell, involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's brief contained one citation defect, including Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) and Johnson v. Mitchell, involving nonexistent authorities, incorrect statutory or rule text. — 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.

Moreover, both Car Source and the Dealer Loyalty Defendants point out that Plaintiff is citing hallucinated cases that do not exist, likely generated by artificial intelligence (“AI”). (See ECF No. 23, PageID 100 (explaining “Plaintiff cites Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) for the proposition that Car Source’s disclosure is insufficient. (ECF No. 22, PAGEID #97). But the case does not exist, it is hallucinated.”); ECF No. 37, PageID 151 (“Plaintiff appears to be utilizing AI-generated briefs and ‘fake, hallucinated law’ that ignore the actual facts of the docket and prior Court orders.”).) As Rule 11 states, by presenting a paper, Plaintiff certifies that to the best of his knowledge “the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing

Authorities cited in the passage: Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) · Rule 11

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