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Courts on AI / Fabricated or misquoted citations

Quandel Construction Group, Inc. v. Hunt Construction Group, Inc.

United States District Court for the Southern District of Ohio · Federal district courts · OH · · No. 2-24-cv-2362 · opinion

On 2026-03-31, U.S. District Court for the Southern District of Ohio ordered counsel to explain how nonexistent citations and nonexistent quoted language entered Hunt’s briefing despite counsel’s denial that AI caused the errors. Counsel submitted a brief with The brief cited nonexistent cases and quoted language that the court could not find in any actual decision.

Disposition
The court granted Hunt leave to file a corrected opposition, denied Quandel relief from the stay, kept the case stayed, and ordered Hunt's attorneys to submit sworn statements addressing the citation errors and any AI use.
Recorded conduct
Hunt's opposition memorandum gave an apparently incorrect Vaughn case number and cited an apparently nonexistent Aerpio case with the wrong case number and Westlaw citation, three quotations that did not exist in the actual Aerpio decision, and pinpoint citations to pages that did not support the proposition. — outcome: pending; actor: lawyer
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.

_ F.4th __, 2026 WL 710568, at *3 (6th Cir. Mar. 13, 2026) (citation omitted). Hunt’s briefing provided this Court with nonexistent case citations and purported to quote nonexistent case language; Hunt’s representation that artificial intelligence was not the cause of these errors is not an explanation sufficient to address how these errors actually happened. Though the Court takes counsel for Hunt at their word if they say that artificial intelligence was not involved in their legal research, that does not end the inquiry. The topical worry that artificial intelligence will lure attorneys with the false siren song of easy shortcuts to legal authority is part of a much larger concern that attorneys will fail to cite their sources properly and—either intentionally or unintentionally—mislead the Court. Whether artificial intelligence was used, false citations damage judicial proceedings: “[t]he opposing party expends resources identifying and exposing the fabrications; the court spends time reviewing materials, holding hearings, deliberating about sanctions, and explaining its ruling; the substance of the case is delayed; and public confidence about the trustworthiness of legal proceedings may be diminished.” Johnson v. Dunn, 792 F. Supp. 3d 1241, 1257 (N.D.

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