Courts on AI / Fabricated or misquoted citations
Oscar Brownfield v. Cherokee County School District No. 35
U.S. District Court for the Eastern District of Oklahoma · Federal district courts · OK · · No. d in ED/OK on 03/19/26 · opinion
On 2026-03-19, U.S. District Court for the Eastern District of Oklahoma denied the plaintiff’s sanctions motion but imposed a $500 sanction for citing fictitious or inaccurate authorities generated through AI research. A self-represented party submitted a motion with two false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hill v. Oklahoma and Wadsworth v. Walmart.
- Disposition
- The court denied the plaintiff’s sanctions motion but imposed a $500 sanction for citing fictitious or inaccurate authorities generated through AI research.
- Recorded conduct
- The motion used two false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hill v. Oklahoma and Wadsworth v. Walmart, which the court found nonexistent, misquoted, or unsupported. — outcome: other; actor: litigant in person; $500
- 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.
AI in legal representation has increased, so have incidences of fictitious or inaccurate citations resulting from such AI tools. Presentation of inaccurate authorities in pleadings resulting from AI subject to the signing party to sanctions. See, e.g., Hill v. Oklahoma, 2025 WL 1840659, at *4 (W.D. Okla. July 3, 2025) (“[C]ourts have increasingly found the imposition of sanctions proper in response to an attorney's conduct in citing ‘fake cases’ that are ‘hallucinations’ generated by an artificial intelligence platform.”) (citing Wadsworth v. Walmart, 348 F.R.D. 489, 495-496 (D. Wyo. 2025) (citing fake cases in a signed motion violated Rule 11(b)(2) and subjected attorneys to imposition of monetary sanctions); Bunce v. Visual Technology Innovations, Inc., 2025 WL 662398 at *1 (E.D. Pa. Feb. 27, 2025) (imposing sanctions where the attorney filed two separate motions that cited two cases that could not be located “on any legal research tool . . . .”); Ramirez v. Humala, 2025 WL 1384161 at * 1 (E.D.N.Y. May 13, 2025) (collecting cases finding “the submission of nonexistent case citations in filings to the court to constitute sanctionable conduct” under Fed. R. Civ. P. 11(b)(2)). Plaintiff admits he
Authorities cited in the passage: Hill v. Oklahoma, 2025 WL 1840659 · Ramirez v. Humala, 2025 WL 1384161 · Fed. R. Civ. P. 11(b)(2)
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