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Courts on AI / Fabricated or misquoted citations

Chapter Kris Jackson v. BOK Financial Corporation et al. (3)

United States District Court for the Northern District of Oklahoma · Federal district courts · OK · · No. 25-CV-00297-SEH-SH · memorandum opinion

Northern District of Oklahoma on 2026-02-24 in Chapter Kris Jackson v. BOK Financial Corporation et al. (3) found the self-represented party's brief contained three citation defects, including Inc. v. Carmen Feliciando and Badillo v. Thorpe, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered the self-represented party to pay $405 for the defective authorities.

Disposition
The court struck the petition, objection, and other pending motions for persistent inaccurate and nonexistent citations, while allowing an amended petition.
Recorded conduct
Jackson’s objection, petition, and motions continued a pattern of nonexistent, misleading, or misquoted authorities after warnings and a prior sanctions order. — outcome: filing struck; 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.

579 U.S. 40, 47 (2016) (recognizing a district court’s inherent power to manage its docket); Moore v. City of Del City, No. 25-6002, 2025 WL 3471341, at *3 (10th Cir. Dec. 3, 2025) (recognizing the same in the context of an attorney who submitted briefs that contained hallucinated or fake case citations as a result of using generative AI technology). The Court’s inherent authority is not without limits, and the exercise of these powers “must be a ‘reasonable response to the problems and needs’ confronting the court’s fair administration of justice,” and such exercise “cannot be contrary to any express grant of or limitation on the district court's power contained in a rule or statute.” Dietz, 579 U.S. at 45. Just as Judge Huntsman did, federal courts 5

Authorities cited in the passage: Badillo v. Thorpe, 158 F. Supp. 2d 177 (D. Conn. 2001) · Inc. v. Carmen Feliciando de Melecio · Badillo v. Thorpe decision is at 158 F. App'x 208 · Moore v. City of Del City, No. 25-6002, 2025 WL 3471341

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