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Courts on AI / Fabricated or misquoted citations

Blackburn v. United States

U.S. District Court for the Western District of Oklahoma · Federal district courts · OK · · No. CIV-22-983-G · order

Fabricated or misquoted citations

On 2026-04-07, U.S. District Court for the Western District of Oklahoma denied the motion in limine and warned that the plaintiff’s mischaracterized treating-physician authorities implicated Rule 11. A self-represented party submitted a motion with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hall v. United States and Poppino v. Berryhill, an unrelated decision.

Disposition
The court denied the motion in limine and warned that the plaintiff’s mischaracterized treating-physician authorities implicated Rule 11.
Recorded conduct
The motion used false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hall v. United States and Poppino v. Berryhill, an unrelated decision, which the court found nonexistent, misquoted, or unsupported. — 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.

At a minimum, Plaintiff’s cited authority fails to demonstrate an entitlement to relief on the merits of her Motion. In addition, such mischaracterizations of case law, whether or not the product of generative artificial intelligence, implicate consideration of Plaintiff’s representations for purposes of Federal Rule of Civil Procedure 11(b) and (c). See Clark v. CoreCivic, Inc., No. CIV-25-775-SLP, 2025 WL 3709023, at *2 n.2 (W.D. Okla. Dec. 22, 2025). As recently explained by the Tenth Circuit, pro se litigants have “the responsibility to ensure that citations to legal authority are not fabrications but instead point to real cases that at least arguably stand for the propositions for which they are cited.” Dodds v. Bridges, No. 25-7021, 2026 WL 380194, at *6 (10th Cir. Feb. 11, 2026). CONCLUSION For the foregoing reasons, Plaintiff’s Motion in Limine (Doc. No. 135) is DENIED. IT IS SO ORDERED this 7th day of April, 2026.

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