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Courts on AI / Fabricated or misquoted citations

Dalton Gage Hill v. Oklahoma County Criminal Justice Authority

United States District Court for the Western District of Oklahoma · Federal district courts · OK · · 2026 WL 1429765 · No. CIV-24-1298-D · report and recommendation

On 2026-05-21, in Dalton Gage Hill v. Oklahoma County Criminal Justice Authority, the Western District of Oklahoma magistrate judge recommended denying the motion to vacate and described earlier Rule 11 sanctions proceedings against counsel. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for.

Disposition
The magistrate judge recommended denying the motion to vacate and described earlier Rule 11 sanctions proceedings against counsel.
Recorded conduct
Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support. — outcome: sanctions; 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.

McBride to appear before the Court to show cause as to why sanctions should not be imposed under Rule 11 and the Court's inherent authority for citing fictitious cases in his response to Defendant Logan's motion to dismiss. See Doc. 126. 2. On September 5, 2025, the undersigned recommended Mr. McBride pay Defendants' reasonable attorneys' fees and costs incurred for attending the Court's show cause hearing. Doc. 134.3 3. On December 4, 2025, Judge DeGiusti adopted the Report andRecommendation.Doc.143.JudgeDeGiustialsoordered Mr. McBride to “disclose in all future pleadings whether generativeAIwasused,thespecificAItoolthatwasused,and [to] certify in the document that he ... checked the accuracy of any portion of the document drafted by generative AI, including all citations and legal authority.” Id. at 3. 4.OnMarch3,2026,theCourtorderedthepartiestomeetand confer and reach an agreement on the amount of attorney fees owed, given an ongoing dispute between counsel McBride and Defendants. See Doc. 156; Doc. 158, at 3. The Court advised Defendants that they must file an appropriate motion no later than March 17, 2026, if an agreement was not reached. Doc. 156. 5. On March 17, 2026, Defendants filed the present contempt motion. Doc. 158. 3. Violations of the Court's Order.

Authorities cited in the passage: Rule 11

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