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Courts on AI / Fabricated or misquoted citations

Dewayne Clark v. CoreCivic

United States District Court for the Western District of Oklahoma · Federal district courts · OK · · No. Case 5:25-cv-00775-SLP · report and recommendation

Fabricated or misquoted citations

Western District of Oklahoma on 2026-03-06 in Dewayne Clark v. CoreCivic found the self-represented party's surreply contained five citation defects, including Garrison v. Gambro, Tuckel v. Glover and Lemons v. Portfolio Recovery Assocs, involving fabricated or misattributed quotations, mischaracterized authority. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.

Disposition
The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.
Recorded conduct
The self-represented party's surreply contained five citation defects, including Garrison v. Gambro, Tuckel v. Glover and Lemons v. Portfolio Recovery Assocs, involving fabricated or misattributed quotations, mischaracterized authority. — 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.

about the types of errors found in Plaintiff’s briefs: There is nothing inherently problematic with the use of artificial intelligence to help prepare legal materials, but its careless use can waste both judicial resources and the opposing party’s time and money, and it can damage the credibility of the legal system. . . . We warn [the plaintiff]—and all pro se litigants and counsel appearing before this court—of 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) (citation modified). VII. Recommendation and Notice of Right to Object

Authorities cited in the passage: drastic remedy · with caution · so sick · Plaintiff's citation to Lemons v. Portfolio Recovery Assocs. in his Surreply was incorrect per the court · Dodds v. Bridges, No. 25-7021, 2026 WL 380194

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