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Courts on AI / Fabricated or misquoted citations

Dillon v. Myles Stephenson, et al.

United States District Court for the Western District of Oklahoma · Federal district courts · OK · · No. Case 5:25-cv-00484-SLP · order

Western District of Oklahoma on 2026-03-11 in Dillon v. Myles Stephenson, et al. found counsel's brief contained three citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court admonished counsel to verify cited authorities and avoid repeating the citation defects.

Disposition
The court admonished counsel to verify cited authorities and avoid repeating the citation defects.
Recorded conduct
Counsel's brief contained three citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. — outcome: warning; 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.

subsequently directed counsel for the Plaintiffs and School District to state “whether or not they used generative AI in connection with their filings in the action.” Order [Doc. No. 14] at 3. The Court also referenced the Court’s Chambers Rules regarding the use of generative AI. Id. at 2. Plaintiffs’ counsel represented to the Court that “AI was not used to generate any content” and that reliance on an AI research assistant “did not supplant counsel’s independent review of [ ] cases.” Notice [Doc. No. 16]. Upon review of Plaintiffs’ Response brief [Doc. No. 10], the Court found three additional incorrect citations associated with Plaintiffs’ briefing on compliance with the Oklahoma Governmental Tort Claims Act (GTCA): (1) Lane v. Buchanan, 2021 OK CIV APP 8, ¶ 11, 489 P.3d 498, 502 (case does not exist and citations are not related to the GTCA); (2) Hall v. GEO Group, Inc., 2021 OK CIV APP 36, ¶ 15, 497 P.3d 136, 1241 (an Oklahoma Supreme Court case with the same name exists, but the indicated reporter citations are incorrect and the case does not support Plaintiffs’ proposition); and (3) Conley v. Board of Regents, 2002 OK CIV APP 84, ¶ 9, 55 P.3d 567, 570 (the case does not exist and citations are not related to the GTCA). Such incorrect citations may have been the result of reliance on a generative- AI program. “By presenting to the court a . . . written motion . . . an attorney . . . certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . the claims, defenses, and other legal contentions are warranted by existing law . . . .” Fed. R. Civ. P. 11(b)(2) (emphasis added). 12

Authorities cited in the passage: Lane v. Buchanan · Hall v. GEO Group · Conley v. Board of Regents · Fed. R. Civ. P. 11(b)(2)

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