Courts on AI / Fabricated or misquoted citations
Kristina Crist v. Roy Chris West
United States District Court for the Western District of Oklahoma · Federal district courts · OK · · No. CIV-25-1446-R · order
The Western District of Oklahoma on 2026-05-07 publicly reprimanded counsel, fined counsel $250, and ordered counsel to notify the client of the sanctions order in Kristina Crist v. Roy Chris West, et al. Counsel filed a brief with one fabricated case citation and one mischaracterized case citation.
- Disposition
- Attorney Bussett was publicly reprimanded and ordered to pay a $250 sanction to the Clerk and notify her client.
- Recorded conduct
- Attorney Rachel Bussett used a trusted legal vendor’s AI tool and filed fake or misleading authorities without adequate verification. The court imposed a $250 sanction payable to the Clerk. — outcome: fine; actor: lawyer; $250
- 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.
Bussett blames the briefing errors on her use of a “trusted legal vendor’s AI tool” to research and draft the brief as well as some “more traditional errors. ” Id. at p. 3. Ms. Bussett concedes that she failed to perform the essential step of personally verifying the case citations and has apologized for her conduct. Id. The Court finds that Ms. Bussett’s conduct – specifically the inclusion of fake or misleading authority in a written brief – violates Rule 11(b)(2). See Wadsworth v. Walmart Inc. , 348 F. R. D. 489, 495 (D. Wyo. 2025) (“[U]sing a fake opinion to support an argument is a violation of Rule 11(b)(2). ”);
Authorities cited in the passage: See Wadsworth v. Walmart Inc. , 348 F · Fed. R. Civ. P. 11
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