Courts on AI / Fabricated or misquoted citations

David Martin v. ODS Community Dental Insurance et al.

United States District Court for the District of Oregon · Federal district courts · OR · 2026-02-18 · No. 3:26-cv-00298-AB · memorandum opinion

Fabricated or misquoted citations

District of Oregon on 2026-02-18 in David Martin v. ODS Community Dental Insurance et al. found the self-represented party's motion quoted language not found in Zschernig and gave incomplete citations to Hartman, Estelle, and Glucksberg. The court denied the temporary-restraining-order motion and warned the self-represented plaintiff against further inaccurate or incomplete citations.

Disposition: The court dismissed the claims and warned Martin that further inaccurate or incomplete legal citations would not be tolerated.
Recorded conduct: Martin’s briefing contained many inaccurate or incomplete citations to caselaw; the court warned him to verify them if using generative AI. — 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.

claims, the Court notes that many of Plaintiff’s citations to caselaw are inaccurate or contain incomplete citations.3 To the extent that Plaintiff is using generative artificial intelligence to aid 3 For example, Plaintiff cites to Zschernig v. Miller, 389 U.S. 429, 432 (1968), for a quote that does not exist on the cited page or anywhere else in the case. Pl.’s Mot. 14. Elsewhere, Plaintiff appears to cite within rhymed verse Hartman v. Moore, 547 U.S. 250 (2006), Estelle v. Gamble, 429 U.S. 97 (1976), and Washington v. Glucksberg, 521 U.S. 702 (1997), without full citations supporting Plaintiff’s argument. Id. at 36–37, 76–77. 3 – ORDER Case 3:26-cv-00298-AB Document 7 Filed 02/18/26 Page 4 of 5

Authorities cited in the passage: Estelle v. Gamble · Washington v. Glucksberg in rhymed verse and without full or supporting citations · Washington v. Glucksberg

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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