Owen v. Askew

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

In the course of briefing her motion to dismiss and in response to Plaintiff’s filings, Ms. Askew acknowledged that she relied on a false citation, “Young v. Maciorca, 69 F.4th 1099, 1106 (9th Cir. 2023).” ECF No. 92. Ms. Askew subsequently withdrew her references to “Young v. Maciorca,” which is not a Ninth Circuit decision. The Court notes, however, that “Young v. Maciorca” is not the only false citation in Ms. Askew’s briefing. Ms. Askew also cited to “IGI Cybersecurity Services v. [Defendant], Case No. 3:23-cv-01277 (D. Or. July 11, 2024),” in which Ms. Askew claims that “the court found no personal jurisdiction even though the defendant engaged in videoconferences and communications with Oregon parties. The court explained that such incidental or attenuated contacts, absent purposeful targeting, do not satisfy due process.” Askew Mot. at 6. As might be guessed from its incomplete caption, this is not the case cited. The docket number, 3:23-cv-1277, is for Cohen v. Infinite Group, Inc. et al. and, while that case did discuss personal jurisdiction and final judgment was entered on July 11, 2024, the case was subsequently reversed by the Ninth Circuit, which found errors in the district court’s analysis of personal jurisdiction. The Court understands that the parties in this case are self-represented and that there is a significant temptation to rely on artificial intelligence in the drafting of legal papers. The Court therefore advises the parties that it will not accept false or “hallucinated” citations and will view their inclusion in legal filings as an attempt to deceive or mislead the Court. All parties are warned that the inclusion of false or hallucinated citations in future briefs may result in the imposition of sanctions on the filing party.

Authorities cited in the passage: Young v. Maciorca, 69 F.4th 1099 (9th Cir. 2023) · IGI Cybersecurity Services v. [Defendant], Case No. 3:23-cv-01277 (D. Or. July 11, 2024) · Cohen v. Infinite Group, Inc., No. 3:23-cv-1277 · LR 7-1(a)(3)