Courts on AI / Fabricated or misquoted citations
Fleck v. Del-One Federal Credit Union
United States District Court for the District of Oregon · Federal district courts · OR · · No. 3:25-cv-01048-SB · opinion
On 2026-03-30, U.S. District Court for the District of Oregon ordered screening conditions and warned that any further hallucinated legal citations would expose the plaintiff to sanctions or dismissal. A self-represented party submitted an appellate brief with The appellate brief attributed a quotation to a non-existent case and relied on that authority for a proposition not supported by real law.
- Disposition
- The court dismissed the complaint without prejudice, allowed leave to amend, and warned Fleck that failure to comply with rules may result in sanctions.
- Recorded conduct
- Fleck cited a case that did not generate a case; the only Westlaw source containing the quoted proposition was Fleck's response in this case. — 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.
case” and the only source on Westlaw that includes the quote that Fleck attributes to the non-existent case is Fleck’s response in this case. Cf. Whiting v. City of Athens, No. 24-5918, --- F.4th ---- , 2026 WL 710568, at *1, *3, *10-13 (6th Cir. Mar. 13, 2026) (sanctioning lawyers for submitting briefing that “cited non-existent cases[] and cited cases for propositions of law that they did not even discuss, much less support,” explaining that the “appeal [was] frivolous as argued because [the lawyers] submitted fake cases, and inventing case law is a misrepresentation of law,” and providing examples that the Sixth Circuit was unable to locate, citations that did “not generate a case,” and an instance in which the “only source on Westlaw” was a lawyer’s “briefing in th[e] case”). It is also important to consider “when AI is used to prepare a brief, ‘AI hallucinations are more likely to occur when there are little to no existing authorities available that clearly satisfy the user’s request—such as, for example, when a [litigant] asks a generative AI tool to supply a citation for an unsupported principle of law.’” Id. at
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
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