Courts on AI / Fabricated or misquoted citations
Stafford v. Andrew Taffet, et al.
U.S. District Court for the District of Oregon · Federal district courts · OR · · No. 1:24-cv-01612-AA · opinion
On 2026-03-23, U.S. District Court for the District of Oregon declined sanctions because defendants did not request them, but warned that the plaintiffs’ false citations appeared to be unverified AI hallucinations. A self-represented party submitted an appellate brief with multiple fabricated or nonexistent authorities, including Campbell v. MERS and Tucker v. HSBC.
- Disposition
- The court declined sanctions because defendants did not request them, but warned that the plaintiffs’ false citations appeared to be unverified AI hallucinations.
- Recorded conduct
- The appellate brief used multiple fabricated or nonexistent authorities, including Campbell v. MERS and Tucker v. HSBC, which the court found nonexistent, misquoted, or unsupported. — outcome: other; 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.
Plaintiffs cite to “Schweitzer v. FHLMC, No. 3:13-cv-0181, 2013 WL 4279629 (D. Or. Aug. 29, 2013)” on pages 11 and 34 of the SAC. Once again, no such case exists and the case number Plaintiffs provide is for a Social Security appeal. Presenting false citations is a grave matter and suggests an intention to mislead or deceive the Court. The most charitable interpretation is that Plaintiffs have relied on AI to complete their pleadings and briefing and have presented the resulting “hallucinated” citations to the Court without verifying their authenticity. The use of such a defective expedient makes Plaintiffs’ repeated complaints concerning their hours spent on legal research ring especially hollow. The presentation of false citations, including AI “hallucinations,” has been found to be sanctionable conduct for attorneys and pro se parties. See United States v. Hayes, 763 F. Supp.3d 1054, 1071 (E.D. Cal. 2025) (collecting cases). Fortunately for Plaintiffs, Defendants have represented to the Court that they do not intend to seek sanctions for Plaintiffs’ conduct at this time and so the Court will leave the matter there for now. II. Shotgun Pleadings Defendants move to dismiss the claims against Defendants Bruce Rose, Andrew Taffet, Stacey Lamarre, and Carrington Holding Company, LLC on the grounds that the Complaint does not allege any specific allegations against those Defendants beyond impermissible group allegations naming either “Defendants” or “Carrington.” Page 4 –OPINION & ORDER A pleading in which a “complainant asserts claims against multiple defendants without specifying which of the defendants are responsible for which acts or