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Courts on AI / Fabricated or misquoted citations

Nemec v. Alao

United States District Court for the District of Oregon · Federal district courts · OR · · No. No. 3:26-cv-83-SI · order

The District of Oregon on 2026-04-10 granted the motions to dismiss, denied the motions to strike, allowed amendment, and warned that AI-generated legal authorities must be verified in Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao. The self-represented plaintiff filed a brief with four fabricated case citations, including Hernandez v. Cnty. of Yamhill.

Disposition
The court granted both defendants’ motions to dismiss and denied Nemec’s motions to strike.
Recorded conduct
Nemec’s pro se oppositions cited four nonexistent District of Oregon cases: Hernandez v. Cnty. of Yamhill, U.S. Bank Nat’l Ass’n v. Taylor, Johns v. County of Douglas, and McNeil v. United States; the court said the false citations appeared to result from an AI tool such as ChatGPT. — outcome: noted, no consequence; 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.

com/watch? v=oqSYljRYDEM. PAGE 3 – ORDER it is advisable to use AI tools to conduct legal research or draft legal briefs will explain that any legal authorities or legal analysis generated by AI need to be verified. Plaintiff opposes both Alyssa Alao and Kelsey Alao’s motions on two grounds. First, Plaintiff argues, Defendants did not include a certification or representation of conferral in their motions, as is required by Local Rule 7-1(a). Although the Court may reject a motion on the ground that it fails to comply with a local rule, it declines to do so here. The record otherwise indicates that the parties have conferred throughout the litigation.

Authorities cited in the passage: Hernandez v. Cnty. of Yamhill · U.S. Bank Nat’l Ass’n v. Taylor · Johns v. County of Douglas · McNeil v. United States

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub