Courts on AI / Fabricated or misquoted citations
Jamal Berry v. Early Warning Services
United States District Court for the Eastern District of Pennsylvania · Federal district courts · PA · · No. 2:25-cv-04638-HB · order
The Eastern District of Pennsylvania on 2026-04-30 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jamal Berry v. Early Warning Services. The self-represented plaintiff filed an opposition with one fabricated case citation, one false case quotation, and one mischaracterized case citation, including McIvor v. Credit Control Servs.
- Disposition
- The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
- Recorded conduct
- The self-represented plaintiff filed an opposition with one fabricated case citation, one false case quotation, and one mischaracterized case citation, including McIvor v. Credit Control Servs and Gonzalez v. Experian Info. Sols. — 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.
Agents, Emps. or Officers, 855 F. 2d 1080, 1091 (3d Cir. 1988). It has come to the court’s attention that plaintiff, in his opposition to the motion to dismiss, submitted legal citations to cases that do not exist, fake quotes from real cases, and inaccurate legal arguments attributed to real cases. For example, plaintiff quoted the following from McIvor v. Credit Control Services, 773 F. 3d 909 (8th Cir. 2014): “A CRA may be liable under §1681i if it receives sufficient information to identify the disputed account, regardless of the channel through which the dispute is transmitted. ” Response in Opposition, Berry v. Early Warning Services, Civ.
Authorities cited in the passage: McIvor v. Credit Control Services, 773 F · Berry v. Early Warning Services · Plaintiff quoted a passage purportedly from McIvor v. Credit Control Servs., 773 F.3d 909 (8th Cir. 2014) · Plaintiff cited Gonzalez v. Experian Info. Sols., Inc., No. 20-cv-8997, 2021 WL 7285265 (C.D. Cal. 2021) · Plaintiff relied on Weseman v. Wells Fargo Home Mortg., No. 06-1338, 2008 WL 542961 (D. Or. Feb. 22, 2008) and attributed to it a rule a
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