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 · memorandum opinion
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 motion to dismiss was granted and Berry was warned about AI-generated false authorities.
- Recorded conduct
- Berry’s pro se opposition contained nonexistent cases, fake quotes, and inaccurate legal arguments that the court attributed to artificial intelligence. The court dismissed on the merits and warned him. — 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.
...of preemption and conflicts between common law and other FCRA provisions. It did not discuss direct disputes and statutory obligations for a CRA as the defendant in that case was a furnisher, not a CRA. While the court cites these three examples, his opposition contained other inaccurate citations. Plaintiff undoubtedly used artificial intelligence to craft his opposition. Plaintiff submitted numerous false citations in his opposition, including cases that do not exist. As noted previously, pro se litigants “cannot flout procedural rules — they must abide by the same rules that apply to all other litigants,” including Rule 11. Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir. 2013). The court strongly cautions him that any use of fictitious caselaw in the future may lead to severe sanctions under R...
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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