Courts on AI / Fabricated or misquoted citations
Domingo Beato-Estrella v. M. Arviza
U.S. District Court for the Middle District of Pennsylvania · Federal district courts · PA · · No. 3:26-CV-245 · memorandum opinion
On 2026-03-16, U.S. District Court for the Middle District of Pennsylvania dismissed the habeas petition without prejudice and cautioned that AI programs can hallucinate fake cases that do not support jurisdiction. A self-represented party submitted a petition with fabricated or nonexistent authorities and mischaracterized authorities, including Santos v. Warden Allenwood FCI, No. 1:17-CV-02116 and London v. Pettit.
- Disposition
- The court dismissed the habeas petition without prejudice and cautioned that AI programs can hallucinate fake cases that do not support jurisdiction.
- Recorded conduct
- The petition used fabricated or nonexistent authorities and mischaracterized authorities, including Santos v. Warden Allenwood FCI, No. 1:17-CV-02116 and London v. Pettit, which the court found nonexistent, misquoted, or unsupported. — 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.
irrelevant to the present dispute. Beato-Estrella is cautioned that not all resources are created equal. For example, AI programs have been known to hallucinate, or create fake cases, in response to a user’s query. Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341, 342 (E.D.N.Y. 2025). The court understands legal research is difficult for anyone, especially when considering the constraints of doing so while incarcerated. Still, even though the court affords latitude to parties who are pro se, they must still ensure to follow the rules of the court and cite to actual law. In any event, it is clear the court does not have jurisdiction over Beato- Estrella’s current petition. He has not pointed to any aspect of his original judgment being ignored by the BOP. Nor is he presently eligible for any program to which an ICE detainer is depriving access. Therefore, this matter will be dismissed without prejudice for lack of subject matter jurisdiction. /S/ KELI M. NEARY Keli M. Neary United States District Judge Middle District of Pennsylvania March 16th, 2026
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