Skip to content

Courts on AI / Fabricated or misquoted citations

Marble v. O'Malley

United States District Court for the Middle District of Pennsylvania · Federal district courts · PA · · No. 3:26cv40 · order

The Middle District of Pennsylvania on 2026-04-27 admonished the self-represented plaintiff for unverified or fabricated authorities and cautioned against repeating the citation misconduct. The self-represented plaintiff filed a brief with one fabricated case citation, one fabricated or AI-like submission item, and one invented legal doctrine, including TRO brief attributes a holding to Manuel v. City of Joliet that it….

Disposition
The R&R was adopted, the TRO was denied, the complaint was dismissed without prejudice, and Marble was admonished and ordered to disclose and certify future AI-assisted filings.
Recorded conduct
Marble’s AI-aided complaint invented an “attorney-equivalent compensation” doctrine and his TRO brief attributed a fabricated Younger holding to Manuel v. City of Joliet. The court admonished him and ordered future AI disclosure and citation certification. — 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.

See Kay v. Ehrler, 499 U. S. 432, 438 (1991). In this variety of hallucination, the Almodel appears to have provided the plaintiff with a legal doctrine that he wanted to exist without it actually existing. also filed an accompanying Al-aided motion for a temporary restraining order (“TRO”) along with an Al-aided brief in support. 2 Per the motion, Marble “is currently subject to criminal prosecution predicated on alleged criminal trespass and/or burglary. ” (Doc. 3 at 1). The motion references Marble’s ostensible preliminary hearing testimony, presented as an “Excerpt of an Official Court Transcript,” where plaintiff’s former landlord testified that he evicted the plaintiff and that plaintiff kept returning to the properties. 3 (Doc.

Authorities cited in the passage: See Kay v. Ehrler, 499 U · Plaintiff's TRO brief attributes a holding to Manuel v. City of Joliet that it references Younger doctrine

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