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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. 3:26-cv-00040-JKM · order

Fabricated or misquoted citations

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 court admonished the self-represented plaintiff for unverified or fabricated authorities and cautioned against repeating the citation misconduct.
Recorded conduct
The self-represented plaintiff filed a brief with one fabricated case citation, one fabricated or AI-like submission item, and one invented legal doctrine. — 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

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