Courts on AI / Fabricated or misquoted citations
Trauger v. Columbia County District Attorney’s Office
United States District Court for the Middle District of Pennsylvania · Federal district courts · PA · · No. 4:25-cv-01469 · memorandum opinion
On 2026-05-29, in Trauger v. Columbia County District Attorney's Office et al, the Middle District of Pennsylvania warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed opposition papers using nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Disposition
- The court granted defendants’ motions to dismiss, dismissed the complaint, and warned plaintiff that future noncompliant AI or false-authority filings may result in sanctions.
- Recorded conduct
- The pro se plaintiff cited Hakeem and Reitz for the opposite of their holdings and represented nonexistent Third Circuit assertions and cases. The court dismissed for lack of suable defendants and warned her. — 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.
Page 9 of 12 Most glaringly, in opposition to the Police Department’s motion to dismiss, Trauger represents non-existent assertions and cases from the Police Department’s brief. See Pl.’s Br. in Opp’n to Def. Police Department’s Mot. to Dismiss, doc. 34 at 3-5. This appears to indicate one of the hallmarks of generative AI use: hallucination.3 For example, Trauger states that the Police Department cited “Will v. Michigan Dep’t of State Police, 491 U.S. 58 (1989), and Estate of Lagano v. Bergen Cty. Prosecutor’s Office, 769 F.3d 850 (3d Cir. 2014), to assert it is a state entity immune from suit (Doc. 30 at 8-10).” Id. at 3. Nowhere in its briefs does the Police Department cite to Will or Lagano. See doc. 30; see also Def. Police Department’s Reply Br., doc. 36. Nor does it assert that “it is a state entity immune from suit,” (doc. 34 at 3) as Trauger asserts, but rather that it is a municipal police department. See doc.
Authorities cited in the passage: Will v. Michigan Dep’t of State Police, 491 U · Estate of Lagano v. Bergen Cty. Prosecutor’s Office, 769 F
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
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