Courts on AI / Fabricated or misquoted citations
Voyton v. Voyton
United States District Court for the Middle District of Pennsylvania · Federal district courts · PA · · 2026 WL 2322660 · No. 3:26-cv-27 · memorandum opinion
The Middle District of Pennsylvania adopts a recommendation to dismiss Courtney Voyton’s complaint with leave to amend and admonishes her AI use. The memorandum says she misrepresented 42 Pa. Cons. Stat. § 5522 and advanced AI-steered ghost arguments unrelated to the report, requiring future AI-use affidavits.
- Disposition
- The court adopted the report and recommendation, dismissed with leave to amend, and required future AI-use affidavits.
- Recorded conduct
- Self-represented plaintiff misrepresented a Pennsylvania notice statute and filed AI-steered ghost arguments about doctrines not discussed in the R&R. — 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.
Prior to addressing the merits of the allegations against Skibitsky, plaintiff is admonished for misrepresenting the law. The statute cited by plaintiff in Paragraph 43 has nothing to do with the alleged conduct by Skibitsky. Rather, the statute referenced requires a person to file a formal written notice of their intent to sue a state governmental unit for personal injury or property damage within six months of the incident. 42 PA. CONS. STAT. § 5522(a). It is improper to misstate the law in this manner. See FED. R. CIV. P. 11 (b). Therefore, plaintiff's future filings in this court will require an affidavit regarding Al usage. ... Courtney's objections also argue about the non-applicability of Younger abstention, the Rooker-Feldman doctrine, and quasi-judicial immunity. However, the R&R issued by Chief Magistrate Judge Bloom in this case did not include a discussion about any of these areas of the law. The only conclusion that may be reached is that the generative Al service used by the plaintiff steered her in the wrong direction. The result is a misleading document and a waste of judicial resources filtering out “ghost arguments” to reach matters on their merits. ... Given the seriousness of the misrepresentations in her complaint and in her objections to the R&R, the plaintiff is forewarned that future unchecked Al usage will result in sanctions, up to and including striking pleadings and dismissing claims with prejudice.
Authorities cited in the passage: 42 Pa. Cons. Stat. § 5522(a) · Fed. R. Civ. P. 11 · Younger abstention · Rooker-Feldman doctrine · Jones v. Kankakee County Sheriff's Department, 164 F.4th 967 (7th Cir. 2026)