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Courts on AI / Fabricated or misquoted citations

Davenport v. Churilla

United States District Court for the Western District of Pennsylvania · Federal district courts · PA · · No. 3:25-cv-00330-RJC · memorandum opinion

Fabricated or misquoted citationsSelf-represented litigants using AI

The Western District of Pennsylvania resolves motions in Dyran Davenport’s civil-rights action and warns him about inaccurate filings. The court identifies nonexistent Loder v. City of Philadelphia as an AI-hallucinated citation in his opposition but still accepts his accrual argument based on other relevant authority.

Disposition
The court dismissed several claims, allowed amendment on some, and warned Davenport about false authority and allegations.
Recorded conduct
Self-represented plaintiff cited nonexistent Loder v. City of Philadelphia in support of his statute-of-limitations argument. — 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.

Moreover, the Court acknowledges that Plaintiff’s briefs appear to include at least one AI hallucinated citation. Plaintiff has also made unsupported, and to the extent unsupportable, arguably outrageous allegations about Defendants and their counsel. ... Plaintiff has proffered and the Court has seen no evidence to suggest that either of these allegations is at all true. Plaintiff is sternly warned that he must confirm the accuracy of both asserted facts and law cited in his filings to this Court. The Court will not countenance inaccurate or inflammatory allegations. ... The Court notes that Plaintiff appears to have cited an AI-hallucinated case in support of his argument on this point. See Br. in Opp. at 2 (citing the nonexistent case “Loder v. City of Philadelphia, 838 F.3d 311 (3d Cir. 2016)”). Nonetheless, Plaintiff has also cited relevant caselaw, and indeed, the Court finds that Plaintiff’s interpretation is the better one.

Authorities cited in the passage: Loder v. City of Philadelphia, 838 F.3d 311 (3d Cir. 2016)

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