Courts on AI / Fabricated or misquoted citations
Donaghy v. Zoning Bd. of Review of the Town of North Kingstown
Rhode Island Superior Court · State trial courts · RI · · 2026 WL 771127 · No. No. WC-2024-0649 · opinion
Rhode Island Superior Court on 2026-03-12 found counsel's appellate brief contained two citation defects, including Smithfield v. Fanning and Duffy v. Milder, involving nonexistent authorities, fabricated or misattributed quotations. The court remanded the zoning appeal to the board for a continued public hearing and cautioned counsel about likely AI-generated citations.
- Disposition
- The court remanded the zoning appeal to the board for a continued public hearing and cautioned counsel about likely AI-generated citations.
- Recorded conduct
- Counsel's appellate brief contained two citation defects, including Smithfield v. Fanning and Duffy v. Milder, involving nonexistent authorities, fabricated or misattributed quotations. — outcome: other; actor: lawyer
- 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.
have made clear that public comment should have been allowed, at least on the new evidence. 2 Although the Court does not address these arguments, it observes with great concern that Appellant's briefing on the definition of an “accessory” includes quotations of nonexistent law. Appellant cites two Rhode Island Supreme Court cases in support of her argument: Town of Smithfield v. Fanning, 602 A.2d 939 (R.I. 1992) and Duffy v. Milder, 896 A.2d 27 (R.I. 2006). These cases exist, but have nothing to do with the question presented. In Smithfield, our high court did not discuss accessory uses or the need for such uses to be consistent with the principle use. Even more disturbing – the sentence quoted from page 942 of Smithfield does not appear anywhere else in the case. Likewise, the Duffy case does not address a photography business in a residential area, it concerns a horse stable and equestrian center. The citations are inaccurate and misleading. Whether it is a short deadline, the rise of artificial intelligence, or a simple error, this leaves the Court doubting all that is said by counsel. Courts depend on memoranda from counsel to guide them through the issues raised in our adversary system. An attorney's work, in the noble profession of the practice of law, is his or her bond. The Court reserves its right to take further action but goes no further today other than to express its dissatisfaction at the presentation of an argument which appears to be the product of, at best, recklessness. “Justice is built on language, and language draws its power from the hearts and minds that create it. Words alone are empty until filled with human conviction. The same is true of every pleading filed before this Court. Generative technology can produce words, but it cannot give them belief. It cannot attach courage, sincerity, truth, or responsibility to what it writes. That remains the sacred duty of the lawyer who signs the page.” Mattox v. Product Innovations Research, LLC, No. 6:24-cv-235-JAR, 2025 WL 3012828, at *1 (E.D. Okla. Oct. 22, 2025).
Authorities cited in the passage: Appellant's brief attributes a sentence to Town of Smithfield v. Fanning · Town of Smithfield v. Fanning · Duffy v. Milder · Mattox v. Product Innovations Research