Courts on AI / Fabricated or misquoted citations
Harding Place Multifamily Partners v. Robinson
Court of Appeals of Tennessee · State appellate courts · TN · · No. M2025-01361-COA-R3-CV · opinion
The Tennessee Court of Appeals affirms a landlord-tenant judgment and disregards fabricated or inaccurate parts of Samuel Robinson’s pro se brief. The opinion says the brief bears AI hallmarks, identifies false case and statutory quotations, a fabricated Tennessee Supreme Court case, and unsupported legal assertions.
- Disposition
- The court disregarded inaccurate or fabricated portions of Robinson's brief and affirmed the trial court's judgment.
- Recorded conduct
- Self-represented appellant filed a brief with false case and statutory quotations, a fabricated Tennessee Supreme Court citation, and misleading reporter citations. — outcome: other; 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.
Unfortunately, Mr. Robinson’s brief fails to comply with this rule as it contains numerous false quotations from case law and statutes and, in some instances, outright fake citations. In this way, Mr. Robinson’s brief bears all the hallmarks of an artificial intelligence-generated brief, filled with what has been referred to as “hallucinations.” ... Mr. Robinson’s brief contains all of these forms of hallucinations. For instance, Mr. Robinson cites to “First Tenn. Bank Nat’l Ass’n v. McClure, 199 S.W.3d 429, 432 (Tenn. Ct. App. 2005).” While there is a real case under that name, it is not reported in the South Western Reporter. The citation given actually leads to the dissent of a case from the Court of Appeals of Texas, City of Seabrook v. Port of Houston Auth., 199 S.W.3d 403 (Tex. App. 2006). Further, the real McClure case is not from 2005 but from 1990. ... This issue of AI hallucinations is prevalent in Mr. Robinson’s statutory citations as well. His brief quotes Tenn. Code Ann. § 66-28-304(a) as “A landlord shall: . . . (4) Maintain in good and safe working order and condition all electrical, plumbing, sanitary, heating, ventilating air-conditioning and other facilities and appliances supplied or required to be supplied by the landlord.” ... However, that section of the code, Tenn. Code Ann. § 66-28-304(a)(4), actually states: “In multi-unit complexes of four (4) or more units, provide and maintain appropriate receptacles and conveniences for the removal of ashes, garbage, rubbish and other waste from common points of collection subject to § 66-28-401(3),” language which is certainly less helpful to Mr. Robinson’s position. Further still, some cases appear to be fabricated entirely as Mr. Robinson cites to “Puckett v. Estate of Puckett, 174 S.W.3d 252, 257 (Tenn. 2005).” The given location in the reporter is actually for the Court of Appeals case Emmit v. Emmit, 174 S.W.3d 248 (Tenn. Ct. App. 2005), and we are unable to find any Tennessee Supreme Court case under the cited case name. ... Because of the inaccurate citations to law, Mr. Robinson’s arguments are not “warranted by existing law,” as required by Tenn. Ct. App. R. 17.01. ... Therefore, we believe the best course is to disregard the citations in Mr. Robinson’s brief that do not accurately reflect what the authority states and address the arguments without consideration of fictitious or meritless arguments.
Authorities cited in the passage: Tenn. Ct. App. R. 17.01 · Simmons v. Islam, 2026 WL 1431143 (Tenn. Ct. App. May 21, 2026) · Andre v. Warden, FCI Danbury, 827 F. Supp. 3d 294 (D. Conn. 2025) · First Tenn. Bank Nat'l Ass'n v. McClure, 199 S.W.3d 429 (Tenn. Ct. App. 2005) · Tenn. Code Ann. § 66-28-304(a) · Puckett v. Estate of Puckett, 174 S.W.3d 252 (Tenn. 2005) · Akerlund v. Atlas Air, Inc., 2026 WL 1993146 (11th Cir. July 10, 2026)