Courts on AI / Fabricated or misquoted citations
Pate v. CMG Mortgage, Inc.
United States District Court for the Eastern District of Tennessee · Federal district courts · TN · · No. 1:25-cv-349 · memorandum opinion
The Eastern District of Tennessee on 2026-04-28 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Pate v. CMG Mortgage, Inc., et al. The self-represented plaintiff filed a submission with two fabricated case citations.
- Disposition
- Defendants’ motion to dismiss was granted, the amended complaint was dismissed with prejudice, and plaintiffs were reminded to verify citations.
- Recorded conduct
- The Pates’ filings cited cases that did not exist as cited, including Pope v. Redwing and First National Bank of Louisville v. Brooks Farms. The court declined sanctions but reminded them of Rule 11 and citation-verification obligations. — 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.
Brooks Farms, LLC, 624 S. W. 3d 601 (Tenn. Ct. App. 2020). ” (See Doc. 31, at 3 n. 1; Doc. 35, at 4. ) Plaintiffs have filed a notice of errata acknowledging some of these errors. (Doc. 36. ) The Court does not find it necessary to address sanctions at this time, but Plaintiffs are reminded that Federal Rule of Civil Procedure 11 applies to pro se litigants and that citation to non-existent authority undermines the credibility of otherwise legitimate arguments. The Court encourages Plaintiffs, should they seek legal counsel in any future proceedings, to ensure that any legal citations are carefully verified. PageID #: 330
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
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