Courts on AI / Fabricated or misquoted citations

Bailey v. Sedgwick Claims Management Services, Inc.

United States District Court for the Western District of Tennessee · Federal district courts · TN · 2026-06-08 · No. 2:24-cv-02749-TLP-tmp · order

Fabricated or misquoted citationsGAI

On 2026-06-08, in Bailey v. Sedgwick Claims Management Services, Inc, the Western District of Tennessee required a corrected motion after counsel disclosed AI-hallucinated citations, but declined to impose sanctions at that point. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

Disposition: The court required a corrected motion after counsel disclosed AI-hallucinated citations, but declined to impose sanctions at that point.
Recorded conduct: Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities. — 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.

Apparently that AI program hallucinated over some citations. As a result, the Court required Plaintiff’s counsel to correct the citations and submit a Corrected Motion. They did so. (ECF No. 94.) The Sixth Circuit has recently addressed the role of AI in the realm of litigation. That court imposed significant sanctions and pointed out that lawyers cannot outsource their ethical obligations to an AI program. In fact, the Sixth Circuit has sanctioned lawyers for doing just that. In United States v. Farris, the court noted the “baseline ethical obligations as they relate to the use of artificial intelligence.” 171 F.4th 920, 922 (6th Cir. 2026). Even though this new technology holds great potential, the court explained that “all in the legal profession must be clear eyed PageID 1120 Agreement so that they can send notice to the Settlement Class.2 (ECF No.

Authorities cited in the passage: In United States v. Farris

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.

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