Courts on AI / Fabricated or misquoted citations
Edward Reynolds v. Progressive Technologies, Inc.
U.S. District Court for the Western District of Tennessee · Federal district courts · TN · · No. 15-2472 · report and recommendation
On 2026-03-30, U.S. District Court for the Western District of Tennessee affirmed the magistrate judge’s order and warned that continued fabricated authority could result in dismissal without further warning. A self-represented party submitted a brief with multiple fabricated or nonexistent authorities.
- Disposition
- The court affirmed the magistrate judge’s order and warned that continued fabricated authority could result in dismissal without further warning.
- Recorded conduct
- The brief used multiple fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — 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.
routinely strike or disregard overlength briefs filed without leave” are fake ones. (See ECF No. 26 at PageID 272.) The cases either do not exist, or they exist but are not decisions from the courts Plaintiff cites. Nor do the cases stand for the proposition Plaintiff asserts. Judge Christoff exercised her discretion with marked restraint. Because Plaintiff has repeatedly cited fake authority, this Court would be justified in dismissing his case. But the Court will give Plaintiff one more chance to show that he is able to follow the law. As Judge Christoff ordered, Plaintiff must review his citations for accuracy going forward. The Court warns Plaintiff if he continues to cite fabricated legal authority, the Court may dismiss his entire case without any further warning. (ECF No. 54 at PageID 930.) Because the Court finds no legal error in Judge Christoff’s decision, it AFFIRMS her Order and next considers the R&R. PageID 964 II. The R&R Having reviewed the record, the Court finds no clear error in Judge Christoff’s R&R. In fact, the Court agrees with her well-reasoned analysis. A. FMLA Claims Plaintiff brings claims for entitlement and retaliation
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