Courts on AI / Fabricated or misquoted citations

Reynolds v. Progressive Technologies, Inc.

United States District Court for the Western District of Tennessee · Federal district courts · TN · 2026-03-30 · No. 2:25-cv-02529-TLP-atc · order

Fabricated or misquoted citationscourt does not name AI

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 adopted the report and recommendation, dismissed the FMLA, EFTA, FLSA and § 1983 claims with prejudice, allowed the § 1981, FHA and contract-based claims to proceed, and warned plaintiff that further fabricated authority could lead to dismissal without further warning.
Recorded conduct: Plaintiff repeatedly cited fake authority; all cases he cited for the proposition that courts routinely strike or disregard overlength briefs filed without leave were fake, misattributed to different courts, or did not support the proposition. — 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

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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