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Courts on AI / Fabricated or misquoted citations

Page v. Apperson Crump, PLC

United States District Court for the Western District of Tennessee · Federal district courts · TN · · No. 1:26-cv-01037-JDB-jay · order

On 2026-03-30, U.S. District Court for the Western District of Tennessee denied the appeal and warned that continued nonexistent, erroneous, or misrepresentative citations after admitted AI drafting could lead to sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities.

Disposition
The court denied Page's objection and appeal, recusal motion, disqualification motion, and stay motion, and warned him that further nonexistent or misrepresentative citations may lead to sanctions.
Recorded conduct
Page's motion for summary reversal relied on three nonexistent, erroneous, or misrepresentative case citations; he admitted using an artificial intelligence tool to draft a substantial portion of the legal documents filed in the appeal and disclosed that the AI assistance caused citation errors. — 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.

DENIED. Lastly, Appellee’s response raises its discovery that Page relied on three nonexistent, erroneous or misrepresentative case citations in his motion for summary reversal. (D.E. 20 at PageID 423 (citing D.E. 11 at PageID 345-46).) The Court’s research confirms Appellee’s report about these citations. In his affidavit, Page addresses these “citation errors,” after admitting that he used “an artificial intelligence tool” to draft “a substantial portion of the legal documents” filed in this appeal. (D.E. 26 at PageID 517.) He states, “I disclose the AI assistance not to excuse the citation errors but to be transparent with this Court about how they occurred and to ensure the record reflects the truth. Every factual assertion in every document I have filed is true to the best PageID 536 of my knowledge.” (Id.) The Court warns Appellant that it may impose sanctions if he continues to submit nonexistent or misrepresentative citations. See Fed. R. Civ. P. 11(b)(2) (“By presenting to the court a pleading, written motion, or other paper . . . an attorney or unrepresented party certifies . . . the claims, defenses, and other legal contentions are warranted by existing

Authorities cited in the passage: Fed. R. Civ. P. 11(b)(2)

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