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Courts on AI / Fabricated or misquoted citations

Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al.

United States District Court for the Western District of Tennessee · Federal district courts · TN · · No. 2:25-cv-2623-SHL-atc · order

On 2026-06-02, in Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al, the Western District of Tennessee ordered Reaves Law Firm to pay costs for improper citations and directed counsel to send the order to professional regulators. Counsel cited Press v. Vanderbilt University even though the court found the authority did not exist.

Disposition
The court ordered Reaves Law Firm to pay costs for improper citations and directed counsel to send the order to professional regulators.
Recorded conduct
Counsel cited Press v. Vanderbilt University even though the court found the authority did not exist. — outcome: costs order; actor: lawyer; $1
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.

Specifically, Defendants’ response to RLF’s Partial Motion to Dismiss asserts that Plaintiff relies on cases that do not stand for the propositions for which they are cited, and, even worse, RLF includes quotations from those cases that do not exist. (See ECF No. 19.) Two days after Defendants initially raised the GAI issues, RLF filed a response to the Motion for Judgment on the Pleadings. (ECF No. 20.) Then, three days after that, RLF filed a supplemental response. (ECF No. 23.) But, according to Defendants, those two filings contain more of the same issues that surfaced in RLF’s Partial Motion to Dismiss, and Plaintiff “remain(ed) steadfast in it misuse and abuse of GAI” even after being put on notice of the GAI issues. (ECF No. 24 at PageID 316.) For instance, the Response to the Motion for Judgment on the Pleadings cites to numbered paragraphs from RLF’s complaint that do not exist and to facts that the complaint does not allege. (See ECF No.

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