Courts on AI / Fabricated or misquoted citations

Reaves Law Firm, PLLC v. Baker Donelson

United States District Court for the Western District of Tennessee · Federal district courts · TN · 2026-06-02 · No. 2:25-cv-2623 · order

Fabricated or misquoted citations Competence, fees and billing

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 imposed Rule 11 sanctions requiring reimbursement of defendants’ costs for AI-related briefing, required filing-review and client-notice obligations, forwarded the order to the Tennessee Board of Professional Responsibility, and warned the firm.
Recorded conduct: Reaves Law Firm filings contained non-existent cases, false quotations, and unsupported holdings despite notice of suspected generative-AI misuse. The court ordered fee reimbursement in an amount to be determined and referred the order to the Tennessee Board of Professional Responsibility. — outcome: regulatory referral; actor: firm
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.

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: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. 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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