Courts on AI / Fabricated or misquoted citations

McCormick v. Texakoma Financial

United States District Court for the Eastern District of Texas · Federal district courts · TX · 2026-06-11 · 2026 WL 1746259 · No. 4:25-cv-773 · order

Fabricated or misquoted citationsGAI

On 2026-06-11, in McCormick v. Texakoma Financial, the Eastern District of Texas publicly reprimanded plaintiff's counsel, imposed $6,000 in sanctions, ordered firmwide citation review, and required AI-focused CLE. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Disposition: The court publicly reprimanded plaintiff's counsel, imposed $6,000 in sanctions, ordered firmwide citation review, and required AI-focused CLE.
Recorded conduct: Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support. — outcome: sanctions; actor: lawyer; $6,000
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.

The Reply also flagged fake quotes and unsupported propositions. Ginsburg did not file a sur-reply or move to remedy this problem. The Order to Show Cause. After reviewing the veracity of Defendant's claim that Ginsburg submitted a brief with fraudulent citations, the Court issued an order to show cause on May 15, 2026 (Dkt. #23). The order identified the suspect citations and ordered Ginsburg to appear in person on May 28, 2026, at 10:00 a.m., to explain why she should not be sanctioned. The Court also ordered Ginsburg to bring highlighted copies of the cases she cited. TheResponsetotheOrdertoShowCause.OnMay28,2026, less than one hour before the show cause hearing, Ginsburg filed a response to the order to show cause (Dkt. #24) (the “OrdertoShowCauseResponse”).AtthestartofherOrderto Show Cause Response, Ginsburg represented that she wanted “to explain how the filing occurred, correct the erroneous [fictitious] Noviello citation, and accept responsibility for the failure to verify the final version had been filed” (Dkt. #24 at p. 1).

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.

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