Courts on AI / Fabricated or misquoted citations

McCormick v. Texakoma Financial, Inc.

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 citations Competence, fees and billing

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 counsel, struck the summary-judgment response, imposed review/CLE/certification requirements, authorized a fee motion, and ordered a $5,000 penalty to the court registry.
Recorded conduct: Attorney Amy Ginsburg signed a summary-judgment response with one fictitious Noviello case, two fake quotations attributed to real cases, and unsupported propositions. She blamed an intern/law clerk and a paralegal, but the court found the explanation not credible. — outcome: fine; actor: lawyer; $5,000
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.

This case presents yet another example of false legal citations caused by reliance on generative artificial intelligence (“AI”). ... the Court will issue sanctions against Plaintiff’s counsel, Amy L.B. Ginsburg.

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
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 Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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