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Courts on AI / Fabricated or misquoted citations

Wells Fargo Bank v. Frances W. Dean

United States District Court for the Eastern District of Texas · Federal district courts · TX · · 2026 WL 555590 · No. NO. 4:25-CV-00263-ALM-BD · report and recommendation

Eastern District of Texas on 2026-02-24 in Wells Fargo Bank v. Frances W. Dean found the self-represented party's motion contained four citation defects involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's motion contained four citation defects involving nonexistent authorities, mischaracterized authority. — 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.

(W.D. Tex. Oct. 19, 2009). 618, 621 (5th Cir. 1985). The decision to grant or deny an injunction lies within the court's discretion. Id. II. Dean's Reliance on Nonexistent Citations Dean cites several cases, or purported cases, in her DISCUSSION motion and reply. Two of them—American Residential Services of Texas, LP v. Jimenez, 446 S.W.3d 649, 652–53 I. Lack of Entitlement to an Injunction (Tex. App.—Houston [1st Dist.] 2014), and Holub v. FDIC, Dean does not specify whether she is seeking a preliminary 159 B.R. 782, 789 (S.D. Tex. 1993)—do not exist. Others do injunction or a TRO. But she has not shown an entitlement not stand for the cited proposition. City of Austin v. Houston to either. Lighting & Power Co., 844 S.W.2d 773 (Tex. App.—Dallas 1992, writ denied), was decided by a different court than she Dean argues that she has established an imminent risk of says it was. And she failed to note that Glade v. Dietert, 286 irreparable harm because there is an ongoing risk that the S.W.2d 955 (Tex. App.—Fort Worth 1956), was reversed by bank, through its agents, will lock her out of the property the Supreme Court of Texas, Glade v. Dietert, 295 S.W.2d 642 again and that another violent incident will occur. Dkt. 23 (Tex. 1956). at 3. In some cases, repeated trespasses to land will warrant injunctive relief if they are “continuous such that stopping The court suspects that those errors stem from the use [them] would require a multiplicity of suits.” Texas v. DHS, of generative artificial intelligence. See Margie Alsbrook, 123 F.4th 186, 212 (5th Cir. 2024). But a trespass to land is Untangling Unreliable Citations, 37 Geo. J. L. Ethics 415, ordinarily compensable by damages. Stevenson v. E.I. DuPont 446–47 (2024). That has become a regrettably common De Nemours & Co., 327 F.3d 400, 408 (5th Cir. 2003). That problem, wasting party and court resources alike. E.g., Wilt v. Whitehouse Police Dep't, No. 6:25-cv-00117-JCB-JDL, 2025

Authorities cited in the passage: LP v. Jimenez · Holub v. FDIC · Others do injunction or a TRO. But she has not shown an entitlement not stand for the cited proposition. City of Austin v. Houston to either. Lighting & Power Co · Dean argues that she has established an imminent risk of says it was. And she failed to note that Glade v. Dietert · Glade v. Dietert · Texas v. DHS · Stevenson v. E.I. DuPont 446 · Wilt v. Whitehouse Police Dep't, No. 6:25-cv-00117-JCB-JDL, 2025 · B.R. 782

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