Courts on AI / Fabricated or misquoted citations
Hartmann v. Davidson
United States District Court for the Northern District of Texas · Federal district courts · TX · · No. 3:24-cv-02317-BT · memorandum opinion
Northern District of Texas on 2026-03-12 in Hartmann v. Davidson found the self-represented party's brief contained one citation defect involving incorrect statutory or rule text. The court dismissed claims or denied relief after identifying the defective authorities in the challenged filing before resolving the pending matter.
- Disposition
- The court granted USCIS's motion to dismiss without prejudice and terminated Hartmann's motion to supplement as moot.
- Recorded conduct
- Hartmann disclosed using generative AI and cited authorities that did not support the propositions for which he offered them in opposing dismissal. — outcome: noted, no consequence; 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.
2 The inaccuracies in Hartmann’s brief are typical of unverified, AI-generated filings, which have become an increasing concern for courts in recent years. While no federal or local rule explicitly prohibits the use of artificial intelligence in litigation, and Hartmann disclosed his use of generative AI in preparing his brief, see Pl.’s Resp. at 1 (acknowledging that Hartmann “used generative AI”), all parties—including those proceeding pro se—must fulfill their obligations under Federal Rule of Civil Procedure 11(b), which requires lawyers and unrepresented parties alike to certify that, after a reasonable inquiry, their legal contentions are warranted by existing law. Consequently, this duty necessitates a careful review of AI-generated statements and citations to ensure accuracy. 8 Case 3:24-cv-02317-BT Document 47 Filed 03/12/26 Page 9 of 15 PageID 2735 decision not to renew his employment contract. Board of Regents v. Roth, 408
Authorities cited in the passage: Page 9 of 15 PageID 2735 decision not to renew his employment contract. Board of Regents v. Roth
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