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Courts on AI / Fabricated or misquoted citations

Transcontinental Realty Investors, Inc. v. Moos

United States District Court for the Northern District of Texas · Federal district courts · TX · · No. 3:26-CV-694-O-BW · memorandum opinion

The Northern District of Texas denies disqualification motions in a commercial dispute. The opinion notes briefing problems, including one nonexistent Northern District citation likely caused by imprudent generative-AI reliance, and admonishes pro hac vice counsel about responsible AI use and Rule 11 obligations.

Disposition
The court denied the motions to disqualify Johansen and Blank Rome and admonished pro hac vice counsel about AI-related citation duties.
Recorded conduct
Pro hac vice counsel signed briefing citing a nonexistent N.D. Texas Aetna decision; only an unrelated D.N.J. case by that name existed. — outcome: warning; actor: lawyer
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 filings in this case are riddled with inaccurate citations, seemingly deliberate misrepresentations of guiding caselaw and the factual record, failures to comply with Court rules, and, in at least one instance, advocacy using caselaw that does not exist, likely the result of imprudent reliance on a generative artificial intelligence tool. ... (See Int. Resp. at 14 (citing Aetna Health Inc. v. Health Goals Chiropractic Ctr., Inc., No. 3:12-CV-2587-O, 2012 WL 12873819, at *1 (N.D. Tex. Oct. 25, 2012) (O’Connor, J.))). The Court notes the existence of a case by the same name, Aetna Health Inc. v. Health Goals Chiropractic Center, Inc., No. 10-5216-NLH-JS, 2011 WL 1343047 (D.N.J. Apr. 7, 2011), but that case provides no support for the assertion made in the brief. The Court notes that the attorney who signed the brief, and thus made certain representations under Fed. R. Civ. P. 11(b), is appearing pro hac vice, and it admonishes counsel about the responsible use of generative artificial intelligence in court filings. See Shelton v. Parkland Health, No. 3:24-CV-2190-L-BW, 2025 WL 3141108, at *3 (N.D. Tex. Nov. 10, 2025). ... For the foregoing reasons, Plaintiffs Pillar and TCI’s Motion to Disqualify Johansen and Blank Rome (Dkt. No. 51) and the Liberty Parties’ Motion to Disqualify Johansen and Blank Rome (Dkt. No. 54) are DENIED.

Authorities cited in the passage: Aetna Health Inc. v. Health Goals Chiropractic Ctr., Inc., No. 3:12-CV-2587-O, 2012 WL 12873819 (N.D. Tex. Oct. 25, 2012) · Aetna Health Inc. v. Health Goals Chiropractic Center, Inc., No. 10-5216-NLH-JS, 2011 WL 1343047 (D.N.J. Apr. 7, 2011) · Fed. R. Civ. P. 11(b) · Shelton v. Parkland Health, 2025 WL 3141108 (N.D. Tex. Nov. 10, 2025)

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