Courts on AI / Fabricated or misquoted citations
Williams v. Dallas-Fort Worth International Airport Board
United States District Court for the Northern District of Texas · Federal district courts · TX · · No. 4:26-cv-00433-P · memorandum opinion
The Northern District of Texas dismisses Williams’s Section 1983 claims and warns that plaintiffs’ qualified-immunity briefing relied on nonexistent or inapposite cases. The court identifies Dawkins, Iko and Yates problems and cautions that generative-AI misrepresentations of law may trigger Rule 11 sanctions.
- Disposition
- The court granted dismissal of the Section 1983 claims with prejudice and dismissed state-law claims without prejudice.
- Recorded conduct
- Plaintiffs cited nonexistent or misidentified cases, including Dawkins, Iko and Yates, to oppose qualified immunity. — 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.
This cannot be undertaken at too broad a level of generality, id., and it certainly cannot be established by citation to nonexistent cases. Here, Plaintiffs make a borderline sanctionable attempt to identify “clearly established” law from five cases. ECF No. 18. Three of these cases—Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997), Yates v. Terry, 817 F.3d 877 (4th Cir. 2016), and Dawkins v. Fields 354 F.3d 392 (5th Cir. 2003)—are either non-existent or mistakenly out-of-circuit and, in any event, inapposite. With respect to Dawkins, this Court cannot even find a case purporting to “clearly establish” law on the matter and wastes its limited judicial resources in doing so. ... The Court cautions that use of generative artificial intelligence that results in repeated misrepresentations of law may qualify for sanctions under Fed. R. Civ. P. 11(b)–(c).
Authorities cited in the passage: Joseph ex rel. Estate of Joseph v. Bartlett, 981 F.3d 319 (5th Cir. 2020) · Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997) · Yates v. Terry, 817 F.3d 877 (4th Cir. 2016) · Dawkins v. Fields, 354 F.3d 392 (5th Cir. 2003) · Fed. R. Civ. P. 11(b)-(c) · Fletcher v. Experian Info. Sols., Inc., 168 F.4th 231 (2026)
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
Hugging Face