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Courts on AI / Fabricated or misquoted citations

Kenneth Hawkins v. I.C. System, Inc.

United States District Court for the Southern District of Texas · Federal district courts · TX · · 2026 WL 497165 · No. Civil Action No. 4:25-CV-2194 · report and recommendation

Southern District of Texas on 2026-02-23 in Kenneth Hawkins v. I.C. System, Inc. found the self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. 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 one citation defect involving nonexistent authorities, incorrect statutory or rule text. — 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.

“By presenting to the court a ... written motion ... an attorney or unrepresented party certifies that to the best of that person's knowledge, information, and belief, formed after an inquiry reasonable under circumstances the ... legal contentions are warranted by existing law.” FED R. CIV. P. 11(b)(2) (emphases added). Providing these nonexistent citations wastes this Court's and counsel's time. Plaintiff is cautioned that Rule 11's obligations and consequences—up to an including stricken filings or monetary sanctions—apply to all who present writings to the Court, including those appearing pro se. Fletcher v. Experian Info. Sols., Inc., No. 25-20086, 2026 WL 456842, at *5–6 (5th Cir. Feb. 18, 2026) (discussing the appropriateness of sanctions for “hallucinated” cases); Vargas v. Salazar, No. 4:23-CV-04267, 2024 WL 4804091, at *3 (S.D. Tex. Nov. 1, 2024) (noting that future presentation “of pleadings or motions that contain ‘made up’ citations” could subject the pro se plaintiff to sanctions), adopted, No. 4:23CV4267, 2024 WL 4804065 (S.D. Tex. Nov. 15, 2024). 11 Plaintiff filed his original state court petition on April 3, 2025. ECF No. 1-4 at 2–8. He then filed an amended state court petition on April 26, 2025. Id. at 13–19. After this case was removed to federal court, he filed the operative complaint on May 20, 2025, styled “First Amended Complaint,” even though it is his second amendment to his pleadings. ECF No. 3.

Authorities cited in the passage: made up · Fletcher v. Experian Info. Sols · Vargas v. Salazar, No. 4:23-CV-04267, 2024 WL 4804091 · Rule 11

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