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Courts on AI / Fabricated or misquoted citations

Moore v. Wireless CCTV LLC

United States District Court for the Southern District of Texas · Federal district courts · TX · · No. H-25-5476 · memorandum opinion

The Southern District of Texas on 2026-04-27 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Moore v. Wireless CCTV LLC. The self-represented party filed a pleading with two fabricated case citations, including Thomas v. City of San Marcos.

Disposition
The motion to dismiss was granted with one final opportunity to amend, and Moore was warned about AI-generated nonexistent cases.
Recorded conduct
Moore’s pro se pleadings cited nonexistent Thomas v. City of San Marcos and Cole v. Sandler authorities that the court found likely indicated AI use. The court warned her under Rule 11. — 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.

14, 2020). private cause of action; that claim is dismissed, with prejudice, because amendment would be futile. Moore has one final opportunity to amend and must do so no later than May 15, 2026. 8 SIGNED on April 27, 2026, at Houston, Texas. ________________________________ Lee H. Rosenthal Senior United States District Judge Wireless also asserts that Moore’s pleadings indicate the use of generative AI and point out cases she cites that do not exist. (Docket Entry No. 10 at 20). The court has checked those citations (see, e. g. , Docket Entry No. 7 at 2 (citing “Thomas v. City of San Marcos (W. D.

Authorities cited in the passage: Thomas v. City of San Marcos · Pleading cited 'Thomas v. City of San Marcos · Pleading cited 'Cole v. Sandler, 2014 WL 266501 (E.D. La.)' · Cole v. Hunter

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