Courts on AI / Fabricated or misquoted citations
Cain v. Hyatt Corporation
United States District Court for the Western District of Texas · Federal district courts · TX · · No. 1:25-cv-02053-ADA-SH · order
The Western District of Texas issues a show-cause order in Cain v. Hyatt. The order says plaintiffs cited nonexistent Henry v. Kroger authority in a dismissal response and requires attorney Daniel Miguel Hernandez to appear under Rule 11(c)(3).
- Disposition
- The court ordered plaintiffs' counsel Daniel Miguel Hernandez to appear and show cause under Rule 11.
- Recorded conduct
- Plaintiffs’ response cited nonexistent Henry v. Kroger Co. authority in opposing partial dismissal. — outcome: pending; 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.
Plaintiffs cited nonexistent case Henry v. Kroger Co., No. 4:19-cv-00630, 2019 WL 6311295 (E.D. Tex. Nov. 25, 2019), in their Response to Defendant’s Motion for Partial Dismissal. Dkt. 9 at 7. Under Rule 11(b), an attorney certifies that legal citations in papers presented to the Court are correct “to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances.” Plaintiffs’ counsel are “duty-bound to check and certify that all factual contentions and statements of law are warranted and nonfrivolous.” Duncan v. Gridhawk, LLC, No. MO:25-CV-00394-DC, 2025 WL 3515411, at *2 (W.D. Tex. Dec. 6, 2025). The Court held a hearing on July 29, 2026, during which Plaintiffs’ counsel Lino Ochoa represented that he did not prepare or review the response before it was filed. The Court ORDERS Plaintiffs’ other attorney of record, Daniel Miguel Hernandez, to appear and show cause under Rule 11(c)(3) why the conduct described in this Order has not violated Rule 11(b) at 2 p.m. Wednesday, August 19, 2026 in Courtroom 6 on the Sixth Floor of the United States Courthouse, 501 W. 5th Street, Austin, Texas 78701.
Authorities cited in the passage: Henry v. Kroger Co., No. 4:19-cv-00630, 2019 WL 6311295 · Fed. R. Civ. P. 11 · Duncan v. Gridhawk, LLC, No. MO:25-CV-00394-DC, 2025 WL 3515411 (W.D. Tex. Dec. 6, 2025)