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Courts on AI / Fabricated or misquoted citations

Moore v. Aldridge Pite LLP

United States District Court for the Western District of Texas · Federal district courts · TX · · No. MO:25-CV-00326-DC · order

The Western District of Texas adopts an R&R and dismisses the remaining defendant without prejudice. The order catalogs repeated invented quotations, unsupported case descriptions, and possible AI use, then warns the self-represented plaintiffs to verify all authorities and quotations in future filings.

Disposition
The court dismissed the final remaining claims without prejudice and expressly warned plaintiffs about future Rule 11 compliance.
Recorded conduct
Self-represented plaintiffs repeatedly filed invented quotations, unsupported case descriptions, and legal misstatements after prior warnings. — 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.

They are the latest installment in a sustained series of filings marked by misstatements of law, mischaracterizations of the record, fabricated quotations, and demands untethered to any rule of procedure. ... Although Plaintiffs certified that they verified each citation contained in those objections (Doc. 76 at 26), the Court identified multiple instances in which Plaintiff attributed propositions to cases that did not support them. ... That motion attributed purported quotations to multiple judicial decisions in which the quoted language does not appear. It also included several misstatements of law and case holdings. ... This conduct is unacceptable. When a litigant places quotation marks around words and attributes those words to a judicial decision, they represent to the Court that the decision contains those words. When the decision does not, the filing misleads the Court. Repeatedly presenting invented quotations and inaccurate descriptions of authority consumes scarce judicial resources, burdens opposing parties, and undermines the adjudicative process. ... Whether those defects in Plaintiffs’ submissions were generated by artificial intelligence, copied from an unreliable source, or created by Plaintiffs themselves is immaterial. A litigant may use whatever tools it chooses, but it may not file misleading legal arguments. ... The Court declines at this time to initiate sanctions proceedings or impose filing restrictions. However, Plaintiffs are expressly WARNED that every future submission to this Court must comply fully with Federal Rule of Civil Procedure 11. Before filing any paper, Plaintiffs must personally verify that every cited authority exists, that every quotation appears in the cited source, that every description of the record is accurate, and that every legal contention is warranted by existing law or a nonfrivolous argument for changing it.

Authorities cited in the passage: Fed. R. Civ. P. 11

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