Courts on AI / Fabricated or misquoted citations

Garcia Perez v. Blanche

United States District Court for the Western District of Texas · Federal district courts · TX · 2026-08-18 · No. 1:26-cv-00786-RP · order

Fabricated or misquoted citations

The Western District of Texas orders more briefing in a habeas case and cautions Gilberto Garcia Perez’s counsel. The order says most cases cited in petitioner’s reply do not exist, lists six hallucinated authorities including one purportedly from the same court, and warns future inaccurate AI citations may be sanctionable.

Disposition: The court ordered additional briefing and cautioned petitioner's counsel that future hallucinated citations may result in sanctions.
Recorded conduct: Petitioner’s counsel cited multiple nonexistent immigration cases in reply, including a fabricated decision purportedly issued by the same district court. — 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.

He then cites a variety of cases supporting this contention, the majority of which do not exist.4 The Court will nonetheless consider Petitioner’s due process argument, as it will not punish Petitioner for his counsel’s mistakes. ... The Court notes that an alarming number of cases cited by Petitioner for support in his Reply are nonexistent, “hallucinated” cases, such as Kostak v. Garland, No. 24-cv-11024-ADB, 2025 WL 2472136, at *4–6 (D. Mass. May 22, 2025); Martinez Lopez v. Garland, No. 1:25-cv-00069, 2026 WL 1200000, at *4–5 (D. Colo. Mar. 24, 2026); Cruz-Reyes v. Decker, No. 1:25-cv-01719-MKV, 2025 WL 332315, at *4–6 (S.D.N.Y. Jan. 21, 2025); Castanon Nava v. Garland, No. 2:25-cv-01308-JHC, 2026 WL 1234567, at *5–7 (W.D. Wash. Feb. 11, 2026); Duarte Escobar v. Garland, No. 1:25-cv-00963-MSN-LRV, 2025 WL 7061234, at *2–4 (E.D. Va. Dec. 2, 2025). ... None of these cases exist on Westlaw or on the purported courts’ dockets. Indeed, Petitioner also hallucinates a case purportedly written by this Court: Garcia v. Mullin, No. 1:25-cv-00836-RP, 2026 WL 1045678, at *2–4 (W.D. Tex. Mar. 9, 2026). Petitioner’s counsel is strongly cautioned that future inaccurate citations “hallucinated” by generative artificial intelligence tools may result in sanctions.

Authorities cited in the passage: Kostak v. Garland, 2025 WL 2472136 (D. Mass. May 22, 2025) · Martinez Lopez v. Garland, 2026 WL 1200000 (D. Colo. Mar. 24, 2026) · Cruz-Reyes v. Decker, 2025 WL 332315 (S.D.N.Y. Jan. 21, 2025) · Castanon Nava v. Garland, 2026 WL 1234567 (W.D. Wash. Feb. 11, 2026) · Duarte Escobar v. Garland, 2025 WL 7061234 (E.D. Va. Dec. 2, 2025) · Garcia v. Mullin, 2026 WL 1045678 (W.D. Tex. Mar. 9, 2026) · Fed. R. Civ. P. 11(b)

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Official source not obtained after CourtListener throttling; read the court-authored document from the Charlotin mirror and marked link-only.

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