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Courts on AI / Fabricated or misquoted citations

Nicholas and Barbara Moulder v. Davis School District (on behalf of M.M.)

U.S. District Court for the District of Utah · Federal district courts · UT · · No. 1:25-CV-00052-TS-CMR · memorandum opinion

On 2026-03-23, U.S. District Court for the District of Utah required AI-related CLE and payment of $1,525.50 already agreed to reimburse fees for two nonexistent cases and a nonexistent quotation. Counsel submitted a brief with two false quotations and fabricated or nonexistent authorities.

Disposition
The court required AI-related CLE and payment of $1,525.50 already agreed to reimburse fees for two nonexistent cases and a nonexistent quotation.
Recorded conduct
The brief used two false quotations and fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — outcome: sanctions; actor: lawyer; $1,525
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.

on an Order to Show Cause1 after Defendants’ counsel discovered two non-existent cases and one non-existent quote cited in Plaintiffs’ briefing. Prior to hearing, the Court also ordered Defendants’ counsel to provide an estimate of the legal expenses incurred in responding to the Order to Show Cause. Defendants’ counsel informed the Court that, after initially discovering the non-existent cases, they reached an agreement with Plaintiffs’ counsel whereby Mr. Ares and Ms. Martz agreed to reimburse $1,525.50 in legal fees to resolve the issue.2 However, since then, Defendants’ counsel assert that they incurred an additional $5,568.50 in legal expenses related to the Order to Show Cause.3 Docket No. 54 (the Court ordered Plaintiffs’ counsel to show cause as to why they should not be sanctioned pursuant to Fed. R. Civ P. 11(c) for violation of Rule 11(b)). Docket No. 64, at 2. Id. of 4 At the hearing, Plaintiffs’ counsel admitted to using Artificial Intelligence (AI) in preparing their arguments and that each failed to independently verify the existence and accuracy of the two non-existent cases. Plaintiffs’ counsel accepted full responsibility for their lack of oversight and conceded their actions fell

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