Courts on AI / Fabricated or misquoted citations

Primerica Life Insurance Co. v. Finlayson

United States District Court for the District of Utah · Federal district courts · UT · 2026-04-22 · No. No. 2:24-cv-00779-AMA-DBP · memorandum opinion

Fabricated or misquoted citations

The District of Utah on 2026-04-22 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson. Counsel filed an opposition with one fabricated case citation and one false case quotation.

Disposition: Johnson’s motion for leave to file an amended opposition was denied, and Finlayson’s summary-judgment motion was granted in part and denied in part.
Recorded conduct: Ms. Johnson’s counsel filed an initial opposition riddled with case citations and quotations the court could not locate on Westlaw; counsel could not provide copies when requested and later sought to replace the filing with different case law. — 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.

46 Significantly, here, Ms. Johnson’s request is not premised on the need to respond to newly-raised issues or to proffer newly-discovered evidence. As Mr. Finlayson has suggested, it appears that the initial Opposition may have resulted from the improper use of artificial intelligence (“AI”). Ms. Johnson’s initial Opposition was riddled with case citations and quotations that the Court was unable to locate on Westlaw. 47 Ms. Johnson’s counsel was unable to provide copies of the cases at issue upon the Court’s request and sought instead to file more than six months after filing the initial Opposition an amended Opposition supported by different case law—case law that was available at the time of the initial Opposition’s filing. The amended Opposition is also supported by evidence that had not before been proffered, yet there is no argument provided that this evidence was not available when the initial Opposition was filed.

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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