Courts on AI / Fabricated or misquoted citations
Regan Wilkes v. Canyons School District
United States District Court for the District of Utah · Federal district courts · UT · · No. 2:25-cv-00218-CMR · order
The District of Utah on 2026-05-04 imposed Rule 11 sanctions and ordered plaintiffs’ counsel to pay defendants $7,000 for expenses caused by non-existent case law in Regan Wilkes, et al. v. Canyons School District, et al. Counsel filed an opposition with three fabricated case citations and one mischaracterized case citation, including A.S. v. Norwalk Public Schools.
- Disposition
- The court found a Rule 11 violation and ordered plaintiffs’ counsel to pay $7,000 in attorney fees to defendants.
- Recorded conduct
- Plaintiffs’ counsel admitted using AI to polish briefing, which distorted authority and produced nonexistent IDEA cases. The court imposed a $7,000 attorney-fee sanction payable to defendants. — outcome: costs order; actor: lawyer; $7,000
- 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.
...counsel for Defendants were present (ECF 42). After consideration of all the arguments, the court rules as follows: I. Rule 11 Violation and Sanction. During the April 14, 2026, Order to Show Cause Hearing, the court heard from Plaintiffs’ counsel regarding the use of non-existent case law. While Plaintiffs’ counsel admitted that Artificial Intelligence (AI) was used, they asserted that it was only used to polish/refine the original writing of the attorneys. They claimed that their original writing included the correct/real case names, but that when the writing was put into the AI software to polish the writing, it must have, Case 2:25-cv-00218-CMR Document 45 Filed 05/04/26 PageID.850 Page 2 of 6 for reasons unknown to counsel, distorted the cases. In support, Plaintiffs filed a Response to Orde...
Authorities cited in the passage: Amended Complaint cited a non-existent 'A.S. v. Norwalk Public Schools · J.M. v. Francis Howell School District · Amended Complaint cited a non-existent 'F.C. v. Capistrano Unified School District' · Amended Complaint cited a non-existent 'A.D. v. Puyallup School District No. 3, 2015' (purported 4th Cir.) to support statute-of-limitations arguments
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