Courts on AI / Fabricated or misquoted citations
Regan Wilkes, et al. v. Canyons School District, et al.
United States District Court for the District of Utah · Federal district courts · UT · · No. 2:25-cv-00218-CMR · memorandum opinion
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 imposed Rule 11 sanctions and ordered plaintiffs’ counsel to pay defendants $7,000 for expenses caused by non-existent case law.
- Recorded conduct
- Counsel filed an opposition with three fabricated case citations and one mischaracterized case citation, including A.S. v. Norwalk Public Schools and J.M. v. Francis Howell School District. — outcome: fine; 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.
Defendants, during the hearing, asserted that they were wary of Plaintiffs’ explanation, given that the holdings of the “correct” cases were not the holdings that were cited to in the Amended Complaint, and likewise were not cited in Plaintiffs’ Opposition to the Motion to Dismiss. Defendants requested that the court, at a minimum, award attorney fees incurred due to theuseofnon-existentcaselaw. Further,Defendantsrequestedthatthecourt impose,as asanction, a dismissal of the entire Amended Complaint; or, in the alternative, grant partial or full dismissal of the Second Cause of Action as a sanction1 as requested by Defendants in their Motion to Dismiss. The court ordered the parties to meet and confer to determine whether they could stipulate to a monetary amount that Plaintiffs would pay Defendants for the attorney fees incurred.
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