Courts on AI / Fabricated or misquoted citations
Suiter v. GM - General Motors, LLC
United States District Court for the Western District of Virginia · Federal district courts · VA · · No. Case 5:24-cv-00054-JHY-JCH · report and recommendation
Western District of Virginia on 2026-03-12 in Suiter v. GM - General Motors, LLC found the self-represented party's brief contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.
- Disposition
- The court warned the self-represented party to verify legal authorities before future filings.
- Recorded conduct
- The self-represented party's brief contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. — outcome: warning; actor: litigant in person
- 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.
along with many other cases cited in Suiter’s filings—are mischaracterized. Suiter includes numerous quotes that do not exist in the cited cases, and his briefs contain characteristics that the court has observed in filings made with generative artificial intelligence programs. Regardless of whether Suiter used these tools, submitting a filing containing fabricated authority or nonexistent quotes is unacceptable and “causes an enormous waste of judicial resources.” Powhatan Cnty. Sch. Bd. v. Skinger, No. 3:24-cv-00874, 2025 WL 1559593, at *10 (E.D. Va. June 2, 2025). Such a filing could also constitute a violation of Federal Rule of Civil Procedure 11, for which the court may impose sanctions. See Fed. R. Civ. P. 11(b)–(c). The court is sympathetic to the challenges associated with navigating the court system as a pro se litigant and concludes that a warning is appropriate at this time. However, Suiter is advised that if any of his future filings fabricate or misrepresent authorities, the court may order him to show cause why he should not face sanctions under Rule 11. See Fed. R. Civ. P. 11(c)(3). Sanctions could include the striking of filings, filing restrictions, monetary penalties, or the dismissal of his action. Overall, Suiter does not offer any legal authority requiring the tolling or restarting of a manufacturer’s warranty period simply because a vehicle is sold as
Authorities cited in the passage: Powhatan Cnty. Sch. Bd. v. Skinger, No. 3:24-cv-00874, 2025 WL 1559593 · Fed. R. Civ. P. 11(b) · Fed. R. Civ. P. 11(c)(3) · Rule 11