Skip to content

Courts on AI / Fabricated or misquoted citations

Rivard v. Vermont Department of Corrections

Superior Court of Vermont, Windham Unit · State trial courts · VT · · 2026 WL 2479362 · No. 26-CV-01521 · order

The Vermont Superior Court grants Brattleboro’s sanctions motion against Jeffrey Rivard and imposes a civil-division prefiling injunction. The order cites Rivard’s prior non-existent authorities, mismatched Vermont Reports citations, spurious record quotations, and repeated warnings that had not changed his filing conduct.

Disposition
The court granted a sanctions motion and imposed a prefiling injunction in Vermont Superior Court civil cases.
Recorded conduct
Self-represented plaintiff repeatedly cited non-existent Vermont authority, mismatched reporter citations, and spurious quotations from court records. — outcome: sanctions; 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.

Plaintiff has himself been admonished by the Court for citing non-existent authority. In his brief, plaintiff cited several purported decisions of this Court, including “Slayton v. Willing, 2010 VT 56, ¶ 14, 188 Vt. 216, 4 A.3d 1155,” “Sorrell v. Wigginton, 154 Vt. 301, 303 (1990),” “Morrison v. City of Montpelier, 2011 VT 9, ¶ 10,” “Thrall v. Rowan, 161 Vt. 451, 456 (1994),” and “EcoScience Corp. v. United States, 156 Vt. 185, 193 (1991),” among others. The Vermont Reports citations provided by plaintiff correspond to entirely different opinions than those named. We were unable to identify any existing case that corresponds to the citations provided in plaintiff's brief. ... Plaintiff's misrepresentation of the record extends to asserting that documents and records contain quotations that simply are not there. ... Plaintiff's practice of citing to non-existent authority and misrepresenting the contents of court records is a waste of limited judicial resources, a waste of the resources of opposing parties and further evidence of his disrespect for the courts of this State. ... Defendant's Motion for Sanctions (# 7) is GRANTED. Plaintiff is hereby ENJOINED from filing any new actions in the Civil Division of the Vermont Superior Court without obtaining prior leave from the court.

Authorities cited in the passage: Slayton v. Willing, 2010 VT 56 · Sorrell v. Wigginton, 154 Vt. 301 (1990) · Morrison v. City of Montpelier, 2011 VT 9 · Thrall v. Rowan, 161 Vt. 451 (1994) · EcoScience Corp. v. United States, 156 Vt. 185 (1991) · V.R.C.P. 11 · V.R.A.P. 25

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub