Courts on AI / Fabricated or misquoted citations

El Bitar v. Hernandez

United States District Court for the Western District of Washington · Federal district courts · WA · 2026-06-02 · No. 2:26-cv-00919 · order

Fabricated or misquoted citations Competence, fees and billingGoogle Gemini

On 2026-06-02, in Fadi El Bitar v. Julio Hernandez, the Western District of Washington imposed a $1,000 monetary sanction for the defective legal authorities. Counsel filed a petition using quotations that did not appear in the cited source. The monetary component was $1,000.

Disposition: The court sanctioned attorney Julian Mansoor Daman $1,000 payable to the court and discharged the show-cause process.
Recorded conduct: Counsel filed habeas briefs citing Thai and Nadarajah with fabricated quotations; he stated interns used Google Gemini to generate text and failed to disclose that it fabricated citations. The court sanctioned counsel $1,000. — outcome: fine; actor: lawyer; $1,000
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.

10) contained citation errors which appeared to be “the result of using generative artificial intelligence without checking the citations generated by the program.” Dkt. 12 at 3. The Court ordered Petitioner’s counsel to show cause as to why they should not be sanctioned pursuant to Rule 11. Id. at 3–4. Within 24 hours, Julian Mansoor Daman—counsel responsible for drafting Petitioner’s briefs—filed a declaration explaining the origin of the errant citations. Dkt. 13. I. ORDER Federal Rule of Civil Procedure 11 “imposes a duty on attorneys to certify that they have conducted a reasonable inquiry and have determined that any papers filed with the court are well grounded in fact, legally tenable, and ‘not interposed for any improper purpose.’” Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 393 (1990).

Authorities cited in the passage: Cooter & Gell v. Hartmarx Corp., 496 U · Rule 11 · Federal Rule of Civil Procedure 11

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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