Courts on AI / Fabricated or misquoted citations
Fadi El Bitar v. Julio Hernandez
United States District Court for the Western District of Washington · Federal district courts · WA · · No. 2:26-cv-00919-TMC · order
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 imposed a $1,000 monetary sanction for the defective legal authorities.
- Recorded conduct
- Counsel filed a petition using quotations that did not appear in the cited source. — outcome: sanctions; 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
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