Courts on AI / Fabricated or misquoted citations

Branden Driver v. CNA Financial Corporation et al.

United States District Court for the Eastern District of Wisconsin · Federal district courts · WI · 2026-06-01 · No. Case No. 25-cv-1204-pp · order

Fabricated or misquoted citationsGAI

On 2026-06-01, in Branden Driver v. CNA Financial Corporation et al, the Eastern District of Wisconsin warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and.

Disposition: The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct: A self-represented litigant submitted a filing using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support. — 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.

The court identified sixteen instances of what appeared to be generative artificial intelligence (AI) hallucinations in the plaintiff’s filings, such as fabricated quotes and cases and misattributed quotes. Id. at 5–9. As the court explained, “[i]t is unacceptable for any party, represented or not, to submit filings that contain non-existent legal citations[,]” and “[p]arties who do so expose themselves to Rule 11 sanctions[.]” Id. at 5. The court ordered the plaintiff to show cause why the court should not sanction him for citing to cases that do not exist, fabricating quotes and asserting that cases stand for 1 The court filed an identical order in each case. certain propositions when they do not.

Authorities cited in the passage: Rule 11

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.

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