Fabricated or misquoted citations

2026-09-03 · District of Columbia Court of Appeals

The District of Columbia Court of Appeals strikes Deutsche Bank’s appellee brief after counsel admits that four cited authorities generated through Google’s AI search did not exist. The court also refers the matter to disciplinary counsel and stresses that signed appellate briefs require verified authorities.

While reviewing appellee’s brief, the court discovered that it contained multiple citations to cases that the court was unable to locate or confirm as legitimate. On June 22, we issued an order requiring appellee to show cause “why the court should not strike its brief for citing nonexistent cases that are possibly the product of …

2026-08-31 · Intermediate Court of Appeals of Hawaiʻi

The Hawaiʻi Intermediate Court of Appeals affirms a criminal judgment while documenting numerous nonexistent or misidentified cases in Cody Presti’s self-represented opening brief. The court explains sanction authority for fake citations but declines to apply civil Rule 11 procedures in the direct criminal appeal.

Of the eleven cases this court was unable to locate, six cases include citations that indicate a volume and reporter that correspond with a different case entirely: • On page 8 of the Opening Brief, Presti relies on “State V. Alves, 45. Haw.296,” but that citation leads to an unrelated case, State v. Pokini, 45 …

2026-08-28 · United States District Court for the District of New Mexico

The District of New Mexico denies self-represented plaintiff Charles Reyes’s Rule 11 motion. The court holds defendants reasonably said Reyes may have fabricated a case citation because Reyes admitted he miscited a case in his amended complaint, and the remaining alleged misrepresentations did not support sanctions.

Mr. Reyes appears to argue that Defendants have violated Rule 11 by “misrepresenting the record and the law.” Doc. 61 at 2. He contends that Defendants: (1) misrepresented that he hallucinated a case citation in his pleadings; (2) “failed to comply with 28 U.S.C. § 1446(a) by omitting critical state-court filings from the Notice of …

2026-08-28 · Appellate Court of Illinois, First District · 2026 IL App (1st) 251168-U · provisional

The Illinois Appellate Court affirms denial of Sanja Noble’s petition and addresses a hallucinated citation in her self-represented brief. The order says Noble cited Ferguson v. Georges, but the reporter citation corresponded to People v. Mott and did not support the standard of review.

Arguments that are unsupported by citation do not meet the requirements of Rule 341(h)(7) and are procedurally defaulted. Wing, 2016 IL App (1st) 153517, ¶11. We also note that Noble’s brief contains a “hallucinated” citation on page 10, which occurs when AI-generated responses are used and not verified. See In re Baby Boy, 2025 IL …

2026-08-28 · United States District Court for the Northern District of Georgia

The Northern District of Georgia sanctions plaintiff’s counsel in Booker v. Kroger after finding fake, false and misleading case authorities and an untruthful denial of AI use. The order imposes an $8,000 court fine and requires documentation of completed ethics and technology CLE.

This matter is before the Court on its previous Order to Show Cause [ECF 53] directed to counsel for Plaintiff to explain why he should not be sanctioned for using fake or hallucinated case authorities, as well as misrepresenting the content of real case authorities, in his filings with the Court. Because Plaintiff’s counsel, as …

2026-08-27 · United States District Court for the Northern District of Texas

The Northern District of Texas dismisses Williams’s Section 1983 claims and warns that plaintiffs’ qualified-immunity briefing relied on nonexistent or inapposite cases. The court identifies Dawkins, Iko and Yates problems and cautions that generative-AI misrepresentations of law may trigger Rule 11 sanctions.

This cannot be undertaken at too broad a level of generality, id., and it certainly cannot be established by citation to nonexistent cases. Here, Plaintiffs make a borderline sanctionable attempt to identify “clearly established” law from five cases. ECF No. 18. Three of these cases—Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997), Yates v. …

2026-08-27 · Superior Court of Pennsylvania · provisional

The Superior Court of Pennsylvania affirms judgment against Paige and Ty Kiser and identifies an unlocatable Com v. Reid citation in counsel’s appellate brief. The memorandum treats the unsupported argument as waived and quotes prior authority warning that counterfeit citations may be chatbot products.

As Burton does not address either Pa.R.E. 404(B)(2) or res gestae, and as Appellants do not provide any discussion of ”Com v. Reid,” this Court’s review of Appellants’ argument to this point is substantially impaired. Further, in light of this unlocatable precedent, “this Court is left to guess whether this counterfeit authority is the product …

2026-08-27 · United States District Court for the Southern District of Florida

The Southern District of Florida recommends denying Miami-Dade County’s Rule 11 motion against James on safe-harbor grounds but says counsel relied for months on unverified AI-generated IACP Training Keys. The recommendation calls the Keys AI hallucinations and recommends referral of four signing attorneys.

In his Response, Plaintiff concedes that the Keys in the Fifth Amended Complaint that are the subject of the Motion were based on unverified AI-generated research, and although Plaintiff does not state so explicitly, the Keys were AI hallucinations. See id. at 6-7. As explained below, the Court finds Plaintiff’s counsel’s use of and repeated …

2026-08-27 · United States District Court for the District of Colorado

The District of Colorado denies Adams’s post-judgment motions and addresses counsel’s response to a show-cause order over a nonexistent Ricks v. Starbucks citation and other inaccurate authorities. The court admonishes counsel about possible AI-assisted research errors and separately imposes a $1,000 sanction for rule violations.

In her response to the show cause order, Ms. Pearson represents that the nonexistent case, Ricks v. Starbucks, was included in Plaintiff’s briefing inadvertently. By way of explanation, Ms. Pearson offers that at the time briefing was due, she was handling a significant family emergency and required additional help from an unnamed “colleague” and her …

2026-08-26 · United States District Court for the District of New Hampshire

The District of New Hampshire affirms bankruptcy dismissal and recounts that the bankruptcy court struck Noella Turgeon’s objection because it contained false, hallucinated case citations. The order rejects Turgeon’s due-process challenge, noting the bankruptcy court warned her about misleading filings and gave leave to amend.

The court then questioned Turgeon regarding her Objection to the Trustee’s motion to dismiss. Specifically, the court asked Turgeon about her use of “false, hallucinated case citations” within her brief. The bankruptcy court explained to Turgeon that the citations she referenced and relied upon in her objection were inaccurate and misleading. Accordingly, her objection to …

2026-08-26 · United States District Court for the Eastern District of Michigan · provisional

The Eastern District of Michigan denies the Potterfs’ objections after they acknowledge using artificial intelligence to prepare them. The court identifies false quotations, nonexistent cases and mischaracterized authorities, declines to grant relief on Rule 11-violating objections, and warns that future false citations may bring sanctions.

The Potterfs are not entitled to relief on any of their objections because they failed to take reasonable steps to ensure that the legal citations in the objections were accurate. As the Potterfs acknowledged during the virtual hearing on August 20, 2026, they used artificial intelligence to prepare their objections. Perhaps for that reason, their …

2026-08-26 · United States District Court for the District of Maryland · provisional

The District of Maryland dismisses Johnson’s mortgage-related claims and flags another hallucinated citation from the self-represented plaintiff. The court says Cooke v. Carrington Mortgage Services, as cited to the Fourth Circuit and Westlaw, does not exist, but declines further Rule 11 action because the case is dismissed.

Notwithstanding the foregoing admonition, it appears Plaintiff has once again cited a “hallucinated” case derived perhaps from use of a generative artificial intelligence (“AI”) tool (e.g., ChatGPT, Gemini, etc.). Specifically, Plaintiff cites to “Cooke v. Carrington Mortg. Servs., No. 22-1425 (4th Cir. 2023),” see ECF No. 57 at p. 3. Plaintiff contends this case stands …

2026-08-26 · United States District Court for the Northern District of Illinois · provisional

The Northern District of Illinois resolves Shelbert’s motion to strike Baxter’s defenses and admonishes plaintiff’s counsel for citing Instituto for propositions the Seventh Circuit opinion does not contain. The court says the motion appeared AI-generated and warns both parties against false or hallucinated citations.

The presumable conclusion was that Tyler had AI review Baxter’s Answer and had it generate his Motion to Strike. While there is not yet a proscription prohibiting this conduct, there is a proscription of filing a brief with citations to cases that do not stand for the asserted proposition. Perez-Castillo v. Blanche, 177 F.4th 837, …

2026-08-26 · Arizona Court of Appeals, Division Two · provisional

The Arizona Court of Appeals affirms a family-law fee award and notes that self-represented appellant Brently Easten relied on Napp v. Napp, a case the court says does not exist at the cited location. The court suspects Breitbart-Napp was intended and declines appellate-fee sanctions.

One such authority is Napp v. Napp, which Easten cites for the proposition that an award must be supported by a record sufficient to permit meaningful review. But that case does not exist—at least not at the citation provided by Easten. We suspect he intended to cite Breitbart-Napp v. Napp, 216 Ariz. 74 (App. 2007). …

2026-08-25 · United States District Court for the District of New Jersey · provisional

The District of New Jersey denies Kurelko’s motions to disqualify state counsel and notes his first motion contained inaccurate or nonexistent case citations and quotations. The court declines sanctions at that time, admonishes the self-represented plaintiff, and warns that similar conduct may bring monetary penalties.

Plaintiff’s first motion to disqualify contains several inaccurate or non-existent case citations and quotations. See [Dkt. 15.] “‘[I]t is improper and unacceptable for litigants—including pro se litigants—to submit ‘non-existent judicial opinions with fake quotes and citations.’” Fagan v. Barnhiser, Civ. No. 24-06012 (CCC), 2025 WL 2654994, at *2 (D.N.J. Sept. 17, 2025) (quoting Anonymous v. …

2026-08-25 · United States District Court for the Western District of Missouri

The Western District of Missouri enters default judgment against Shante Gaines and recounts an earlier Rule 11 show-cause order over citations to nonexistent cases and quotations in a November 2025 filing. The court notes Gaines did not respond to the show-cause order or comply with discovery obligations.

On November 21, 2025, AndDone filed a motion requesting an order that Gaines show cause why she should not be sanctioned for violations of Federal Rule of Civil Procedure 11 for misrepresentations to the Initial Court including citations to nonexistent cases and quotations contained in a November 18 filing, (Doc. 53). (Doc. 57.) ... The …

2026-08-24 · United States District Court for the District of Arizona

The District of Arizona publicly reprimands Elizabeth Tate after finding she filed three briefs with fake AI-generated quotations and a fourth with an inaccurate AI-generated case summary. The order says she used ChatGPT, violated Rule 11 and ethics duties, and must report the discipline where required.

The first issue to be addressed is whether Ms. Tate’s conduct violated any procedural or ethical rules. It did. Ms. Tate acknowledges that she filed three different briefs in this action that contained fake AI-generated quotations and filed a fourth brief that contained an inaccurate AI-generated case summary. ... In the course of preparing this …

2026-08-21 · Superior Court of California, County of Sacramento · provisional

The Sacramento Superior Court rules on a demurrer and addresses Joseph Perez’s unsupported quotation from Adorh Farms. The court says the quotation does not appear in that opinion or any reported case, flags possible generative AI use, declines sanctions, and warns future fabricated authority may be sanctioned.

Plaintiff quotes Adorh Farms, Co. v. Love (1967) 255 Cal.App.2d 366 at p. 371: “The filing of an answer … effected a waiver of the right to demur.” (Opp., at p. 8: 19–21.) This is at best an incomplete statement of law. “A party objecting to a complaint or cross-complaint may demur and answer at …

2026-08-21 · United States District Court for the Eastern District of California · provisional

The Eastern District of California recommends dismissal of Stephen Lohbeck’s claims and considers Amazon’s Rule 11 argument. The magistrate judge finds two quotations in Lohbeck’s sanctions motion do not appear in the cited cases, declines sanctions because he is self-represented, and warns that future false authority may be sanctionable.

Defendant argues Plaintiff has violated Federal Rule of Procedure 11 by misusing generative artificial intelligence (“generative AI”). See Def. Sanctions Opp. at 6-7 (ECF No. 21). Specifically, Defendant argues Plaintiff’s writing contains generative AI hallmarks and that for each case Plaintiff cites with a parenthetical, the quoted language is absent from the cited opinion. ... …

2026-08-20 · United States District Court for the Northern District of California · provisional

The Northern District of California grants in part a renewed fee motion and discharges a sanctions order. The order records that plaintiff’s counsel reimbursed SJ 6070 $14,500 for expenses incurred addressing nonexistent cases cited in opposition to an earlier attorneys’ fees motion.

The Court also ordered Plaintiff’s counsel to show cause why he should not be sanctioned in an amount sufficient to reimburse Defendant for expenses it incurred in addressing nonexistent cases cited by Plaintiff in opposition to the first attorneys’ fees motion. See Order to Show Cause, ECF 30. The parties have resolved that issue informally, …

2026-08-20 · United States District Court for the Central District of California · 2026 WL 2447454 · provisional

The Central District of California grants Cecile Kasengela’s remand motion while addressing non-existent quotations in her self-represented briefing. The court reiterates its standing order on AI-generated hallucinated caselaw, rejects her accusation against Kaiser, and says a lawyer would face significant sanctions.

Lastly, the Court underscores its Standing Order to remind Plaintiff that the inclusion of non-existent quotations in Plaintiff's briefing submitted to this Court is unacceptable. (See Opp'n at 3-4; Order Re Amended Civil Case Standing Order, Dkt. No. 65 at 18-20 (“caution[ing] that unqualified reliance on AI-generated content can result in filings that rely on …

2026-08-20 · United States District Court for the Central District of California · provisional

The Central District of California denies Michael Dotson’s reconsideration application and identifies three quotations misattributed to Mission Power. The court says the language appears in Horne instead, describes the errors as AI-hallucination hallmarks, and orders counsel to show cause about sanctions and bar referral.

At three different points in his Application, Plaintiff attributes quoted language to Mission Power, 883 F. Supp. at 492, which appears nowhere in the body of the cited case. See Appl. at 7:10–7:15, 10:5–10:8, 10:17–10:22. The discrepancies between the quoted language and the language of the cited case are so significant as to abrogate any …

2026-08-19 · Superior Court of Pennsylvania · 2026 PA Super 185 · provisional

The Superior Court of Pennsylvania affirms dismissal of Zoryana Kaspryak’s partition action. The court finds that two citations in her self-represented reply brief are hallucinated, explains that the reporter citations lead to different cases, and concludes her claims are waived for unsupported and fabricated authority.

Specifically, Appellant cites to “General Fin. Co. v. Archetto, 167 A.2d 306 (Pa. Super. 1961)” and “Lowrey v. Eastaff, 860 A.2d 533 (Pa. Super. 2004).” See id. (some formatting altered). These citations are so nonsensical and disconnected from Appellant’s claims that we conclude that they are hallucinated citations. To the extent that Appellant has employed …

2026-08-19 · United States District Court for the District of Nevada · provisional

The District of Nevada dismisses William Lee Kelly’s second amended complaint against FINRA and warns him about AI-generated fake authority. The court finds several false quotes and nonexistent citations in his opposition and explains that future Rule 11 violations may lead to monetary or nonmonetary sanctions.

FINRA states that Kelly’s opposition to its motion to dismiss contains several nonexistent case citations and quotations that do not appear in Kelly’s cited caselaw. I reviewed the citations in the first few pages of Kelly’s opposition and found several quotes that did not appear in the cited cases. These false quotes appear on page …

2026-08-19 · Court of Appeals of Iowa · provisional

The Court of Appeals of Iowa affirms a custody order and addresses a sanctions request based on alleged AI use. The court finds no hallucinated case, says it cannot determine whether a nonexistent appellate rule citation is a typo or unchecked AI output, and declines AI-use sanctions.

In her resistance to Brett’s motion for remand and request for sanctions, Lacey asked our supreme court to impose sanctions on Brett for purported use of generative AI in his limited-remand motion and briefs. ... The twist is that, absent the presence of a hallucinated case, it is difficult to differentiate poor human drafting from …

2026-08-19 · United States District Court for the Northern District of Illinois · provisional

The Northern District of Illinois affirms a bankruptcy abstention order and identifies false quotations and erroneous legal statements in Peter Snisko’s appellate brief. The court says counsel doubled down after appellee flagged the errors and orders attorney Martin Spencer to show cause regarding fabricated citations and other misrepresentations.

Appellant’s brief is replete with false quotations and erroneous statements of law. By way of example, appellant cites In re Chi., Milwaukee, St. Paul & Pac. R.R. Co., 6 F.3d at 1188, for the proposition that the applicable standard of review is de novo. [17] at 18. True, a bankruptcy court’s legal conclusions are reviewed …

2026-08-19 · Court of Appeals of Georgia · provisional

The Court of Appeals of Georgia affirms summary judgment for HIG Realty Credit Fund and warns Trentiss Mitchell about citations in his self-represented appellate briefing. The court identifies two non-existent cases and two unrelated cases, says the defects suggest unchecked generative AI, and declines sanctions.

As an initial matter, we note that in his appellate briefing, Mitchell cites five cases that are either fictitious or have nothing to do with the propositions for which they are cited.1 These defects suggest that Mitchell’s briefs were “drafted with the use of unchecked generative AI,”2 and his reliance on non-existent law is a …

2026-08-19 · California Court of Appeal, Fourth Appellate District, Division One · provisional

The California Court of Appeal affirms an order in Marriage of Dillon and addresses three miscited cases in the respondent’s self-represented brief. The court disregards arguments based on the hallucinated citations, declines sanctions because none were sought, and denies prevailing-party costs on appeal.

Wife miscited three cases in her respondent’s brief by attributing to them quotations or legal propositions that do not appear in the cited opinions.3 The miscitations appear to be the result of Wife’s use of generative artificial intelligence without sufficient verification. We have disregarded the arguments in Wife’s brief that are based on the miscited …

2026-08-18 · United States District Court for the Western District of Washington · provisional

The Western District of Washington grants summary judgment for Outliers and addresses AI-generated citation tables used in expert materials. The court recounts sanctions against counsel, finds Dr. Holguin’s hallucinated citations undermine his report’s reliability, and excludes that expert opinion under Rule 702 and Daubert.

The Court also issued sua sponte sanctions against Plaintiff’s attorney, Ms. Jocelyn Stewart, for generating numerous false citations with artificial intelligence and submitting them to the Court without verification. Dkt. 265. Multiple such citations existed in the expert reports of Mr. James Kababick and Dr. Ronald Shippee, where Plaintiff admitted that “she used Claude or …

2026-08-18 · Court of Appeals of Washington, Division Two · provisional

The Washington Court of Appeals affirms a parenting plan and awards Rebekah Muriel fees for responding to Jonathan Farris’s response brief. The court says the brief twice cited nonexistent Marriage of Sanjuan, surmises AI-assisted drafting, deems the filing frivolous, and sets the fee amount for the commissioner.

However, we award appellate attorney fees to Rebekah under RAP 18.9(a) for her time spent reviewing and responding to Jonathan’s response brief. Here, Jonathan’s brief twice cites to Marriage of Sanjuan to support his arguments, but as Rebekah points out in her reply brief, no such case exists. We surmise that Jonathan used artificial intelligence …

2026-08-18 · United States District Court for the Western District of Texas · provisional

The Western District of Texas orders more briefing in a habeas case and cautions Gilberto Garcia Perez’s counsel. The order says most cases cited in petitioner’s reply do not exist, lists six hallucinated authorities including one purportedly from the same court, and warns future inaccurate AI citations may be sanctionable.

He then cites a variety of cases supporting this contention, the majority of which do not exist.4 The Court will nonetheless consider Petitioner’s due process argument, as it will not punish Petitioner for his counsel’s mistakes. ... The Court notes that an alarming number of cases cited by Petitioner for support in his Reply are …

2026-08-18 · Court of Appeals of Texas, First District · provisional

The Texas First Court of Appeals strikes Manny Kourradi’s fourth self-represented brief and dismisses the appeal. The memorandum identifies multiple unlocatable or mismatched Westlaw-style citations, says the errors are at best partially fabricated, and treats the defective briefing as grounds for dismissal.

The brief also included incomplete legal citations accompanied by unintelligible numeric strings (e.g., “2990836”). We again struck Kourradi’s appellate brief and ordered Kourradi to file a corrected brief. We admonished Kourradi to ensure that record references and citations to authorities are accurate. See Campbell v. Campbell, No. 03-25-00388-CV, 2026 WL 179402, at *2 n.3 (Tex. …

2026-08-18 · Appellate Court of Illinois, First District · 2026 IL App (1st) 252264-U · provisional

The Illinois Appellate Court affirms dismissal of Lemna Sani’s complaint and admonishes her about a nonexistent citation in her self-represented opening brief. The court says Helm v. Illinois Central Railroad does not exist and that the reporter citation leads to People v. Hardy, an unrelated criminal case.

We are particularly troubled by the fact that one of her case citations in her opening brief (as IHR notes) does not exist: “Helm v. Illinois Cent. R.R.” does not appear in any reported case in this state, and the precise citation (again, as IHR points out), “142 Ill. App. 3d 108 (1986),” is for …

2026-08-14 · Superior Court of Vermont, Windham Unit · 2026 WL 2479362 · provisional

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.

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, ¶ …

2026-08-14 · United States District Court for the Southern District of Indiana · 2026 WL 2374808 · provisional

The Southern District of Indiana dismisses Darryl Harris’s complaint without prejudice and warns him about an incorrect citation in a service-extension motion. The court says the Walsh docket number linked to a different case, the Westlaw citation led nowhere, and future Rule 11 violations may be sanctioned.

In Harris's motion for extension of time to effect service of process, he cites Walsh v. Kreiger, No. 19-cv-1764, 2020 WL 6325983, at 2 (E.D. Wis. Oct. 28, 2020) (citing United States v. McLaughlin, 470 F.3d 698, 700 (7th Cir. 2006)), for the proposition that “good cause” not the stricter “excusable neglect” standard is the …

2026-08-14 · Court of Appeals of Indiana · provisional

The Court of Appeals of Indiana affirms the denial of David Brankle’s motion to compel and a $1,546 expenses award. The memorandum quotes the trial court’s finding that Brankle cited nonexistent rules and fictitious cases suggesting ChatGPT use, and holds hallucinated authorities cannot substantially justify the motion.

Brankle’s motion is totally without merit. First, Commercial Court Rules are inapplicable to this case[,] and Brankle should not cite to them again. Brankle’s repeated citations to rules that do not exist or fictitious cases leads the Court to opine that Brankle is using ChatGPT or other form of artificial intelligence to prepare his numerous …

2026-08-14 · United States Court of Appeals for the Fifth Circuit · provisional

The Fifth Circuit resolves consolidated immigration appeals and warns appellants’ counsel about systematically defective authorities. The opinion identifies quotations falsely attributed to Ng Fung Ho, an incorrect circuit attribution for Doe v. McAleenan, and a quotation from an Afroyim dissent misattributed to the majority.

Appellants have not adequately briefed these claims: They are completely unsubstantiated by citations to the record, and the case citations in the briefing are systematically defective. Accordingly, Appellants have forfeited these arguments. ... Troubling to the court is the fact that the briefs filed in both cases by Appellants’ counsel contain significant inaccuracies. Both briefs …

2026-08-14 · Arizona Court of Appeals, Division One · provisional

The Arizona Court of Appeals grants partial special-action relief in a contempt dispute and addresses a quotation in Father’s filing. The court says neither cited case contains the quoted jurisdictional rule, it cannot find the language in Arizona law, strikes the false quotation, and declines sanctions.

Father contends the superior court both lacked jurisdiction to hold him in contempt and abused its discretion by finding him in contempt. He also contends the court imposed improper sanctions. ... In making his jurisdictional argument, Father said, “Arizona appellate courts have consistently held that a trial court may not hold a party in contempt …

2026-08-12 · United States District Court for the Western District of Pennsylvania · provisional

The Western District of Pennsylvania resolves motions in Dyran Davenport’s civil-rights action and warns him about inaccurate filings. The court identifies nonexistent Loder v. City of Philadelphia as an AI-hallucinated citation in his opposition but still accepts his accrual argument based on other relevant authority.

Moreover, the Court acknowledges that Plaintiff’s briefs appear to include at least one AI hallucinated citation. Plaintiff has also made unsupported, and to the extent unsupportable, arguably outrageous allegations about Defendants and their counsel. ... Plaintiff has proffered and the Court has seen no evidence to suggest that either of these allegations is at all …

2026-08-12 · United States District Court for the Middle District of Florida · 2026 WL 2329753 · provisional

The Middle District of Florida partly grants Arts Bonita’s motion about generative AI use. The court finds Julia Rose cited a nonexistent Prousalis case, later withdrew it as incorrect or unverifiable, declines sanctions for a single hallucinated citation, and warns future inaccurate authority may be sanctioned.

In her response to Arts Bonita's motion to dismiss, Rose cited Prousalis v. Bert's Bikes & Fitness, No. 8:18-cv-1234, 2019 WL 13202785 (M.D. Fla. 2019). That case does not exist. Once Arts Bonita caught the error, it asked Rose to join an agreed order on generative AI use. The City signed on, but Rose refused, …

2026-08-12 · District Court of Appeal of Florida, Fourth District · provisional

The Florida Fourth District Court of Appeal refers Barry Leff to the Florida Bar after a certiorari petition cited false AI-draft authority. Counsel says he filed the wrong draft; the court finds the petition misrepresented jurisdictional law, lacked controlling adverse authority, and cited non-existent authority.

Counsel filed a certiorari petition in this case that is riddled with false citations and arguments, including an unsupported allegation that this Court has “repeatedly entertained, and granted, certiorari review of orders vacating clerk’s defaults.” The petition cited a non-existent case allegedly from this Court and cited other cases that do not support this proposition. …

2026-08-12 · United States District Court for the Northern District of Alabama · 2026 WL 2350902 · provisional

The Northern District of Alabama sanctions Scott Morro for false citations, quotations, and legal representations in Chapman v. City of Priceville. The court treats client-drafted filings submitted without verification like unchecked AI work, publicly reprimands Morro, orders notice in pending cases, and directs publication.

The court finds, based upon its own careful review and Morro's admission, (doc. 34 at 1–2), that the purported citations, quotations, and representations of law in the filings at issue were fabricated. Accordingly, by citing nonexistent cases and attributing nonexistent quotations and propositions of law to actual authorities, Morro made false statements of law. Morro …

2026-08-11 · United States District Court for the Middle District of Pennsylvania · 2026 WL 2322660 · provisional

The Middle District of Pennsylvania adopts a recommendation to dismiss Courtney Voyton’s complaint with leave to amend and admonishes her AI use. The memorandum says she misrepresented 42 Pa. Cons. Stat. § 5522 and advanced AI-steered ghost arguments unrelated to the report, requiring future AI-use affidavits.

Prior to addressing the merits of the allegations against Skibitsky, plaintiff is admonished for misrepresenting the law. The statute cited by plaintiff in Paragraph 43 has nothing to do with the alleged conduct by Skibitsky. Rather, the statute referenced requires a person to file a formal written notice of their intent to sue a state …

2026-08-11 · Appellate Court of Maryland · 2026 WL 2321382 · provisional

The Appellate Court of Maryland affirms judgment for 72 Barrow St. Realty and taxes costs to Simon Eyong. The per curiam opinion notes earlier orders striking large portions of his self-represented briefs for fictitious legal citations and inaccurate summaries, and leaves a sanctions motion for remand.

72 Barrow has moved for sanctions against Mr. Eyong under Rules 1-341 and 8-504, arguing that his citation to fictional legal authority in his opening brief and his reply brief; the lack of legal authority for his positions; and his failure to prepare a record extract justify an award of reasonable attorneys’ fees and costs. …

2026-08-11 · United States District Court for the Western District of Arkansas · provisional

The Western District of Arkansas sanctions Nicholas Nesbitt in a consumer-credit case by imposing filing restrictions. The court says he relied on AI for legal research and writing, filed at least two motions with fabricated cases, apologized after a Rule 11 show-cause order, and continued filing improper papers.

Since then, Plaintiff has filed numerous replies without leave of Court, repetitive notices and motions, and at least two motions relying on fabricated cases. ... On July 17, 2026, the undersigned ordered Plaintiff to show cause why he should not be sanctioned under Federal Rule of Civil Procedure 11(b) for citing nonexistent case law in …

2026-08-10 · Court of Chancery of the State of Delaware · provisional

The Delaware Court of Chancery master recommends removing Gregory Palumbo as trustee, denying his accounting petition, and shifting fees. The report says the self-represented disbarred attorney cited Kuroda and Koninklijke for propositions they do not support, treated fictitious quotations as an AI hallmark, and found subjective bad faith.

Moreover, many of the cases cited by Respondent in support of his proposition neither expressly state nor even suggest the statements for which he invokes them. Respondent cites Kuroda v. SPJS Holdings, LLC for the proposition that (1) the proper procedural retort to a confusing claim is a Rule 12(e) motion for a more definite …

2026-08-10 · Arizona Court of Appeals, Division One · provisional

The Arizona Court of Appeals dismisses Stefanie Kuerschner’s appeal and awards appellate fees and costs. The court says her brief lacked record citations, repeatedly misquoted or misstated cases, included one unlocatable case, and repeated citation problems despite earlier warnings about AI-related errors.

Stefanie’s opening brief does not include a single citation to the record. Her opening brief also consistently misquotes cases and cites cases for propositions either not mentioned or directly contradicted by the case. And one case she cites appears not to exist. ... On page 27, the brief quotes State ex rel. Dep’t of Econ. …

2026-08-07 · United States District Court for the District of Utah · provisional

The District of Utah addresses Jayne Stephens’s declaration that ChatGPT assisted her filings. The order notes a mischaracterized assertion based on an improperly cited Tenth Circuit case, requires future assistance disclosures, and cautions that GenAI-related Rule 11 violations may be sanctioned.

Ms. Stephens filed the Declaration on August 3, 2026, and declared, under penalty of perjury, that she had used a generative artificial intelligence (“GenAI”) tool known as ChatGPT. She confirms that she utilized ChatGPT “for assistance with research, organization, drafting, editing, and formatting.” Her candor is appreciated, but necessitates a caution. ... Ms. Stephens has …

2026-08-07 · Supreme Court of New York, New York County · 2026 N.Y. Slip Op. 51211(U); 2026 WL 2291696 · provisional

The New York Supreme Court decides a broker-dispute dismissal motion and denies sanctions requested on reply. The court says plaintiffs attributed a quotation to a case where it did not appear, but even treating it as an AI fabrication did not warrant a monetary sanction.

Movants alternatively seek dismissal of plaintiffs' claims and an award of attorney fees, on the additional ground that plaintiffs' opposition assertedly includes a quotation fabricated by artificial intelligence. (NYSCEF No. 30 at 5-6, 9.) Movants do not identify the basis for this court's authority to impose the requested sanction. Movant's request for sanctions is denied. …

2026-08-07 · United States District Court for the Western District of North Carolina · provisional

The Western District of North Carolina resolves summary-judgment and spoliation motions and discharges an AI show-cause order. The court says plaintiff’s counsel accepted responsibility for fabricated quotations but did not explain their origin or substantiate claims about an unnamed AI program.

On June 3, 2026, the Court directed counsel for the Plaintiff to show cause in writing as to why she should not be sanctioned for failure to comply with the Court’s Standing Order Regarding the Use of Artificial Intelligence. [Doc. 98 at 15]. The Court specifically directed counsel for the Plaintiff to explain both the …

2026-08-07 · Massachusetts Land Court, Plymouth District · 2026 WL 2295072 · provisional

The Massachusetts Land Court denies Robert Machinsky’s self-represented motion to dismiss in a registered-land proceeding. A footnote documents false statutory quotation, irrelevant recusal authority, Rule 70 cases that do not address Rule 70, and warns about AI-generated hallucinations and false citations.

In addition to this false quotation, a review of other legal citations in defendant's filings uncovered several additional inaccuracies and questionable string citations that may be attributable to use of generative artificial intelligence (“AI”) tools or large language models (“LLMs”). On page 3 of defendant's Motion to Recuse, he writes: “The appearance of bias or …

2026-08-07 · United States District Court for the Northern District of Illinois · provisional

The Northern District of Illinois denies Darren Smith’s § 2255 motion and issues a sanctions show-cause order. The court identifies a nonexistent Johnson case, false quotations from real cases, and nearly a dozen falsified cases or quotations, then orders Smith to explain why monetary sanctions should not issue.

Smith also cites United States v. Jones, 965 F.3d 149 (2d Cir. 2020) as a case that “reversed a sentence,” Smith’s Br. at 2, but Jones both did not involve challenges to the sentence and affirmed the defendant’s conviction, 965 F.3d at 153. In his reply brief, Jones cites “United States v. Johnson, 605 F.3d …

2026-08-06 · United States District Court for the Middle District of Tennessee · 2026 U.S. Dist. LEXIS 175482; 2026 LX 497566 · provisional

The Middle District of Tennessee sanctions attorney Louis W. Ringger III after a filing contained hallucinated quotations and misleading citations. The order says unchecked AI-generated content contributed to the deficiencies, publicly reprimands Ringger, and orders him to pay $1,500 to the clerk.

On July 30, 2026, the Court ordered several of plaintiff's attorneys to show cause why they should not be sanctioned-under either or both of Rule 11 of the Federal Rules of Civil Procedure and the Court's inherent authority-for filing a document at Doc. No. 293 that contained hallucinated quotations and misleading citations. ... Ringger has …

2026-08-06 · United States District Court for the Northern District of Ohio · provisional

The Northern District of Ohio rules on Greater Cleveland Regional Transit Authority’s motion to dismiss and flags a Shimola citation. The court says the cited reporter page points to another case, Shimola does not support the proposition, and future hallucinated citations may be sanctioned.

The Court first addresses GCTRA’s reliance on Shimola. First, “State ex rel. Shimola v. City of Cleveland” is not found at “70 Ohio St.3d 40” as cited by GCRTA. That citation is to State ex rel. Hopkins v. Indus. Comm’n of Ohio, 70 Ohio St.3d 36, 635 N.E.2d 1257 (Ohio 1994). And that case was …

2026-08-06 · United States District Court for the District of Nebraska · 2026 WL 2267773 · provisional

The District of Nebraska grants an EAJA fee request and cautions plaintiff’s counsel over a cited Peterson decision. The order says the Eighth Circuit citation does not exist, a similarly named case lacks the quoted language, and Nebraska’s AI rule requires verification.

Plaintiff cites one case in her initial brief in support of the Motion for Attorney Fees. Filing No. 27-1 at 2. Plaintiff quotes Peterson v. U.S. Retirement Board, 785 F.2d 245 (8th Cir. 1986) as follows: Agency action found to be arbitrary and capricious or unsupported by substantial evidence is virtually certain not to have …

2026-08-06 · Supreme Court of North Dakota · 2026 ND 156 · provisional

The North Dakota Supreme Court affirms and remands in a divorce dispute and separately sanctions self-represented appellant Mojahid Osman. The court says Osman corrected two nonexistent citations but ignored many unrelated authorities, and awards Sara Ali $1,000 for multiple fictitious or nonexistent citation errors.

We conclude Osman’s appeal is not completely frivolous; therefore, we do not sanction under N.D.R.App.P 38 as requested. Nevertheless, while Osman corrected two nonexistent citations, he failed to acknowledge numerous other citations wholly unrelated to the propositions for which they were cited. Under N.D.R.App.P. 28(b)(2) and (7), a party’s brief must provide citations to authorities, …

2026-08-05 · United States District Court for the Western District of Texas · provisional

The Western District of Texas issues a show-cause order in Cain v. Hyatt. The order says plaintiffs cited nonexistent Henry v. Kroger authority in a dismissal response and requires attorney Daniel Miguel Hernandez to appear under Rule 11(c)(3).

Plaintiffs cited nonexistent case Henry v. Kroger Co., No. 4:19-cv-00630, 2019 WL 6311295 (E.D. Tex. Nov. 25, 2019), in their Response to Defendant’s Motion for Partial Dismissal. Dkt. 9 at 7. Under Rule 11(b), an attorney certifies that legal citations in papers presented to the Court are correct “to the best of the person’s knowledge, …

2026-08-05 · Texas Court of Appeals, Fourth District · provisional

The Texas Fourth Court of Appeals reverses denial of SAISD’s jurisdiction plea and renders dismissal. Before reaching the merits, the court identifies four hallucinated opinions in Becerra’s brief and cautions counsel that similar future issues will not be tolerated.

We begin by noting that Becerra’s appellee’s brief cites eight judicial opinions, four of which appear to be hallucinations created by generative artificial intelligence: “Alief Independent School District v. Lozano, 543 S.W.3d 118 (Tex. App.—Houston [14th Dist.] 2018, pet. denied),” cited on page 23 of Becerra’s brief, does not exist. The citation 543 S.W.3d 118 …

2026-08-05 · United States District Court for the Northern District of New York · 2026 WL 2253803 · provisional

The Northern District of New York grants Waste Management’s dismissal motion, allows limited amendment, and warns self-represented plaintiff Mary-Rose Calenzo. The court identifies at least four nonexistent opinions in her opposition and directs her to stop using hallucinated or fabricated case law.

As a final matter, the undersigned has been unable to locate or verify several of the cases cited by Plaintiff in support of her opposition to Defendant's motion to dismiss. Specifically, Plaintiff's opposition includes citations to at least four nonexistent judicial opinions: LPD New York, LLC v. Adidas Am., Inc., 2020 WL 1501881 (S.D.N.Y. Mar. …

2026-08-05 · United States District Court for the District of Connecticut · provisional

The District of Connecticut admonishes self-represented debtor Ulish Booker in a bankruptcy appeal. After a show-cause hearing, the court finds his briefs contained fabricated cases, erroneous citations, and incorrect quotations produced with Gemini Pro, Perplexity, Cetient Legal AI, and ChatGPT.

On June 25, 2026, this Court issued an Order to Show Cause after discovering that Booker III’s briefs were riddled with cases that do not exist, incorrect quotes, and erroneous citations. Specifically, in its Show-Cause Order, the Court identified the following hallucinations: ... BCB Contracting Services, LLC v. United States, 104 B.R. 771, 775 (S.D. …

2026-08-04 · United States District Court for the Southern District of Texas · provisional

The Southern District of Texas magistrate judge recommends summary judgment for SWBC Mortgage and Cenlar. The recommendation says plaintiffs’ counsel cited fabricated Pointe West and Tractebel cases, misused other authorities, and is reminded of Rule 11 duties.

Plaintiffs cite Pointe West Center, LLC v. It’s Alive, Inc., 796 S.W.2d 830, 838–39 (Tex. App.—Houston [1st Dist.] 1990, writ denied), and Motten v. Chase Home Financial, 821 F. Supp. 2d 988, 1008 (S.D. Tex. 2011), for the proposition that a cause of action for wrongful initiation of foreclosure proceedings exists. Pointe West is a …

2026-08-04 · Missouri Court of Appeals, Western District · provisional

The Missouri Court of Appeals dismisses self-represented father Zackery Moore’s family-access appeal because he did not supply the record needed for review. A footnote says his brief also contained two nonexistent reporter citations and one misrepresented holding, independently supporting dismissal.

Therefore, we dismiss Father’s appeal for failure to provide this Court with the required record on appeal necessary to resolve the questions raised in his appeal. ... There are numerous other briefing deficiencies with Father’s appellate brief that would also independently support dismissal of Father’s appeal. ... Father’s brief includes two citations to cases that …

2026-08-04 · United States District Court for the District of Connecticut · provisional

The District of Connecticut sanctions defense counsel Hilary Miller in a trademark dispute. The order says Miller used Open Law, Claude, and ChatGPT, submitted unverified AI-generated legal authorities with nonexistent quotations and erroneous citations, and must pay $3,500 with a grievance referral.

This Order addresses the Court’s previously issued Order to Show Cause concerning defense counsel Hilary Miller’s use of unverified generative artificial intelligence (“AI”) in this matter. Having considered counsel’s written response to the Order to Show Cause and his representations made at the show-cause hearing, the Court concludes that sanctions are warranted and imposes the …

2026-08-03 · United States District Court for the Western District of Texas · provisional

The Western District of Texas adopts an R&R and dismisses the remaining defendant without prejudice. The order catalogs repeated invented quotations, unsupported case descriptions, and possible AI use, then warns the self-represented plaintiffs to verify all authorities and quotations in future filings.

They are the latest installment in a sustained series of filings marked by misstatements of law, mischaracterizations of the record, fabricated quotations, and demands untethered to any rule of procedure. ... Although Plaintiffs certified that they verified each citation contained in those objections (Doc. 76 at 26), the Court identified multiple instances in which Plaintiff …

2026-08-03 · Superior Court of Pennsylvania · provisional

The Superior Court of Pennsylvania affirms summary judgment in a medical-malpractice appeal. A footnote identifies three cited cases that do not exist, reminds the self-represented appellants that authority must be pertinent, and warns that substantial brief defects can justify dismissal.

Appellants cite to two cases—one which is non-existent—for the rules that summary judgment may not be entered where discovery is incomplete or credibility issues remain. See id. at 40 (citing Gibson v. Bicknell, 668 A.2d 1370 (Pa. Super. 1995), and Washington v. Baxter, 719 A.2d 733 (Pa. 1998)). ... This cited case does not exist.Elsewhere …

2026-08-03 · Ohio Court of Appeals, Seventh Appellate District · 2026-Ohio-2993 · provisional

The Ohio Seventh District affirms Jacob Davis’s speeding conviction. The opinion says Davis disclosed using generative AI for his nonconforming brief, and a cited Sanchez case does not discuss the indefinite-tolling proposition he raised, possibly reflecting an AI hallucination.

A further problem on appeal is that Appellant has filed a non-conforming brief, well outside of the limits set by the Rules of Appellate Procedure. The brief is set in a small font, single spaced, and if converted to 12-point font and double-spaced would well exceed 35 pages and 9,000 words (the word count is …

2026-08-03 · United States District Court for the Eastern District of North Carolina · 2026 WL 2439988 · provisional

The Eastern District of North Carolina recommends dismissal of Damon Forney’s employment case as untimely and sanctions attorney Lucas Colantonio. The order says Colantonio repeatedly submitted fabricated authority after a warning, must pay Cary’s response fees, and is referred to the North Carolina State Bar.

The record provides clear and convincing evidence that Colantonio engaged in conduct that justifies imposing sanctions under the court's inherent authority. First, Colantonio provided erroneous case citations repeatedly even after being warned. Colantonio has admitted that the citation was erroneous. ... Thus the record establishes by clear and convincing evidence that Colantonio knowingly submitted a …

2026-08-03 · United States District Court for the Central District of California · 2026 WL 2227350 · provisional

The Central District of California manages a transferred pro se case by striking improper filings and imposing filing limits. The court says Jabbari’s papers contain AI hallmarks and fabricated legal authorities, then orders him to show cause why Rule 11 or inherent-authority sanctions should not issue.

The court also ORDERS Plaintiff to Show Cause (“OSC”) in writing, on or before August 17, 2026, why sanctions should not be imposed under Federal Rule of Civil Procedure Rule 11 and the court's inherent authority, for Plaintiff's submission of frivolous and vexatious filings and/or false and fabricated legal citations. ... Plaintiff's filings bear hallmarks …

2026-08-03 · United States District Court for the Northern District of Alabama · provisional

The Northern District of Alabama dismisses Domeneque Perry’s Social Security claim without prejudice and denies TRO and amendment motions. The court notes the Commissioner raised fabricated citations and misrepresentations in Perry’s TRO motion and warns this is Perry’s only warning before sanctions.

The SSA raised an issue of “fabricated citations” and misrepresentations in Ms. Perry’s motion for a temporary restraining order. See Doc. 30; Doc. 33 at 23–24. The court is aware that Ms. Perry has been warned by another court against such practices. The court warns Ms. Perry that fabricated citations and misrepresentations will not be …

2026-07-31 · United States Bankruptcy Court for the Eastern District of Virginia · 2026 WL 2220314 · provisional

The Eastern District of Virginia bankruptcy court dismisses Alicia Mahar’s adversary complaint for lack of jurisdiction. Footnotes note that counsel cited a nonexistent In re Coastal Carolina Fruit Company decision and supplied incorrect court, Westlaw, or date information for three other mortgage cases.

At the March 26, 2026 hearing, the Court advised Ms. Mahar's counsel that one of the cases he cited in support of this proposition does not exist. ECF No. 61, Transcript of Mar. 26, 2026 hearing, at 9-10. Despite extensive efforts, the Court was unable to locate any case by the alleged name, and its …

2026-07-31 · Texas Court of Appeals, Twelfth District · provisional

The Texas Twelfth Court of Appeals affirms Kevin Higgins’s conviction. The opinion recounts defense counsel’s admission that an AI-produced evidentiary memorandum misstated case holdings because counsel did not read the cited cases, but holds Higgins did not establish Strickland prejudice.

Outside the jury’s presence, the trial judge referred to a written memorandum defense counsel filed regarding the admissibility of said items. During the ensuing colloquy between the trial judge and defense counsel, the trial judge stated that defense counsel’s memorandum misstated the holdings of several cases, whereupon defense counsel admitted that the memorandum was produced …

2026-07-31 · United States District Court for the District of Oregon · 2026 WL 2212298 · provisional

The District of Oregon partially suppresses statements in a criminal case. In resolving the Miranda arguments, the court notes that defense briefing supplied a quotation that does not appear in Smith and admonishes counsel, while recording counsel’s statement that the mistake was not caused by generative AI.

Perhaps recognizing that Smith does not support his argument, Williams resorts to providing a non-existent quotation from the case: “The Ninth Circuit held that officers cannot ‘prevent a suspect from making an unambiguous request for counsel by cutting him off.’ ” Reply, ECF 172 at 9. This Court admonishes Williams's counsel for misquoting Smith, but …

2026-07-31 · United States District Court for the Southern District of New York · 2026 WL 2212887 · provisional

The Southern District of New York compels arbitration and stays a pro se employment case. The opinion separately addresses defendants’ concern that Santana’s opposition used nonexistent case authority attributed to AI, declines sanctions for now, and warns that future inaccurate citations may be sanctioned.

As a final matter, the Court addresses Defendants’ concern that Plaintiff's opposition brief contained citations and quotations to non-existent case authority, which they attribute to his use of artificial intelligence (“AI”). Dkt. No. 55 (“Forrest Defs. Repl.”) at 1–2; Dkt. No. 58 (“Shook Defs. Repl.”) at 1. The Shook Defendants urge the Court to sanction …

2026-07-31 · United States District Court for the Eastern District of Michigan · 2026 WL 2211604 · provisional

The Eastern District of Michigan overrules arbitration-related objections and warns Natashah Al-Ali. The order identifies nonexistent cases and an inaccurate statutory quotation, says the factitious citations appear AI-created, and states that even one future factitious citation may trigger sanctions.

First, Plaintiff's objections contain numerous factitious citations. For example, Plaintiff quotes 9 U.S.C. § 5, but the quote is inaccurate. Additionally, Plaintiff purportedly cites cases such as “Cottman Transmission Sys., Inc. v. Metro. Pontiac GMC, Inc., 351 F. Supp. 2d 343, 347 (E.D. Pa. 2004)” and “McMahon v. RMS Electronics, Inc., 951 F. Supp. 923, …

2026-07-31 · Government Accountability Office · provisional

GAO dismisses JAAW’s bid protest as factually insufficient and separately addresses AI-associated citation problems. The decision notes one nonexistent GAO citation and one irrelevant Federal Circuit citation, declines sanctions because dismissal rests on other grounds, and warns future filings may be sanctioned.

In addition to the factual inaccuracies discussed above, JAAW offered, in support of its protest arguments, citations to five bid protest decisions--two decisions of our Office and three decisions of the U.S. Court of Appeals for the Federal Circuit. ... Based on these inaccurate legal citations, the Army posited that JAAW’s protest “bears indicia consistent …

2026-07-30 · Wisconsin Court of Appeals, District IV · provisional

The Wisconsin Court of Appeals affirms in a credit-union dispute and denies a frivolous-appeal fee request. A footnote says Ashley Smith’s briefs contain false legal citations, warns against repetition, and cautions that generative AI can hallucinate nonexistent cases or misreport holdings.

Smith’s briefs include false legal citations, of which her citation to Gielow is one example. Specifically, and as noted throughout this opinion, some citations misrepresent the content of the cited cases and statutes, and some citations are to legal authorities that exist but are wholly unrelated to the proposition for which they are cited. The …

2026-07-30 · United States District Court for the District of Utah · provisional

The District of Utah grants transfer to Arizona and flags possible improper AI use in plaintiff’s opposition. The order says counsel cited two cases the court could not locate on Westlaw, quotes authority condemning fake opinions, and leaves the matter to the receiving judge.

Before addressing the substance of Defendants’ Motion, the Court calls attention to certain concerns it has regarding the Opposition Plaintiff’s counsel filed on March 10, 2026. In reviewing the Opposition, the Court located a number of case citations suggesting that the improper use of artificial intelligence may have occurred here. For example, the Opposition cites …

2026-07-30 · Texas Court of Appeals, Fourteenth District · provisional

The Fourteenth Court of Appeals affirms a child-custody modification judgment and sanctions Father’s lawyer. The court finds fabricated quotations from Harrison and Swim, unsupported assertions from Lenz and A.S., assumes AI hallucination rather than deliberate deception, and orders three additional hours of AI-focused CLE.

Finally, some discussion of appellant’s brief is warranted. As previously mentioned, appellant’s brief is disjointed and difficult to follow. However, that is not the only shortcoming of appellant’s briefing. It is obvious that appellant’s brief was either (1) the result of using artificial intelligence yielding hallucination citations or (2) a deliberate attempt to mislead this …

2026-07-30 · Texas Court of Appeals, Second District · provisional

The Texas Second Court of Appeals affirms a child-custody modification judgment on rehearing. The opinion notes Mother’s original brief cited a nonexistent case and that her counsel-filed amended brief cited nonexistent case portions and false quotations, but the court resolves the appeal on briefing and merits grounds.

Despite the lengthy preparation time, her opening brief’s purported legal analysis—which advanced six appellate issues—spanned just five pages with zero record references and a citation to a nonexistent case. Cf. Tex. R. App. P. 38.1(i). ... Three months later, on the day Father’s brief was due, Mother moved for leave to file an overhauled amended …

2026-07-30 · United States District Court for the Southern District of New York · provisional

The Southern District of New York denies Nirav Modi’s motion for leave to appeal a bankruptcy order. The court notes Modi used an outside person and AI tool to format the motion, identifies a false Cohen quotation and unsupported AI-generated citations, and dismisses the action.

[H]e claims that because he has no access to a computer or typing facilities in prison, he first wrote “the entire document by hand” and then had “a person outside the prison type[] [his] handwritten notes and input[] them into an [artificial intelligence (‘AI’)] tool to help format the document properly.” Id. at 2. The …

2026-07-30 · United States District Court for the Northern District of Mississippi · provisional

The Northern District of Mississippi dismisses a pro se FCRA suit without prejudice for lack of standing. A footnote identifies two Northern District opinions that the court could not locate, calls them likely AI-generated fictitious citations, declines immediate sanctions, and warns Harris.

While not touched on by the current opinion due to lack of standing, the Court will note that Mr. Harris cited “Allen v. Equifax Info. Services, LLC, 2020 WL 2155673, at 3 (N.D. Miss. Apr. 1, 2020) and LeBlanc v. TransUnion, LLC, 2021 WL 1243659, at 5 (N.D. Miss. Mar. 19, 2021)” to support his …

2026-07-30 · Appellate Court of Illinois, First District · 2026 IL App (1st) 252223-U · provisional

The Illinois First District strikes Tony Cole’s pro se brief and dismisses his appeal. The order identifies authorities that do not support cited propositions and incorrect case citations, says the inaccuracies improperly shifted research burdens to the court, and relies on repeated Rule 341 violations.

Before we can consider the merits of Cole’s contentions, we observe that several of his citations to authorities are incorrect, including attributing propositions to authorities that those authorities simply do not support. For example, citing to Avery v. State Farm Mutual Automobile Insurance Co., 216 Ill. 2d 100 (2005), Cole asserts that claims under the …

2026-07-29 · Court of Appeals of Tennessee · provisional

The Tennessee Court of Appeals affirms a landlord-tenant judgment and disregards fabricated or inaccurate parts of Samuel Robinson’s pro se brief. The opinion says the brief bears AI hallmarks, identifies false case and statutory quotations, a fabricated Tennessee Supreme Court case, and unsupported legal assertions.

Unfortunately, Mr. Robinson’s brief fails to comply with this rule as it contains numerous false quotations from case law and statutes and, in some instances, outright fake citations. In this way, Mr. Robinson’s brief bears all the hallmarks of an artificial intelligence-generated brief, filled with what has been referred to as “hallucinations.” ... Mr. Robinson’s …

2026-07-29 · United States District Court for the Southern District of Ohio · 2026 WL 2184981 · provisional

The Southern District of Ohio dismisses Gragston’s amended employment complaint but permits a motion for leave to amend. A footnote identifies a purported Sixth Circuit hostile-work-environment citation as AI-hallucinated and formally warns that future reliance may bring monetary sanctions or dismissal with prejudice.

As Amazon suggests (but does not expressly state), Gragston seems to rely on AI-hallucinated caselaw in support of this point. (See Doc. 28, #141 n.2). The Court's independent review suggests the same. Gragston cites a case that he refers to as “Latham v. Off. of Att'y Gen. of Ohio, No. 20-4089, 2021 WL 1324065 (6th …

2026-07-29 · United States District Court for the District of Colorado · provisional

The District of Colorado magistrate judge recommends summary judgment and grants discovery-fee sanctions in part. The order separately finds Maloit’s briefs contain misquotations, misstatements, and seven nonexistent cases likely from generative AI, then orders her to show cause about additional sanctions.

Finally, it has come to the Court’s attention that Plaintiff’s Response briefs in opposition to the instant Motion for Summary Judgment [#91] and Motion for Sanctions [#87] contain defective citations to case law. These defects include (1) misattributed or inaccurately quoted language from cases, (2) misrepresentations of legal concepts associated with the cited cases, and, …

2026-07-29 · United States Court of Appeals for the Tenth Circuit · provisional

The Tenth Circuit affirms dismissal of Shantell Robinson’s claims with prejudice as a Rule 11 sanction. The order describes nonauthentic evidence, at least four filings with nonexistent or misrepresented authority, and a new appellate brief citation to the nonexistent Reynolds v. Smith case.

The district court’s order detailed the clear and convincing evidence it relied on to determine that Ms. Robinson’s conduct was sanctionable. The court noted that despite her claims that her emergency motion was “grounded in fact,” Ms. Robinson submitted “no evidence to support the veracity of the purported intercepted statements” about Mr. Raines following her, …

2026-07-28 · United States District Court for the Northern District of Texas · provisional

The Northern District of Texas denies disqualification motions in a commercial dispute. The opinion notes briefing problems, including one nonexistent Northern District citation likely caused by imprudent generative-AI reliance, and admonishes pro hac vice counsel about responsible AI use and Rule 11 obligations.

The filings in this case are riddled with inaccurate citations, seemingly deliberate misrepresentations of guiding caselaw and the factual record, failures to comply with Court rules, and, in at least one instance, advocacy using caselaw that does not exist, likely the result of imprudent reliance on a generative artificial intelligence tool. ... (See Int. Resp. …

2026-07-28 · United States District Court for the District of Oregon · provisional

The District of Oregon denies self-represented defendants’ dismissal, transfer, and anti-SLAPP motions. Before reaching the merits, the order records withdrawn and additional false citations in Askew’s briefing and warns all parties that future false or hallucinated citations may be sanctioned.

In the course of briefing her motion to dismiss and in response to Plaintiff’s filings, Ms. Askew acknowledged that she relied on a false citation, “Young v. Maciorca, 69 F.4th 1099, 1106 (9th Cir. 2023).” ECF No. 92. Ms. Askew subsequently withdrew her references to “Young v. Maciorca,” which is not a Ninth Circuit decision. …

2026-07-28 · United States District Court for the District of Maine · provisional

The District of Maine grants summary judgment to the Social Security Commissioner and dismisses Alexander McNeil’s amended complaint. A footnote flags several nonexistent or fabricated legal authorities in the pro se pleadings and cautions McNeil to personally verify each future citation.

The Court notes the presence of several citations to nonexistent or fabricated legal authority in Plaintiff's pleadings. “Although courts are solicitous toward pro se litigants, there are reasonable limits”—“a pro se litigant must not provide the Court with erroneous and factitious citations and has an obligation to review documents filed with the Court to make …

2026-07-28 · United States District Court for the District of Maryland · provisional

The District of Maryland denies discovery sanctions in a pro se employment case and addresses possible generative-AI misuse. The court says Campbell’s filings do not outright hallucinate cases but misdescribe Aguilar and Mancia, corroborating admitted tool use, and cautions that future errors may draw fees or sanctions.

One other consideration worth discussing is the potential misuse of generative artificial intelligence. The parties dedicate a substantial portion of their respective filings to whether Campbell’s motions involve improper use of or reliance on generative artificial intelligence, including whether she misstates legal authority or she uploaded confidential documents into a generative artificial intelligence program. ... …

2026-07-28 · Appellate Court of Illinois, First District · 2026 IL App (1st) 251462

The Illinois First District affirms dismissal of Kimberly Scott’s discrimination charge and sanctions attorney Mason Cole. The opinion says ChatGPT produced 10 false citations or quotations, fines Cole $15,000 at $1,500 per misstatement, and directs the clerk to send the opinion to the ARDC.

We also sanction petitioner’s attorney Mason Cole for submitting briefs containing false citations and quotations that are the product of artificial intelligence (AI) hallucinations. ... Petitioner’s briefs also contain false case citations. One such case, “Harris v. Illinois Human Rights Comm’n, 2022 IL App (1st) 210454,” does not exist at all. The citation 2022 IL …

2026-07-28 · United States District Court for the District of Arizona · 2026 WL 2167989 · provisional

The District of Arizona expands an AI show-cause inquiry against Elizabeth Tate. The order recounts Tate’s Claude AI workflow, finds that list-based cite checking missed false quotations in several filings, criticizes delegating whole-brief drafting to Claude, and requires a supplemental memorandum.

On July 8, 2026, the Court issued an order to show cause (“OSC”) requiring Plaintiff's counsel, Elizabeth Tate, to show cause why she should not be sanctioned or disciplined for including, in Plaintiff's response to Defendant's motion for attorneys’ fees, two false quotations from Ninth Circuit cases. ... Ms. Tate utilized Claude AI to help …

2026-07-27 · Minnesota Court of Appeals · provisional

The Minnesota Court of Appeals affirms summary judgment for Ally Bank. At the end of the opinion, the court defines fabricated authority, identifies three nonexistent citations and many unsupported legal propositions in Ngouambe’s pro se informal brief, and disregards them when evaluating the merits.

We conclude by addressing fabricated authority in Ngouambe’s brief to this court. Fabricated authority includes citations to authority that do not exist, quotations that do not appear in the cited authority, and asserted propositions of law not reasonably attributable to the cited authority. Ngouambe’s informal brief contains fabricated authority in the form of three citations …

2026-07-27 · United States District Court for the Eastern District of Michigan · provisional

The Eastern District of Michigan resets a pro se FCRA case by striking pending motions and setting aside default. The order cautions both sides after a brief cites Antoine for a quotation and proposition not found there, warning that generative-AI phantom cases can trigger Rule 11 sanctions.

Finally, the Court issues a caution about the use of generative artificial intelligence (“AI”). It appears from the briefing that one or both parties may be utilizing AI to draft their briefs. (See, e.g., ECF No. 20, PageID.71 (citing Antoine v. Atlas Turner, Inc., 66 F.3d 105, 110 (6th Cir. 1995) for a quotation and …

2026-07-24 · United States District Court for the Western District of Washington · provisional

The Western District of Washington sanctions Jocelyn Stewart in the LeDoux litigation. The order finds Stewart used ChatGPT and Claude without verifying outputs, causing dozens of false citations across briefs and expert reports, and imposes a $3,000 personal sanction plus future citation certifications.

In November and December 2025, Plaintiff Joann LeDoux submitted multiple filings containing dozens of inaccurate factual and legal citations which appeared “hallucinated” by a generative artificial intelligence tool. On February 4, 2026, the Court ordered Plaintiff’s counsel, Ms. Jocelyn Stewart, to show cause and explain why she should not be sanctioned for these errors. ... …

2026-07-24 · United States District Court for the Eastern District of California · 2026 WL 2138081 · provisional

The Eastern District of California recommends dismissing Graves’s utility-pole claims with leave to amend and denies e-filing. A footnote identifies two nonexistent California cases, notes that Pierce does not support the cited limitations point, and warns about AI research and Rule 11 sanctions.

Plaintiff cites to Boling v. Pub. Utils. Comm'n, 105 Cal.App.3d 805 (1980) and Loving v. Cnty. of Stanislaus, 33 Cal.App.5th 444 (2019), which are not real cases. Plaintiff also cites to Pierce v. Cnty. of Orange, 526 F.3d 1190 (9th Cir. 2008), which does not discuss statute of limitations or continuing violation issues. At the …

2026-07-23 · United States District Court for the District of Columbia

The District of Columbia district court transfers Catarina Almeida Porfirio’s visa case to the Northern District of Texas. The court says plaintiff’s opposition brief contains nonexistent quotations, nonexistent cases and misstatements of law bearing the hallmarks of reliance on an AI tool, but leaves any inquiry to the transferee court.

It is not acceptable to submit filings to the Court containing false, misleading, or nonexistent quotations or authorities. Such conduct contravenes an attorney’s duty toward their client to exercise professional judgment and responsibility. See Park v. Kim, 91 F.4th 610, 614 (2d Cir. 2024). In particular, Rule 11(b)(2) of the Federal Rules of Civil Procedure …

2026-07-22 · District Court of Appeal of Florida, Fourth District

The Florida Fourth District Court of Appeal affirms a fee order against Rose Gouldy and separately orders her to show cause why she should not be barred from further pro se filings. The court says her brief uses phantom authority, record misstatements and fabricated quotations likely produced with AI.

This case demonstrates a growing problem in Florida’s appellate courts. The recent change in jurisdiction has given intermediate appellate courts jurisdiction to hear appeals from county court cases. The result has been that the amount of pro se appeals has significantly increased. Initially, the appellate courts were able to expeditiously handle the county court appeals. …

2026-07-16 · Indiana Tax Court

The Indiana Tax Court denies Chryshawna and Jeremy Webb’s pro se motion to supplement an administrative tax record. In a note on artificial intelligence, the court says cited rules did not support the Webbs’ propositions, admonishes them for likely generative-AI use, and imposes no further penalties.

NOTE ON THE USE OF ARTIFICIAL INTELLIGENCE The Webbs refer to various court rules in their motion to support their request to supplement the record. While the rules the Webbs cite do exist, they plainly do not stand for any of the propositions that the Webbs advance. This leads the Court to believe that the …

2026-07-10 · United States Court of Appeals for the Eleventh Circuit

The Eleventh Circuit affirms summary judgment for the Florida Department of Corrections and grants sanctions relief against Parnell’s counsel. The court strikes defective reply-brief material, awards fees for the sanctions motion, and refers counsel after finding two non-existent opinions and at least five non-existent quotations.

The FDOC has moved for sanctions under Federal Rule of Appellate Procedure 27 and our inherent authority, seeking attorney’s fees and to strike portions of Parnell’s reply brief. The FDOC argues that Parnell’s reply brief cites two non-existent court opinions and at least five non-existent quotations from our opinions. Parnell responds that he withdraws any …

2026-07-10 · United States Court of Appeals for the Eleventh Circuit

The Eleventh Circuit affirms dismissal of claims against Atlas Air and Flight Services International while referring plaintiffs’ counsel Anthony F. Sabatini for discipline. The court says his opening and proposed reply briefs contained repeated hallucinated case citations and that unverified AI-generated briefing violated duties to clients and the court.

Though the filings in this case were substandard in a variety of ways, we have saved the worst for last. The plaintiffs’ counsel Anthony F. Sabatini’s filings are riddled with citations to nonexistent, “hallucinated” cases. His opening brief relies on at least eight such cases, including one purportedly decided by this Court. After the defendants …

2026-07-08 · District Court of Appeal of Florida, Second District

The Florida Second District Court of Appeal affirms orders against Cynthia Hulse-Gibson without comment. The panel separately cautions the self-represented appellant that her briefs contained mismatches among propositions, case names and citations, and warns that unverified generative-AI legal research can expose filers to sanctions.

We affirm the orders on appeal without comment. We write, however, to caution Cynthia Hulse-Gibson about using generative AI in any future pro se filings without verifying the accuracy of the results. Hulse-Gibson's briefs here are replete with mismatches involving the purported legal proposition, the case name, and the reporter citation. See Fletcher v. Experian …

2026-07-01 · Court of Chancery of Delaware

The Delaware Court of Chancery orders Richard P. Rollo and Richards, Layton & Finger to show cause over GenAI errors in an answering brief. The court says counsel did not verify citations, left fabricated legal synthesis in a corrected filing, and must address Rule 11 and firm-supervision issues.

GenAI offers a powerful tool to streamline legal practice and assist in advocacy. Using GenAI in preparing court filings is “not inherently problematic”—provided the attorney (or litigant) carefully verifies the accuracy of the output. Here, counsel acknowledges that the GenAI output was not verified before the Answering Brief was filed. The submission of hallucinated legal …

2026-06-26 · Ohio Court of Appeals, First Appellate District · 2026-Ohio-2432

The Ohio First District Court of Appeals resolves post-divorce property disputes, denies Victoria Morgan’s request to sanction self-represented Mark Jones, and denies a vexatious-litigant motion. The court says Jones’s two phantom citations bear the hallmarks of AI hallucinations but predate its local AI rule.

Morgan suggests that these phantom cases may be artifacts from the use of generative artificial-intelligence (“AI”) software drawing upon large language models. Appellate courts across Ohio and the country have experienced a surge of filings with such “hallucinations”—i.e., false citations proffered as true by generative AI. Jones neither confirms nor denies the allegation that he …

2026-06-26 · Alabama Court of Civil Appeals

The Alabama Court of Civil Appeals grants part of a mother’s mandamus petition. In dissent, Judge Bowden says the petition should be dismissed because the mother relied on AI-generated hallucinations and misrepresented real holdings, warning that granting relief leaves fake citations without repercussions.

The mother primarily relied on AI-generated hallucinations and misrepresentations of holdings in real cases. Rule 21(a)(1)(F), Ala. R. App. P., requires petitioners to include “[a] statement of the reasons why the writ should issue, with citations to the authorities and the statutes relied on” in a petition for the writ of mandamus. Four of the …

2026-06-23 · Supreme Court of New York, Appellate Division, Second Department · 2026 NY Slip Op 03935

The New York Appellate Division, Second Department sanctions attorney Michael Sanders and Law Offices of Michael S. Lamonsoff, PLLC after an appellate brief used GenAI-assisted research. The court finds nonexistent cases, fictitious Court of Appeals quotations and misstatements, ordering $8,000 and $2,500 sanctions.

In this case, we impose sanctions upon an attorney and a law firm for submitting a brief, prepared with the assistance of generative artificial intelligence (hereinafter GenAI), containing citations to nonexistent cases, fictitious purported Court of Appeals quotations wholly contrary to actual law, and misrepresentations about what certain real cases actually held or decided. As …

2026-06-22 · Court of Appeals of Indiana

The Indiana Court of Appeals affirms multiple orders in Hoagland Family Limited Partnership’s sewer-system dispute with Clear Lake. While rejecting one appellate argument, the court says a Fox v. Fox citation and quotation did not exist, likely came from generative AI, and reminds counsel of candor duties.

This case appears to not exist. The reporter citation provided—“521 N.E.2d 1240”—leads to People v. Pira, 521 N.E.2d 1236 (Ill. App. Ct. 1988) (beginning on page 1236, ending on page 1243). The pincite provided—“521 N.E.2d [at] 1244”—leads to Hauk v. Day, 521 N.E.2d 1243 (Ill. App. Ct. 1988) (beginning on page 1243, ending on page …

2026-06-17 · Michigan Court of Appeals

The Michigan Court of Appeals affirms denial of Joyce Barber’s new-trial motion but sanctions her counsel for AI-related citation failures. The court holds that repeated fabricated and unsupported authorities violated Michigan court rules, remands to determine defendant’s actual damages and expenses, and refers counsel for possible investigation.

Counsel’s explanation does not excuse the violation. Artificial intelligence may be a useful tool for legal research and drafting, but the use of such technology does not alter an attorney’s professional obligations. Lawyers remain responsible for the filings they sign and submit. They must verify that cited authorities exist, read the authorities on which they …

2026-06-16 · Court of Appeals of Indiana

The Indiana Court of Appeals affirms a custody order in Holstein v. Holstein and denies Mother’s request for $5,000 in sanctions. The court says Father’s counsel included citations from his client without verification, corrected them promptly, and receives a warning rather than a monetary sanction.

These circumstances present an opportunity for this court to reemphasize the importance of verifying every citation, holding, and quote a litigant selects for inclusion in his or her filings to a court. We expect this even more so from an attorney when case-related information is provided by his non-lawyer client for use in his brief. …

2026-06-15 · United States Court of Appeals for the Tenth Circuit · provisional

On 2026-06-15, in Andria Borsody v. Frontier Heritage Communities, the Tenth Circuit affirmed dismissal and upheld the district court's admonition that the self-represented appellant verify case citations before relying on AI-assisted briefing. A self-represented appellant cited Alford v. City of Canon City even though the court found the authority did not exist.

As we will discuss, the district court confirmed no such case exists and admonished Ms. Borsody to refrain from using AI when drafting legal documents without confirming the accuracy of citations. We too have confirmed “Alford v. City of Canon City” is not a real case. In October 2025, while Frontier’s motion to dismiss was …

2026-06-12 · Court of Appeals of Texas · provisional

On 2026-06-12, in Shaddai Harris v. Nadia Lyotard and Mitchell Sadler, Court of Appeals of Texas struck the appellant's original briefs, required an amended brief, and then decided the appeal on the redrawn briefing. A self-represented appellant filed a reply brief using at least four nonexistent or hallucinated authorities and authorities used for propositions they did not support.

–4– Appellant initially filed a brief raising sixteen appellate issues.1 The brief contained at least four hallucinated citations and at least twenty citations which do not stand for the proposition or holding for which they are presented. After appellees filed their brief, appellant filed a reply brief with at least two hallucinated citations and at …

2026-06-12 · Supreme Court of New York · 2026 WL 1811875 · provisional

On 2026-06-12, in Vargas v. MTA Bus Co, Supreme Court of New York amended its prior order and declined to attribute the non-existent citations in duplicated opposition papers to appellate counsel. Counsel filed opposition papers using nonexistent or hallucinated authorities.

The prior decision and order acknowledged the non-existent cases, but the proposition of law in those non-existent citations was, in fact, true. As the filing of identical motion papers in Paez Rodriguez is intended to cure a mistaken belief that “consolidated motion practice” was permissible, this court will not attribute the non-existent citations to appellate …

2026-06-12 · United States District Court for the Southern District of New York · provisional

On 2026-06-12, in Jason Wimberly v. Verizon New York Inc, the Southern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a reply brief using nonexistent or hallucinated authorities.

Courts have previously observed that a citation to a nonexistent case suggests that Plaintiff may have used a form of generative artificial intelligence (“genAI”) to draft submissions to the Court and that genAI hallucinated the phantom case citation. See Park v. Kim, 91 F.4th 610, 614 (2d Cir. 2024) (discussing case cited in a reply …

2026-06-11 · United States District Court for the Eastern District of Texas · 2026 WL 1746259 · provisional

On 2026-06-11, in McCormick v. Texakoma Financial, the Eastern District of Texas publicly reprimanded plaintiff's counsel, imposed $6,000 in sanctions, ordered firmwide citation review, and required AI-focused CLE. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

The Reply also flagged fake quotes and unsupported propositions. Ginsburg did not file a sur-reply or move to remedy this problem. The Order to Show Cause. After reviewing the veracity of Defendant's claim that Ginsburg submitted a brief with fraudulent citations, the Court issued an order to show cause on May 15, 2026 (Dkt. #23). …

2026-06-11 · Court of Appeal of California, First Appellate District · provisional

On 2026-06-11, in Quinteros v. Harbor Distributing, LLC, the California First District Court of Appeal imposed $6,000 in sanctions payable to the court and referred counsel to the California State Bar. Counsel filed opposition papers using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

adequate record on an issue requires that the issue be resolved against [appellant]”].) on Plaintiff’s multiple misrepresentations and erroneous citations of authority” that “permeate[] Plaintiff’s opposition.” On July 8, the court issued a tentative ruling granting Harbor’s motion to stay under the court’s inherent authority and the doctrine of exclusive concurrent jurisdiction and noticing in …

2026-06-11 · Arizona Court of Appeals, Division One · provisional

On 2026-06-11, in Villanueva v. Bowers, Arizona Court of Appeals, Division One awarded $1 in costs or fees caused by the defective legal authorities. A self-represented appellant filed an opening brief using nonexistent or hallucinated authorities. The monetary component was $1.

Mother's opening brief contained citations to a non-existent case, citations to cases with incorrect and impossible pin cites, citations to a memorandum decision issued before 2015, and other errors. Father noted these issues in his answering brief and argued Mother's arguments should be considered waived. Mother responded to this argument by denying the errors and …

2026-06-10 · Iowa Court of Appeals · provisional

On 2026-06-10, in State of Iowa ex rel J.G. v. Mynesia A. Anderson, Iowa Court of Appeals dismissed the appeal after the appellant failed to comply with its order addressing fabricated authorities in her briefs. A self-represented appellant filed a petition using quotations that did not appear in the cited source and at least eight nonexistent or hallucinated authorities.

Her briefs also cited two Iowa cases that do not exist; the reporter citations provided are for other states and cases unrelated to the cited propositions. We have addressed this phenomenon—problematic filings apparently “written” by artificial intelligence (AI)—in other cases. See Nisland Asset Inv., LLC v. Gericke, No. 25-0659, 2026 WL 1162553, at *1 (Iowa …

2026-06-10 · United States Bankruptcy Court for the Northern District of Indiana · 2026 WL 1815400 · provisional

On 2026-06-10, in In re Garcia-Martz, the Northern District of Indiana Bankruptcy Court ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.

Figure 3 below cites the 13 deficient arguments previously mentioned above; captures additional questionable arguments, misleading quotes, a non-existent Bankruptcy Rule; internally inconsistent and contradictory arguments; and describes other problems with the Trustee's Brief. The Court would not have a problem if the issues below were isolated, or if only a few of them appeared. …

2026-06-10 · United States District Court for the Northern District of Illinois · 2026 WL 1678232 · provisional

On 2026-06-10, in Ifeoma Delliane Chinedu Obi v. Cook County, Illinois, et al, the Northern District of Illinois struck the latest defective filing and imposed monetary sanctions for repeated AI-hallucinated arguments and cases. A self-represented litigant cited Andrade v. Arby Concessions, 88 F.4th 1014 (7th Cir. 2023) even though the court found the authority did not exist.

Obi continues to submit AI hallucinated arguments and cases. On page 7, she asserts that “The district court acknowledged on page 7 that ‘a federal court may hear a claim alleging a state court judgment is void forlackofjurisdiction.’ItcitedAndradev.ArbyConcessions, 88F.4th1014(7thCir.2023).”(Dkt.100at7).Theentiretyof that assertion—the quote, case, and “acknowledgement”—is made up. (Compare id. with Dkt. 88). Obi is a …

2026-06-10 · Court of Appeals of Georgia · provisional

On 2026-06-10, in Henry County Schools et al. v. Grant et al, Court of Appeals of Georgia vacated the order denying dismissal of the Title VII claims and remanded for reconsideration using proper standards and real case law. The trial court's order relied on at least one nonexistent or hallucinated authority and authorities used for propositions they did not support.

In addition to citing federal law applicable to motions to dismiss and confusing constitutional claims with employment discrimination, it also ignores binding Georgia precedent, mis-quotes cases cited, and relies on at least one hallucinatedcase.Wefindittroublingthatcounselsubmittedsuchanordertothetrial court, and regrettable that the trial court failed to identify any of these errors. See Paynev.State,CaseNo.S26A0459,slipop.at1-5(1)-(4),2026WL1215905(Ga.May 5, 2026) (sanctioning counsel who …

2026-06-09 · United States District Court for the Eastern District of Pennsylvania · provisional

On 2026-06-09, in Casey A. Gaddy v. Wood Brothers Bar, Inc., et al, the Eastern District of Pennsylvania admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant filed a motion using record or transcript quotations not found in the record, quotations that did not appear in.

He speculates about Gillespie’s motives and saturates his briefing with immaterial and misrepresented facts, apparently hallucinated by artificial intelligence. The record shows Gillespie fired Gaddy because he concluded after investigating that Gaddy fudged the customers’ tips. The Court grants defendants’ motion. I Customers and staff at Woody’s and Voyeur are mostly gay, bisexual or queer …

2026-06-09 · United States District Court for the Southern District of New York · provisional

On 2026-06-09, in LiveVideo.AI Corp. v. Redstone, the Southern District of New York awarded more than $85,000 in fees and costs and referred counsel to the district grievance committee. Counsel filed a motion using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.

Constants also admitted that “he did not prepare, review, or file at least one of plaintiffs motions,” and nearly all of the motions in this matter contain the hallmarks of artificial intelligence (“Al”) fabrication, including non-existent hallucinated cases, formatting unchanged from that produced by Al platforms, and remnants of prompts that the drafter declined LEGAL …

2026-06-09 · United States District Court for the Middle District of Florida · provisional

On 2026-06-09, in Leafwell, Inc. v. The Doc App, Inc, the Middle District of Florida declined to add new sanctions but warned counsel that the order could support future professional-discipline proceedings. Counsel filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Across these motions, the Court finds Castro: (1) overstated the breadth of four cases; (2) discussed a non-existent count; (3) completely misrepresented five cited authorities; and, most troubling of all, (4) failed to take responsibility for clearly failing to review his motions. Leafwell requests the Court dismiss with prejudice My Florida Green’s related claims against …

2026-06-09 · United States District Court for the District of Colorado · provisional

On 2026-06-09, in Tlingit Haida Tribal Business Corporation v. OnePromom, the District of Colorado ordered plaintiff to show cause why the filing was not sanctionable and whether counsel complied with professional obligations. Counsel filed a motion using quotations that did not appear in the cited source.

However, the Amended Complaint alleges that the Employee Handbook contains certain language that does not appear in the document filed by Defendants. Compare [Doc. 24 at ¶¶ 42–47], with [Doc. 34-1]. Because the Court cannot verify the accuracy of the document filed by Defendants, the Court declines to consider it in ruling on the Motion …

2026-06-09 · United States District Court for the District of Arizona · provisional

On 2026-06-09, in Perry v. Merrick Bank Corporation, the District of Arizona dismissed the complaint without leave to amend and noted the plaintiff's prior hallucinated citations in related litigation. A self-represented litigant filed a response using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.

2026) (granting defendant’s motion to compel arbitration, in response to Plaintiff’s “90-page complaint [that] assert[ed] 18 causes of action under federal and state law,” and noting that Plaintiff’s filings included at least one “hallucinated citation” as well as “fake quotations” misattributed to real cases). … … … Court Action. Restatement (Second) of Judgments § 13, …

2026-06-08 · District Court of Travis County, Texas, 250th Judicial District · provisional

On 2026-06-08, in Erica Whitesock v. Bird Global, Inc., and The City of Austin, the Travis County district court granted the City of Austin's jurisdictional plea, dismissed those claims with prejudice, and awarded $10,000 in attorney fees. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.

✳ ✳ ✳ As counsel for the City of Austin has noted, Plaintiffs’ response to the City’s plea to the jurisdiction contains a non-existent quotation of a legal authority. The response falsely quotes the Texas Tort Claims Act as containing an exception to governmental immunity for “engaging in a proprietary function, including . . . …

2026-06-08 · United States District Court for the Western District of Tennessee · provisional

On 2026-06-08, in Bailey v. Sedgwick Claims Management Services, Inc, the Western District of Tennessee required a corrected motion after counsel disclosed AI-hallucinated citations, but declined to impose sanctions at that point. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

Apparently that AI program hallucinated over some citations. As a result, the Court required Plaintiff’s counsel to correct the citations and submit a Corrected Motion. They did so. (ECF No. 94.) The Sixth Circuit has recently addressed the role of AI in the realm of litigation. That court imposed significant sanctions and pointed out that …

2026-06-08 · United States District Court for the Northern District of Mississippi · provisional

On 2026-06-08, in Withers v. City of Aberdeen, the Northern District of Mississippi revoked pro hac vice admission, disqualified resident counsel, fined counsel $8,000, and referred the matter to bar authorities. Counsel filed opposition papers using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

On December 10, 2025, the Court entered an Order to Show Cause [110] directing all counsel of record in this case to show cause as to why the Court should not impose sanctions against them pursuant to Rule 11 of the Federal Rules of Civil Procedure, the Court’s Local Rules, and/or its inherent authority for …

2026-06-08 · Minnesota Court of Appeals · provisional

On 2026-06-08, in Young v. Young, Minnesota Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a brief using record or transcript quotations not found in the record, quotations that did not appear in.

Our review of father’s brief shows that it contains many citations to caselaw that either do not exist—sometimes referred to as “hallucinations”—or do not support his legal argument. And father’s brief inaccurately quotes statutes and the record. Our review also leads us to believe that father may have used generative artificial intelligence (AI) to write …

2026-06-08 · United States District Court for the Northern District of Illinois · provisional

On 2026-06-08, in Allison v. Shutterfly LifeTouch LLC, the Northern District of Illinois warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant cited || Misrepresented: Case Law | Plaintiff characterized Norberg v. Shutterfly as even though the court found the authority did not exist.

In any event, Norberg is a district court case—it is not precedential, and certainly not “controlling.”2 Allison’s mischaracterization of the cases he cites, as well as his filing of prior documents that include citations to fictitious cases, are “hallmarks of a so-called AI hallucination, a circumstance where anAI large language model generates an output that …

2026-06-05 · Kansas Court of Appeals · provisional

On 2026-06-05, in Kendall E. Scheer v. Scheer Farms, LLC, Kansas Court of Appeals affirmed summary judgment, while a concurrence admonished the appellant over fake case citations and quotations in his brief. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.

I would, however, address the appellant's use of several fake case citations in his brief. An appellate brief containing nonexistent case citations or fake legal authority needlessly undermines the validity of a party's arguments. Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 448-49 (S.D.N.Y. 2023). Here, the appellant's brief—as noted by the appellee—contains several …

2026-06-04 · Supreme Court of Oregon · provisional

On 2026-06-04, in Mary McGreevy v. Adam Witkin, Supreme Court of Oregon struck the response to the petition for review, imposed a $500 sanction, and granted judicial notice. A self-represented appellant filed a response using nonexistent or hallucinated authorities. The monetary component was $500.

Petitioner on review filed a reply to the response that argued, among other things, that respondent on review’s "response relies on authorities that cannot be located in the Oregon Reports." On March 26, 2026, respondent on review filed a response to the reply that addressed petitioner's other arguments but did not address the assertion about …

2026-06-04 · United States District Court for the Eastern District of New York · 2026 WL 1413883 · provisional

On 2026-06-04, in Owens v. Select Portfolio Servicing, Inc, the Eastern District of New York 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 and at least four nonexistent or hallucinated authorities.

The use of fake or misleading citations violates this rule and wastes the opposing party’s and the Court’s time by requiring them to parse through the citations to determine which points of law, if any, are accurate. See Perez v. Evans, 24-CV-356, 2025 WL 2726792, at *4 (S.D.N.Y. Sept. 25, 2025) (determining that a plaintiff’s …

2026-06-04 · Appellate Court of Maryland · provisional

On 2026-06-04, in Lafaye B. Brown v. James E. Clarke, et al, Appellate Court of Maryland affirmed the foreclosure rulings and noted that the appellant's reply brief used a quotation found nowhere in Maryland or other case law. A self-represented appellant filed a reply brief using quotations that did not appear in the cited source.

at 728. As a result, the Substitute Trustees have standing to foreclose. Thus, Brown’s motion to stay or dismiss did not raise a valid defense to the Substitute Trustees’ right to foreclose, and the circuit court therefore did not abuse its discretion in denying it without a hearing. JUDGMENT OF THE CIRCUIT COURT FOR BALTIMORE …

2026-06-04 · Court of Appeals of Georgia · provisional

On 2026-06-04, in Washington v. Washington, Court of Appeals of Georgia warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source and multiple nonexistent or hallucinated authorities.

As an initial matter, we are troubled by Mother’s citation to fictitious cases and fictitious quotations throughout her appellate brief. “Such ‘hallucinated’ cases are typically a hallmark of the irresponsible use of regenerative artificial intelligence (A.I.)inlegaldrafting.”Slayv.Ross,379Ga.App.1,1(927SE2d 569)(2026).While Motherisprose,sheisnonethelessrequiredtofollowtherulesofthisCourt,andwe caution her that any future filings in this Court containing fictitious cases and/or fictitious quotations may result …

2026-06-04 · United States District Court for the District of Colorado · provisional

On 2026-06-04, in Y.S. v. John Doe, et al, the District of Colorado warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant submitted a filing using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Judge Starnella concluded that pseudonymity is not warranted in this case because the record shows that the individuals that threatened Plaintiff already know his name and address, and that he has not faced 1 In his argument that Judge Starnella mischaracterized his request as a fishing expedition, Plaintiff cites to hallucinated cases and misattrib- utes …

2026-06-04 · United States Court of Appeals for the Fifth Circuit · provisional

On 2026-06-04, in Kisha Peters v. Banner Health, the Fifth Circuit struck the defective appellate filings, admonished the appellant, and warned that additional violations could draw sanctions. A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

motions and other papers that “strain[ed] the [district] [c]ourt’s ability to manage its docket efficiently.” After a four-month span in which she filed fifty-five motions, the court ordered that Peters “must request leave of court before filing any Motion, Notice, Request, or any other document.” Peters repeatedly violated this and other explicit court orders by …

2026-06-03 · United States District Court for the Western District of North Carolina · provisional

On 2026-06-03, in Wayne K. Smith, Sr. v. Polk County, et al, the Western District of North Carolina ordered plaintiff's counsel to show cause about two fabricated quotations and compliance with the court's AI-use standing order. Counsel filed an opening brief using quotations that did not appear in the cited source.

Artificial Intelligence The Defendants contend that the Plaintiff’s memorandum in support of the instant motion contains two fabricated quotations, along with multiple quoted statements lacking citation to any authority, and that such deficiencies suggest that the memorandum was drafted using artificial The Plaintiff complains that the Defendants tookthe “position” throughout discovery “that neither the vehicular …

2026-06-03 · United States District Court for the Western District of Missouri · provisional

On 2026-06-03, in Euphoric, LLC et al. v. Westport Community Improvement District, et al, the Western District of Missouri admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. Counsel filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

“The covenant of good faith and fair dealing cannot be relied upon to overcome the parol evidence rule and add terms to a contract that do not exist,” and is not “an ever[]flowing cornucopia of wished-for legal duties,” in that it “cannot giverise to new obligations not otherwise contained in a contract’s express terms.” DePeralta …

2026-06-02 · United States District Court for the Western District of Washington · provisional

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.

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 …

2026-06-02 · United States District Court for the Western District of Tennessee · provisional

On 2026-06-02, in Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al, the Western District of Tennessee ordered Reaves Law Firm to pay costs for improper citations and directed counsel to send the order to professional regulators. Counsel cited Press v. Vanderbilt University even though the court found the authority did not exist.

Specifically, Defendants’ response to RLF’s Partial Motion to Dismiss asserts that Plaintiff relies on cases that do not stand for the propositions for which they are cited, and, even worse, RLF includes quotations from those cases that do not exist. (See ECF No. 19.) Two days after Defendants initially raised the GAI issues, RLF filed …

2026-06-02 · United States District Court for the Middle District of North Carolina · provisional

On 2026-06-02, in Anthony Josue Grajales v. Santander Consumer USA Inc., et al, the Middle District of North Carolina sanctioned the plaintiff $120, stayed the case until payment, and required copies of cited authorities with future filings. A self-represented litigant filed a response using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities, and.

149.) In addition, it appears Plaintiff has also been using some form of generative artificial intelligence resulting in citations which are hallucinations or other improper citations. (See Doc. 223 at 6-7 and 12-16). Defendants identify that in one of Plaintiff’s numerous responses, he made a total of “one hundred fifteen false citations.” (Doc. 186 at …

2026-06-02 · Missouri Court of Appeals · provisional

On 2026-06-02, in Boatner v. Hickerson, Missouri Court of Appeals imposed a $10,000 monetary sanction for the defective legal authorities. A self-represented appellant cited Davis v. Bess even though the court found the authority did not exist. The monetary component was $10,000.

Boatner’s appeal violates several Missouri Supreme Court Rules, including the briefing requirements of Rule 84.04, and her amended brief includes fictitious cases generated by artificial intelligence (“A.I”), which prevent this Court from engaging in meaningful review. Accordingly, the appeal is dismissed. Additionally, given the frivolousness of the appeal, this Court awards $10,000 in damages to …

2026-06-02 · United States District Court for the Eastern District of Michigan · 2026 WL 1556473 · provisional

On 2026-06-02, in Patrick C. Shaltry v. Donna Collins, et al, the Eastern District of Michigan magistrate judge recommended dismissal and noted a false Sixth Circuit citation while denying further relief. A self-represented litigant cited Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016) even though the court found the authority did not exist.

3 Judge Morris also noted Plaintiff's “troubling” pattern of misquotes, false quotations, and false citations throughout his briefs. This court likewise notes that in his briefing, Plaintiff stated the following proposition: “The Sixth Circuit likewise holds that a conviction on appeal is not final. Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016).” ECF No. …

2026-06-01 · United States District Court for the Eastern District of Wisconsin · provisional

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.

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 …

2026-06-01 · Supreme Court of New York · 2026 WL 1872259; 2026 N.Y. Slip Op. 50994(U) · provisional

On 2026-06-01, in Sharei Torah v. Hendel, Supreme Court of New York struck defendants' amended answer and counterclaims and awarded plaintiff costs and fees for responding to unsupported citations. A self-represented litigant cited Ennis v. Lessing even though the court found the authority did not exist.

Directing that all service in this matter be made upon [Defendant] Mendel Hendel via email to mmhendel@gmail.com; and 10. Granting such other and further relief as the Court deems just and proper.” (NYSCEF Doc. No. 133) a. Plaintiff's first and second branches of its motion: The first two (2) branches of relief sought by Plaintiff …

2026-06-01 · United States District Court for the District of Massachusetts · provisional

On 2026-06-01, in Richard A. Cole v. Midland States Bank, et al, the District of Massachusetts admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant filed a motion using authorities used for propositions they did not support and a nonexistent rule or legal standard.

June 30 , 2023) ("Because Johnson claims that Wells Fargo failed to deposit funds into his account- as opposed to transfer funds outside of his account-the provisions of section 1693h do not appear to apply to Plaintiff ' s allegations . " ) . The complaint makes clear that Jonathan , not Cole , instructed …

2026-06-01 · United States Court of Appeals for the Seventh Circuit · provisional

On 2026-06-01, in Heriberto Perez-Castillo v. Todd W. Blanche, the Seventh Circuit sanctioned counsel for appellate expenses, admonished him, and referred the matter for possible discipline. Counsel filed an opening brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and authorities used for propositions they did not support.

Perez-Castillo’s opening brief was riddled with AI hallucinations. These included two 2 No. 25-1988 dozen fabricated quotations, seven cases wrongly identified as precedent from this circuit, erroneous legal propositions, and assertions of fact flatly contradicted by the record. Counsel for Perez-Castillo, Abdullah Salah, blamed these errors on another attorney with whom he had contracted to …

2026-05-29 · Supreme Court of Pennsylvania · 2026 WL 1506862 · provisional

On 2026-05-29, in Jaclyn Cocco v. Rosario Palmieri, Jr, Supreme Court of Pennsylvania affirmed and observed that an asserted parental-alienation authority could not be located. A self-represented appellant filed a petition using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

To the extent Father contends that this court has mandated dispositiveweightbeattributedtofactorsconcerningparental alienationasamatteroflaw,heisincorrect.Indeed,itappears that the authority to which Father cites in support of this contention either does not exist or does not stand for the proposition for which he asserts it does. Notably, Father's brief includes the following quotation: “Where the record demonstrates that one parent …

2026-05-29 · United States District Court for the Middle District of Pennsylvania · provisional

On 2026-05-29, in Trauger v. Columbia County District Attorney's Office et al, the Middle District of Pennsylvania warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed opposition papers using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Page 9 of 12 Most glaringly, in opposition to the Police Department’s motion to dismiss, Trauger represents non-existent assertions and cases from the Police Department’s brief. See Pl.’s Br. in Opp’n to Def. Police Department’s Mot. to Dismiss, doc. 34 at 3-5. This appears to indicate one of the hallmarks of generative AI use: hallucination.3 …

2026-05-29 · United States District Court for the District of Colorado · provisional

On 2026-05-29, in Garcia v. City of Monte Vista, Colorado et al, the District of Colorado ordered counsel to show cause why sanctions should not issue for relying on an allegedly fabricated autopsy and forensic report. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

at ¶ 73.) Garcia alleges that the arrest affidavit relied upon the fabricated autopsy and forensic report by Eikelenbloom and Eikelenbloom-Schieveld but purposefully omitted other exonerating information. (Id. at ¶¶ 74, 76.) Specifically, he asserts the arrest affidavit made no mention of: • The fact that Jones’ autopsy definitively concluded that she died by suicide, …

2026-05-28 · Court of Appeals of Texas · provisional

On 2026-05-28, in Christian Lavell Jennings v. Vandergriff Honda, Court of Appeals of Texas affirmed the judgment and noted that the appellant's briefing relied on a nonexistent case and fabricated quotations. A self-represented appellant filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Whether the trial court entered judgment despite Appellee initiating the state court action without proper notice to Appellant, and whether this lack of notice constitutes a fundamental procedural defect warranting reversal[;] The alleged contents of the USB drive do not appear anywhere in the record. 3. Whether the trial court violated Appellant’s procedural due process …

2026-05-28 · Supreme Court of New York · 2026 WL 1587346 · provisional

On 2026-05-28, in Strategic Funding Source, Inc. v. STI-NY, LLC, Supreme Court of New York awarded $2,000 in costs or fees caused by the defective legal authorities. Counsel filed a motion using authorities used for propositions they did not support.

*1 Editor's Note: This document contains discussion of unverified citations, likely generated by AI tools used by a party or counsel. These citations are not attributable to the Court. The unverified citations have been preserved as part of the official record, but links are unavailable. Part 11M Motion Date 02/12/2026 Motion Seq. No. 002 Decision …

2026-05-28 · United States District Court for the Eastern District of Michigan · provisional

On 2026-05-28, in Boyle, et al. v. Steven Kramer, the Eastern District of Michigan warned that future filings containing fabricated legal authorities may lead to sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

2026) (stating that citing “even a single fake case” is sanctionable conduct). And when litigants misrepresent the law, they waste judicial resources. Pro se litigants who have engaged in similar behavior have been subjected to sanctions such as the striking of filings with factitious citations, dismissal of the case, and monetary penalties. See Sanders, 176 …

2026-05-28 · United States District Court for the Western District of Kentucky · provisional

On 2026-05-28, in Roger Patel et al. v. Chandresh Patel et al, the Western District of Kentucky warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. Counsel filed a response using quotations that did not appear in the cited source and authorities used for propositions they did not support.

RESPONDENTS MEMORANDUM OPINION AND ORDER In reviewing Petitioners’ Response to Respondents’ Motion to Dismiss (DN 61), the Court identified a series of citations and quotations that appear to be generative artificial intelligence (“AI”) hallucinations. Petitioners’ counsel—Daniel N. Thomas and Mary E. Jocelyn—were ordered to show cause why they should not be sanctioned pursuant to Fed. …

2026-05-28 · Appellate Court of Illinois, First District · 2026 IL App (1st) 250013-U · provisional

On 2026-05-28, in In re M.H., M.L., and M.H., Minors, Appellate Court of Illinois, First District ordered mother to show cause within fourteen days why sanctions should not be imposed for fictitious authorities. Counsel filed a response using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

The Public Guardian points out that, throughout her brief, the Mother misstates the facts or holdings of cases she citedinsupportofherarguments,incorrectlycitesothers,and referencescasesthatdonotexist.ThePublicGuardianargues that the Mother's reliance on fictitious case holdings violates Illinois Supreme Court Rule 341(h)(7) (eff. Oct. 1, 2020) and asks us to find the Mother's arguments forfeited. “ ‘[B]ecause the merits of the case …

2026-05-28 · United States Court of Appeals for the First Circuit · provisional

On 2026-05-28, in USA ex rels. v. Barton Associates, Inc, the First Circuit affirmed dismissal and noted that appellants misrepresented authorities and quoted language absent from cited cases. Counsel filed a reply brief using quotations that did not appear in the cited source and authorities used for propositions they did not support.

Instead, they merely declared that they could "cure[]" any deficiencies and that the 4 In addition to misrepresenting the holdings of several cases in their opening appellate brief, Solano and Maxilin also referenced quotations that do not appear in those cases or in any case that we have been able to find. Then, even after …

2026-05-27 · Supreme Court of Oklahoma · 2026 OK 37 · provisional

On 2026-05-27, in State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves, Supreme Court of Oklahoma publicly reprimanded the attorney as reciprocal discipline for ChatGPT-generated citations used in federal filings. Counsel filed a motion using authorities used for propositions they did not support.

1-A, Complainant, Oklahoma Bar Association, caused documentation to be transmitted to the Chief Justice of this Court following public reprimand and public censure in the states of Texas, Tennessee, and Alabama based on a sanctions order in the United States District Court for the Northern District of Alabama for using generative artificial intelligence to fabricate …

2026-05-27 · United States District Court for the Eastern District of New York · provisional

On 2026-05-27, in Polanco v. Himalayan Real Estate LLC, et al, the Eastern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant cited Moore v. Alliance Credit Union even though the court found the authority did not exist.

Warning About Fake Citations Plaintiff cites a fictitious case, “Moore v. Alliance Credit Union,” which he falsely claims was decided by the United States Supreme Court on January 14, 2025, and “addressed the legality of mortgage loans based on fiat currency and its implications on constitutional rights.” ECF No. 1 at 4. He claims, falsely, …

2026-05-27 · Supreme Court of New York, Appellate Division, Second Department · 2026 WL 1476261; 2026 N.Y. Slip Op. 03308 · provisional

On 2026-05-27, in In the Matter of Kevin A. Julien v. Danielle M. Arthur, New York's Second Department imposed a $250 sanction on the self-represented appellant for a brief prepared with unverified generative AI. A self-represented appellant filed an appellate brief using unsupported or inaccurate legal authorities.

By order to show cause datedJanuary14,2026,thisCourtdirectedthepartiestoshow cause before this Court why an order should not be made and entered imposing sanctions and/or costs, if any, as this Court may deem appropriate, against the appellant pursuant to 22 NYCRR 130–1.1 for filing a brief containing fabricated legal authority. The motion was held in abeyance and referred …

2026-05-27 · Iowa Court of Appeals · provisional

On 2026-05-27, in Christ Apostolic Temple, Inc., Dwight Reed and Jordan Reed v. Demetrius Sinegal, et al, Iowa Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a reply brief using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Sinegal’s appellate and reply briefs contain citations to cases that do not exist or donotstandforthepropositionforwhichtheyarecited. Thissuggeststhepossibilitythat he used generative artificial intelligence to prepare his briefs. If that is the case, we again “stress that self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when …

2026-05-27 · District Court of Appeal of Florida, Fourth District · provisional

On 2026-05-27, in Robert Hinton Avery v. Danielle Beauzil, District Court of Appeal of Florida, Fourth District barred the appellant from future pro se filings in the case unless signed by a Florida Bar member. A self-represented appellant filed a brief using nonexistent or hallucinated authorities, authorities used for propositions they did not support, and a nonexistent.

These types of AI-hallucinated arguments are just as egregious as a citation to non-existent law. See Clerk of Court & Comptroller for 13th Judicial Circuit, Hillsborough Cnty. v. Rangel, 427 So. 3d 1069, 1071 (Fla. 2d DCA 2025) (sanctioning counsel for filing a brief that, among other things, “misstated court holdings”). Pro se litigants and …

2026-05-27 · District Court of Appeal of Florida, Fourth District · provisional

On 2026-05-27, in Innocent v. Meraki Installers, LLC, District Court of Appeal of Florida, Fourth District affirmed and referred counsel to the Florida Bar over trial-transcript quotations not found in the record. Counsel filed an initial brief using record or transcript quotations not found in the record, quotations that did not appear in the.

We write briefly, however, to address concerns regarding multiple quotations from the trial transcript contained in Appellant’s initial brief that do not appear to be found anywhere in the actual trial transcript or otherwise in the Record. In consideration of the arguments made on this point in the parties’ briefs, as well as during oral …

2026-05-27 · District Court of Appeal of Florida, Fourth District · provisional

On 2026-05-27, in Eclectic Synergy, LLC v. Seredin, District Court of Appeal of Florida, Fourth District ordered counsel to show cause why sanctions should not issue for an apparently AI-generated emergency stay motion. Counsel filed a response using several nonexistent or hallucinated authorities and authorities used for propositions they did not support.

We denied the “emergency” motion for stay,1 and issued an order requiring counsel to show cause why sanctions should not be imposed because the petition appears AI-generated and raises frivolous arguments, misstates the law, and cites non-existent caselaw. Fla. R. App. P. 9.410(a). As an example, we quoted page 5 of the petition, which argues: …

2026-05-27 · Supreme Court of Delaware · 2026 WL 1482293 · provisional

On 2026-05-27, in SWSZ Holding v. SZ Global, Supreme Court of Delaware denied the sealing motion without prejudice and directed the movant to refile using only existing, accurately quoted authorities. A self-represented appellant filed a motion using several nonexistent or hallucinated authorities.

Motion,hemoved“tosealorredactimproperanddefamatory material” within the Third-Party Complaint, under Superior Court Civil Rules 5(g), 12(f), “and the Court's inherent equitable authority to seal or redact specific portions....”6 WithintheattachedMemorandumofLawinSupport,Movant asserted four defenses.7 However, he did not object to the Court'sexerciseofjurisdictionoverhisperson.Instead,while seeking dismissal or alternative relief on other grounds, he challenged the merits,8 even noting he “stands prepared to …

2026-05-27 · United States District Court for the District of Delaware · provisional

On 2026-05-27, in Williamson v. Meyers (derivatively on behalf of Equinix, Inc.), the District of Delaware warned counsel after plaintiff conceded a fictitious citation and withdrew it from the briefing. Counsel filed a motion using at least one nonexistent or hallucinated authority.

CONCLUSION10 10 In reviewing Plaintiffs briefing, the Court identified at least one existence where Plaintiffhad cited to a non-existent authority and brought this issue to Plaintiffs attention. After investigating, Plaintiffconceded that this fictitious citation was most likely the result of artificial intelligence (“Al”). The Court has not considered any ofPlaintiffs contentions, to the extent that …

2026-05-26 · Court of Appeals of Ohio, Sixth District · 2026-Ohio-1930 · provisional

On 2026-05-26, in Guo v. Meade Motorcars, L.L.C, Court of Appeals of Ohio, Sixth District imposed a $100 monetary sanction for the defective legal authorities. A self-represented appellant cited Davis v. Davis, 590 N.E.2d 1372 (Ohio Ct. App. 1990) even though the court found the authority did not exist.

Meade postulated that the cases were “wholly fictitious.” {¶ 16} On July 10, 2025, Guo opposed Meade’s request for sanctions. He stated in his motion that Davis v. Davis—as well as the three other cases referred to by Meade—was available at the provided citation and was “readily accessible to any attorney who exercises due diligence. …

2026-05-26 · United States District Court for the Southern District of New York · provisional

On 2026-05-26, in Hodges v. McGough Enterprises LLC, the Southern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a motion using nonexistent or hallucinated authorities.

This raises concern that these cases may be the result of generative artificial intelligence hallucinations.7 See Smith v. Smith, 5:25-CV-1077 (MAD/DJS), 2025 WL 3706691, at *2-3 (N.D.N.Y. Dec. 22, 2025).8 “Although in some circumstances courts will make ‘some allowances for a pro se Plaintiff's failure to cite to proper legal authority,’ it is ‘no more …

2026-05-26 · United States District Court for the District of New Mexico · provisional

On 2026-05-26, in Sample et al v. Hilton Worldwide Holdings, Inc, the District of New Mexico warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a response using quotations that did not appear in the cited source.

None of these grounds identifies a part of Although courts make some allowances for a pro se plaintiff's failure to cite to proper legal authority, courts do not excuse the use of fabricated or misleading authorities. Morgan v. Cmty. Against Violence, No. 23-cv-353-WPJ/JMR, 2023 WL 6976510, *7 (D.N.M. Oct. 23, 2023). Plaintiffs are cautioned that …

2026-05-26 · United States District Court for the Southern District of Indiana · provisional

On 2026-05-26, in William C. Maxwell v. Dakota Michael & Chelsey Smith, the Southern District of Indiana imposed a $1,000 Rule 11 sanction for non-existent citations and denied the motion for preliminary injunction. A self-represented litigant filed a motion using quotations that did not appear in the cited source and at least 37 nonexistent or hallucinated authorities.

163.] The Court further directed Plaintiff to file a statement showing why he should not be subject to Federal Rule of Civil Procedure 11(c) sanctions for citing and quoting non-existent cases. Plaintiff responded to the Court's order onApril 9, 2026. [Filing No. 165.] Plaintiff does not dispute that certain citations were incorrect, but claims his …

2026-05-26 · Indiana Court of Appeals · provisional

On 2026-05-26, in Jean-Paul B. Kalonji v. State of Indiana, Indiana Court of Appeals admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant cited Taylor v. State, 133 N.E.3d 708 (Ind. Ct. App. 2019) even though the court found the authority did not exist.

Then we address Kalonji’s citation to nonexistent legal authority and mischaracterization of caselaw. In addition to asking this Court to take judicial notice of the APRA Responses, Kalonji’s Motion for Judicial Notice of Legislative Facts and Alternative Relief also requested that this Court remand this case for a “limited evidentiary hearing,” reverse the trial court’s …

2026-05-22 · United States District Court for the Southern District of New York · provisional

On 2026-05-22, in Sana Hazina Butler v. Fidelity Management & Research Company LLC, the Southern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant cited Rate Technology Inc. v. Speakeasy Inc even though the court found the authority did not exist.

2024) (per curiam) (observing that the “attempt to persuade a court or oppose an adversary” by relying on “non-existent precedent” is an “abuse of the adversary system”). (ECF 43). Plaintiff’s response to Defendant’s request for a stay of discovery includes citation to a case, Rate Technology Inc. v. Speakeasy Inc., that does not match the …

2026-05-22 · Kentucky Court of Appeals · 2026 WL 1443318 · provisional

On 2026-05-22, in A.T.W. v. Commonwealth of Kentucky, Kentucky Court of Appeals affirmed and noted that the circuit court had already warned mother about non-existent case law. A self-represented appellant filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

It should further be noted that in her motion [Mother] cites to non-existent case law .... Again, this causes the Court concerns regarding [Mother's] candor with the Court, and she has been advised as such. The circuit court also rejected Mother's argument that relief was warranted under 60.02(f) for extraordinary cause. Significantly, the court determined …

2026-05-22 · United States District Court for the Northern District of Illinois · 2026 WL 1453740 · provisional

On 2026-05-22, in Saqib Kafeel v. CJDropshipping, the Northern District of Illinois dismissed the second amended complaint and declined to award fees for AI-hallucinated citations. A self-represented litigant filed a motion using record or transcript quotations not found in the record, quotations that did not appear in.

52, SAC ¶¶ 1, 5, 9-24, 26-28.) Defendant now moves to dismiss the SAC on jurisdictional and other grounds,(seegenerallyR.54,Def.’sMot.toDismiss),andfor sanctions based on Kafeel's reliance on AI-hallucinated case citations and quotations in court filings, (R. 59, Def.’s Mot. for Sanctions). Analysis A. Motion to Dismiss *2 Defendant moves to dismiss the SAC under: (1) Rule 12(b)(1) …

2026-05-22 · District Court of Appeal of Florida, Sixth District · 2026 WL 969721 · provisional

On 2026-05-22, in Kings Roofing v. Fusion Works, District Court of Appeal of Florida, Sixth District ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed an initial brief using quotations that did not appear in the cited source, several nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

McCommon, Esquire, who, in his Initial Brief, has provided this Court with citations to several cases, some of which appear to be fabricated. The Initial Brief looks as if it was drafted with the assistance of generative artificial intelligence without Mr. McCommon having put sufficient safeguards in place to ensure the existence or accuracy of …

2026-05-22 · United States District Court for the Central District of California · 2026 WL 1454205 · provisional

On 2026-05-22, in Lagac v. Capital One, N.A, the Central District of California warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed opposition papers using quotations that did not appear in the cited source.

“Although courts make some allowances for the pro se Plaintiff's failure to cite to proper legal authority, courts may not condone actions by a party who cites to false, nonexistent, or misleading authorities.” Meriland Keith Dillard v. CBS Studios, Inc., 2026 WL 790882, at * 11 (C.D. Cal. Mar. 16, 2026) (internal quotation marks omitted). …

2026-05-21 · Court of Appeals of Tennessee · 2026 WL 1431143 · provisional

On 2026-05-21, in Simmons v. Shahidul Islam, Court of Appeals of Tennessee affirmed dismissal and rejected briefing that used apparent AI-hallucinated cases and an inaccurate Rule 19 argument. A self-represented appellant filed a motion using authorities used for propositions they did not support.

One, his case citations appear to be from an artificial intelligence hallucination.3 The cases cited in the brief, insofar as they exist, do not stand for the stated propositions for which Mr. Simmons offers them.4 Two, Rule 19 itself and prior caselaw support the opposite conclusion. The Rule itself states that, when a party dies …

2026-05-21 · United States District Court for the Middle District of Pennsylvania · provisional

On 2026-05-21, in Twigg v. BSN Sports, Inc., et al, the Middle District of Pennsylvania ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a motion using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

there can be no clear legal error for the failure of either the Court or the jury to apply a stipulation that does not exist. It is apparent to the Court that the text of the damages stipulation may not comport with the intentions of the Plaintiffs. They have made clear in their briefing on …

2026-05-21 · United States District Court for the Western District of Oklahoma · 2026 WL 1429765 · provisional

On 2026-05-21, in Dalton Gage Hill v. Oklahoma County Criminal Justice Authority, the Western District of Oklahoma magistrate judge recommended denying the motion to vacate and described earlier Rule 11 sanctions proceedings against counsel. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for.

McBride to appear before the Court to show cause as to why sanctions should not be imposed under Rule 11 and the Court's inherent authority for citing fictitious cases in his response to Defendant Logan's motion to dismiss. See Doc. 126. 2. On September 5, 2025, the undersigned recommended Mr. McBride pay Defendants' reasonable attorneys' …

2026-05-21 · District Court of Tulsa County, Oklahoma · provisional

On 2026-05-21, in In re the Marriage of Amy Haddock and Justin Blu Haddock, the Tulsa County district court sanctioned counsel $2,000, ordered attorney-fee proceedings, required a knowledge-base audit, and directed bar referral. Counsel filed a motion using authorities used for propositions they did not support.

Husband's Motion containedthree citations to nonexistent lawand three citations to cases with inaccurate descriptions ofthe propositions oflawfor which they stood. The errant citations were pointed out to Mr. Johnson on August 25, 2025, at which point the parties agreed to pass that day's setting. This Court was not the assigned Judge at that time and …

2026-05-21 · United States District Court for the Southern District of Ohio · provisional

On 2026-05-21, in Arron v. Custer, et al, the Southern District of Ohio magistrate judge treated the cited Ohio Supreme Court decision as unverified and recommended remand. A self-represented litigant filed a motion using unsupported or inaccurate legal authorities. The document links the problem to GAI.

Likewise, the Complaint does not appear to be attacking a state-court judgment so as to implicate the Rooker-Feldman doctrine. Beyond a vague reference to “court proceedings” (Compl, ECF No. 1-1, PAGEID # 3), Ms. Arron has not alleged the existence of any specific state judicial decision that she wants the Court to overturn.2 See, e.g., …

2026-05-21 · Court of Appeals of Ohio, Eighth District · 2026 WL 1434161; 2026-Ohio-1869 · provisional

On 2026-05-21, in Isaiah Hunter-Bey v. City of Cleveland Law Department, Court of Appeals of Ohio, Eighth District admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented appellant filed a motion using record or transcript quotations not found in the record and authorities used for propositions they did not support.

Specifically, his brief exhibits all the hallmarks of being generated by artificial intelligence (“AI”) including nonexistent cases, miscited cases, and cases that exist but standfordifferentlegalpropositionsthanwhatisrepresented. See Smith v. Gamble, 2025-Ohio-2381, ¶ 26 (12th Dist.); Gonzalez v. Tex. Taxpayers & Research Assoc., 2025 U.S. Dist. LEXIS 16801 (W.D. Tex. Jan. 29, 2025). App.R. 16(7) requires that …

2026-05-21 · Court of Appeals of Ohio, Eighth District · 2026 WL 1434248; 2026-Ohio-1871 · provisional

On 2026-05-21, in City of Shaker Heights v. Andre D. Thompson, Court of Appeals of Ohio, Eighth District overruled the assignment of error after finding the cited plea-record authority nonexistent or unrelated. A self-represented appellant cited State v. Banks even though the court found the authority did not exist.

The Hunt Court stated: Hunt's claims that his plea was not knowingly, voluntarily, or intelligently entered or that the trial court failed to comply with the dictates of Green, all of which are dependent on the nonexistent transcript, are without merit. We must presume regularity in the proceedings and that thethree-judgepanelcompliedwithGreenandCrim.R.11. Further, the final entry …

2026-05-21 · United States District Court for the District of New Mexico · provisional

On 2026-05-21, in Lowrey v. City of Rio Rancho et al, the District of New Mexico ruled on the merits and separately addressed defective legal authorities in the filing. A self-represented litigant filed a response using authorities used for propositions they did not support.

The School Defendants cite to the Court’s November 5, 2025, Order in which it issued a warning to Plaintiff regarding his citations to nonexistent cases and/or to case law that misleads and falsely represents legal support for arguments presented. Id. The School Defendants assert that each time Plaintiff files a motion, his duty to present …

2026-05-21 · United States District Court for the Eastern District of California · provisional

On 2026-05-21, in That Xiong v. Minga Wofford, the Eastern District of California declined sanctions in light of remedial steps but required counsel to verify all future case and record citations. Counsel cited G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025) even though the court found the authority did not exist.

Petitioner was ordered to provide in his OSC response signed declarations from Petitioner’s counsel, law student Gina Herrera, and any and all other staff who assisted Petitioner’s counsel regarding compliance with the Court’s January 13, 2026 Order; a detailed description of how the hallucinated citations were included in Petitioner’s reply brief at ECF No. 12; …

2026-05-21 · United States District Court for the Northern District of Alabama · provisional

On 2026-05-21, in Jackie L. Miller v. Regions Bank, the Northern District of Alabama disqualified counsel from the case and from appearing before the judge for six months and referred the order to bar authorities. Counsel submitted a filing using quotations that did not appear in the cited source.

Harp includes four false quotations. (See Doc. 23 at 22, 24, 25, 32). These quotations—along with the cases to which they are attributed and any language necessary for context—are as follows: SeeHolly v. Clairson Indus., L.L.C., 492 F.3d 1247, 1256–57 (11th Cir. 2007) (questions regarding the extent of limitations and need for accommodation are “classic …

2026-05-21 · United States District Court for the Northern District of Alabama · provisional

On 2026-05-21, in Chapel v. Americredit Financial Services & Experian, the Northern District of Alabama admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. A self-represented litigant submitted a filing using quotations that did not appear in the cited source.

5), but these quotations do not appear anywhere in these cases or in any other case the Court can find. Generative artificial intelligence likely produced these unreliable quotations. The Court does not prohibit the use of AI, but to comply with Rule 11 of the Federal Rules of Civil Procedure and other applicable legal and …

2026-05-20 · United States District Court for the Western District of Virginia · provisional

On 2026-05-20, in Sherwood v. County of Botetourt, Virginia, et al, the Western District of Virginia granted dismissal of most claims and warned that any future filing must be supported by real law. Counsel cited Peal v. Commonwealth even though the court found the authority did not exist.

The Sherwoods’ sweeping claims appear to stem from incorrect interpretations of law and include citations to hallucinated law ostensibly obtained from generative AI tools. A fundamental misunderstanding about (1) the requirements for a misdemeanor warrant under Virginia Code § 19.2-72;and (2) the effect of a nolo contendere plea in Virginia court underlies all twenty counts. …

2026-05-20 · Supreme Court of New York, Appellate Division, Second Department · provisional

On 2026-05-20, in Landberg v City of New York, New York's Second Department ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a brief using unsupported or inaccurate legal authorities. The sanction issue remained pending after the order.

Lamonsoff, PLLC, and Michael Sanders, Esq., pursuant to 22 NYCRR 130-1.1, for filing briefs containing fabricated and/or erroneous legal authority and/or citations, by serving and filing an affirmation or affidavit on that issue, via NYSCEF, on or before June 3, 2026; and it is further, ORDERED that the Clerk of this Court, or his designee, …

2026-05-20 · United States Bankruptcy Court for the District of New Jersey · provisional

On 2026-05-20, in In re Nicholia Cherry-Crockette, the District of New Jersey Bankruptcy Court denied the sanctions motion and rejected authorities that were nonexistent or did not support the debtor's position. A self-represented litigant filed a motion using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

The Inapplicable or Non-Existent Cases Cited by Debtor In her supplemental submission, the Debtor cites three cases in support of her position that there is a willful stay violation. None of those cases involved a legally required notification such as what is at issue here, nor did any of those cases analyze the sufficiency of …

2026-05-20 · United States District Court for the Middle District of North Carolina · provisional

On 2026-05-20, in Curtin v. Watts, et al, the Middle District of North Carolina warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a brief using quotations that did not appear in the cited source and authorities used for propositions they did not support.

Rule 11(b) and Fabrication of Legal Authority Finally, Curtin points to reprimands issued against Cyberlux in other litigation, specifically an order to pay attorneys’ fees and a show-cause order for fabricating or misrepresenting legal authorities. (Doc. 48 at 9.) He contends that Cyberlux has engaged in a “persistent pattern of deception and obstruction” that undermines …

2026-05-20 · Appellate Court of Maryland · 2026 WL 1413152 · provisional

On 2026-05-20, in Brandy Dorsey v. Walter Livramento, III, Appellate Court of Maryland warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed a brief using numerous nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Submission of nonexistent or inaccurate legal authority is improper and wastes judicial resources. Mother's brief contains numerous citations to cases and other legal authorities. We suspect that Mother may have used generative artificial intelligence (“AI”) to assist in drafting her brief, as several cited authorities are fictitious, and others do not support the stated proposition.5 …

2026-05-20 · United States District Court for the Eastern District of Louisiana · provisional

On 2026-05-20, in Taiujuan Burches v. Equifax Information Services, LLC, et al, the Eastern District of Louisiana warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a motion using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Plaintiff requested,13 and the Court granted,14 leave to file a Second Amended Complaint, which was then filed into the record.15 Experian then answered the Second Amended Complaint,16 and Trans Union filed a Motion to Dismiss the same.17 On September 26, 2025, Plaintiff requested leave to file a Third Amended Complaint.18 Trans Union opposed the request,19 …

2026-05-20 · United States District Court for the Southern District of Indiana · provisional

On 2026-05-20, in Davis v. Marion County Juvenile Detention Center, the Southern District of Indiana magistrate judge recommended a $2,000 sanction against counsel for two AI-generated non-existent citations. Counsel filed a motion using multiple nonexistent or hallucinated authorities and authorities used for propositions they did not support.

The Magistrate Judge has recommended that the Undersigned personally sanction Plaintiff’s counsel, Tae Sture, for including two non-existent legal citations in a brief responding to a motion to compel. The legal citations were hallucinations generated by an artificial intelligence (“AI”) research tool. The Magistrate Judge found Mr. Sture’s conduct violated the Indiana Rules of Professional …

2026-05-20 · United States Court of Appeals for the Eleventh Circuit · provisional

On 2026-05-20, in Downing v. Dwayne Brown, et al, the Eleventh Circuit struck fabricated-authority portions of the brief and affirmed dismissal. A self-represented appellant filed an appellate brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and nonexistent or hallucinated authorities.

First, Downing’s argument is supported almost exclusively by fabricated legal authorities. Throughout her appellate brief, USCA11 Case: 25-14133 Document: 14-1 Date Filed: 05/20/2026 Page: 4 of 8 25-14133 Opinion of the Court 5 Downing relies on precedents that do not exist. For example, she quotes UnitedStatesv. Jones, 29 F.4th 1290, 1294 (11th Cir. 2022), as …

2026-05-19 · United States District Court for the District of Oregon · provisional

On 2026-05-19, in REDACTED v. United States Citizenship and Immigration Services, the District of Oregon allowed counsel to correct suggested findings after fabricated citations were identified. Counsel filed a response using nonexistent or hallucinated authorities. The document links the problem to GAI.

§ 1421(c) (“Aperson whose application for naturalization under this subchapter is denied, after a hearing before an immigration officer under section 1447(a) of this title, may seek review of such denial before the United States district court for the district in USCIS’s counsel submitted two court filings that contained hallucinated case citations. (See Defs.’Suggested Findings …

2026-05-19 · United States District Court for the Southern District of New York · provisional

On 2026-05-19, in Chakma v. Sushi Katsuei, Inc, the Southern District of New York imposed a $2,712 monetary sanction for the defective legal authorities. Counsel filed opposition papers using authorities used for propositions they did not support. The monetary component was $2,712.

Specifically, on July 15, 2025, Plaintiffs brought to the attention of the Court that Defendants had fabricated legal authority in at least two submissions to the Court. (See Dkt. #101 (alerting the Court to Defendants’ improper citations)). The most egregious examples appeared in Defendants’ July 8, 2025 letter regarding their interference with the class notice …

2026-05-19 · United States District Court for the Eastern District of Missouri · provisional

On 2026-05-19, in Syreeta LaShawn McNeal v. Vera L. Calvin, et al, the Eastern District of Missouri required the litigant to certify citation verification with every future filing. A self-represented litigant cited Weniger v. Dynamic Recovery Solutions, LLC even though the court found the authority did not exist.

Plaintiff alleges in the Amended Complaint that various Defendants revealed her private information and defamed her by calling her a “fake attorney,” among other things. The facts relayed by the Court about Plaintiff’s disciplinary history—all matters of public record and permissible to consider on a motion to dismiss, Stahl, 327 F.3d at 700—are relevant to …

2026-05-18 · United States District Court for the District of Minnesota · provisional

On 2026-05-18, in Harris v. St. Peter Investors, LLC et al, the District of Minnesota warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a motion using quotations that did not appear in the cited source and at least two nonexistent or hallucinated authorities.

that “Avidity’s agents acted on behalf of both Avidity and St. Peter Investors, establishing joint and vicarious liability.” ECF No. 1 at 4 (emphasis added). As a result, the Court believes that the “better approach to remedy this problem” is “to defer judgment against the defaulting party until the merits have been resolved.” Rankin v. …

2026-05-18 · Supreme Judicial Court of Massachusetts · provisional

On 2026-05-18, in Glenn Wilder and Others v. President & Fellows of Harvard College and Others, Supreme Judicial Court of Massachusetts denied pro hac vice admission because counsel had signed AI-hallucinated filings in a prior federal case. Counsel filed a motion using nonexistent or hallucinated authorities.

11(b) because he signed motions in limine without reading them and, as a result, permitted the filing of motions citing eight non-existent cases that had been hallucinated by Morgan & Morgan’s in-house Artificial Intelligence (“AI”) platform. See Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. Feb. 24, 2025). The Court will exercise its discretion …

2026-05-18 · Arizona Court of Appeals · 2026 WL 1383355 · provisional

On 2026-05-18, in Estate of Claxton, Arizona Court of Appeals affirmed and declined to find waiver despite several fictitious or inaccurate citations in the appellant's brief. A self-represented appellant filed a brief using several nonexistent or hallucinated authorities. The document links the problem to GAI.

Many of Claxton's factual assertions lack specific record cites, he includes several fictitious or inaccurate case citations, and he relies on numerouslawfirmarticleswithoutexplainingtheirrelevance or persuasive value. Though we could conclude that he has waived his arguments, in our discretion we decline to do so. See Delmastro & Eells v. Taco Bell Corp., 228 Ariz. 134, 137, …

2026-05-16 · United States District Court for the Southern District of New York · provisional

On 2026-05-16, in Waggeh v. Utility Workers Union of America Local 1-2 et al, the Southern District of New York publicly admonished counsel after accepting the withdrawal of incorrectly cited cases. Counsel filed a response using authorities used for propositions they did not support.

9-10.) As set forth at the end of this Opinion and Order, in response to an Order to Show Cause from the Court, Petitioner admits that these cases were incorrectly cited do not support his argument with respect to the ALJ’s decision and has withdrawn such argument. (See Hardy 4/29/25 Decl., ECF No. 47, ¶¶ …

2026-05-15 · United States District Court for the Southern District of Ohio · provisional

On 2026-05-15, in Brock et al. v. Hamilton County JFS Children Services et al, the Southern District of Ohio warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant filed a petition using nonexistent or hallucinated authorities.

To start it appears her objection on this front relies on hallucinated case law. Brock cites to Jansen v. City of Cincinnati, 904 F.3d 336, 349–50 (6th Cir. 2018), which she describes as specifically holding that “§ 1983 claims against child welfare workers for fabricating evidence are not barred by Rooker-Feldman.” (Doc. 21, #2408 (emphasis …

2026-05-15 · United States District Court for the Middle District of North Carolina · provisional

On 2026-05-15, in Bank of America v. Mapp, the Middle District of North Carolina remanded the collection case and ordered the defendant to show cause within fourteen days why Rule 11 sanctions should not issue. A self-represented litigant filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used.

Rule 11(b)(2) provides that by signing a filing, an attorney or unrepresented party certifies that, to the best of his knowledge and after a reasonable inquiry, “the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law.” …

2026-05-15 · United States Court of Appeals for the Seventh Circuit · provisional

On 2026-05-15, in Nikko D’Ambrosio v. Meta Platforms Inc, the Seventh Circuit ordered counsel to show cause by June 5, 2026, why sanctions should not issue for citations to cases that do not exist. Counsel filed a motion using quotations that did not appear in the cited source, at least one nonexistent or hallucinated authority, authorities.

Rajala referred to is not in the com- plaint, but the secondisasfollows, withexpletivescleanedup for this opinion: Speak for yourself you ugly vial [sic] fake whore. Your ego matches that fake f****** face where you can’t even smile in pictures because your teethare sof*****.The truthhurtsb**** and my message will stay with you forever c***. The manner …

2026-05-14 · Supreme Court of New York, Appellate Division, First Department · provisional

On 2026-05-14, in In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law, New York's First Department suspended the attorney for three months and imposed a $1,500 sanction for filing an AI-hallucinated judicial-order draft. Counsel filed a brief using numerous nonexistent or hallucinated authorities.

Respondent’s draft, however, was replete with citations to non-existent cases attributed by the court to hallucinations by ChatGPT or a similar artificial intelligence program. Complainant was fined $1,500 and ordered to contact the internet platform, self-report their sanction, and report respondent to the New York disciplinary authorities. In furtherance of the AGC’s investigation, on October …

2026-05-14 · United States District Court for the Middle District of Florida · provisional

On 2026-05-14, in Stringer v. White Cap Supply Holdings, LLC, the Middle District of Florida ordered the filer to show cause why sanctions should not issue for the defective authorities. A self-represented litigant filed a response using record or transcript quotations not found in the record, quotations that did not appear in.

The record cites that Plaintiff references to support this statement either do not exist (Doc. No. 35-3, at 57:19-58:11; Doc. No. 35-5, at 72:15-74:2), or do not establish that Plaintiff engaged in any such conduct. Doc. No. 35-17. In addition, Plaintiff cites to Nadler v. Harvey, No. 06-12692, 2007 WL 2404705, at *9 (11th Cir. …

2026-05-14 · United States District Court for the Central District of California · provisional

On 2026-05-14, in Oscar Danilo Montealto Garcia v. Todd Lyons, et al, the Central District of California granted the habeas petition and noted a non-existent case citation in counsel's briefing. A self-represented litigant filed a petition using unsupported or inaccurate legal authorities.

(ECF 11; ECF 13.) On May 13, 2026, the parties filed a joint status report and supplemental brief responding to inquiries from the Court, including the authority for a bond hearing and the status of Petitioner’s 4 Petitioner also cites what appears to be a nonexistent case: Sanchez-Perez v. Garland, 2023 WL 5663021, at *3 …

2026-05-13 · United States District Court for the Western District of Oklahoma · provisional

On 2026-05-13, in Jane Doe 1, et al. v. Mount Saint Mary High School Corporation, the Western District of Oklahoma publicly reprimanded counsel, ordered notice to the client, and required self-reporting to the Oklahoma Bar Association. Counsel filed a reply brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used.

Introduction This matter concerns an issue that has unfortunately become all too common: an attorney’s violation of her ethical and professional responsibilities via the inclusion of fake or misleading case citations in a legal brief. The proliferation of this issue is the result of some attorneys misusing new technological tools – specifically generative AI – …

2026-05-13 · United States District Court for the Eastern District of New York · 2026 WL 1309291 · provisional

On 2026-05-13, in Henri Giovani Morales Jimenez v. Christopher Shanahan, the Eastern District of New York denied habeas relief and admonished counsel for briefing that relied on an abrogated decision and a nonexistent case. Counsel filed a petition using unsupported or inaccurate legal authorities.

And she relied on an abrogated Supreme Court case and at least one nonexistent case. It was always going to be difficult for petitioner to prevail, but at least he would've had the benefit of liberal construction had he proceeded pro HENRI GIOVANI MORALES JIMENEZ, Petitioner, v...., Slip Copy (2026) se.Individualsinpetitioner'spositionneedzealousadvocates, not“cut-and-pastelawyering.”TubaPullav.Lyons,No.1:26- cv-2682, 2026 WL …

2026-05-13 · United States Bankruptcy Court for the Southern District of Florida · provisional

On 2026-05-13, in In re: Latasha Transrina Kebe, the Southern District of Florida Bankruptcy Court imposed a Rule 9011 sanction against debtor's counsel equal to ten percent of the reply-fee award. Counsel filed a motion using authorities used for propositions they did not support.

With respect to the citation errors identified in the Reply [Dkt. No. 222] and acknowledged in the Corrective Notice [Dkt. No. 223], the Court acknowledges and accepts the apologytenderedbyDebtor’scounsel.However,theCourtfindsthatanapology,whileappropriate, does not fully resolve Debtor’s counsel’s obligations under Bankruptcy Rule 9011. The standard governing submissions to this Court is objective: legal contentions must be warranted by …

2026-05-13 · District Court of Appeal of Florida, Second District · 2026 WL 1311959 · provisional

On 2026-05-13, in Christopher Gleason v. Julie Marcus, District Court of Appeal of Florida, Second District warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities.

His briefs cite numerous cases that do not exist, and they frequently quote case law for propositions that appear nowhere in the cases cited. We have cautioned on the dangers of using generative artificial intelligence before, see, e.g., Russell v. Mells, 426 So. 3d 913, 920 (Fla. 2d DCA 2025), and we again sound the …

2026-05-13 · United States District Court for the Northern District of California · provisional

On 2026-05-13, in Joseph Guy v. AFGE, the Northern District of California ordered the plaintiff to explain why sanctions should not issue for misquoting a discovery case. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

United States District Court Northern District of California Guy cites no authority, apart from a misquoted case regarding the limits of discovery under the federal rules of civil procedure, for the proposition that the Fourth Amendment has any bearing on relevant discovery in a civil lawsuit. See Mot. at 8 (misquoting Henson v. Turn, Inc., …

2026-05-13 · United States Court of Appeals for the Federal Circuit · provisional

On 2026-05-13, in Jones v. Department of the Army, the Federal Circuit warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed a petition using nonexistent or hallucinated authorities. No monetary sanction was imposed in this document.

Jones included citations that appear to ref- erence cases that do not exist, or at the least contain sig- nificant errors, apparently resulting from the use of artificial intelligence. See, e.g., Pet’r’s Br. 20 (purporting to cite Riley v. Dep’t of Veterans Affs., 64 M.S.P.R. 42, 44–46 (1994), which does not appear to exist); Dkt. …

2026-05-12 · Supreme Court of New York · 2026 NY Slip Op 50864 (U); 2026 NY Slip Op 50864(U) · provisional

On 2026-05-12, in Gully v Varghese, Supreme Court of New York struck the self-represented plaintiff's reply submission because its case citations could not be located. A self-represented litigant filed opposition papers using nonexistent or hallucinated authorities. The document links the problem to GAI.

Law :: Justia https://law.justia.com/cases/new-york/other-courts/2026/2026-ny-slip-op-50864-u.html 3/13 After plaintiff made her reply submission, defendants filed a reply affirmation of counsel, in which they point out that the case citations set forth in plaintiff's filings do not exist, and argues that plaintiff's use of such false citations renders her entire summary judgment motion frivolous (Attorney Affirmation in Reply …

2026-05-12 · Louisiana Court of Appeal, Fifth Circuit · 2026 WL 1304558 · provisional

The Louisiana Court of Appeal, Fifth Circuit on 2026-05-12 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities in Jacobs v. Timberlake. Counsel filed a brief with one fabricated case citation, including Harvey v. Harvey.

App. 4 Cir. 10/30/13), 127 So. 3d 156; or 2) explain the source of the citation and whether the citation is erroneous. Counsel's brief shall also address whether any generative artificial intelligence tool was used in the preparation of the instant writ application and, if so, what steps Counsel took to verify the existence and …

2026-05-12 · United States District Court for the District of New Jersey · provisional

The District of New Jersey on 2026-05-12 ordered the self-represented plaintiff to show cause why sanctions or corrective action should not issue for the defective authorities in Zena L. Powell v. The Borough of Bergenfield. The self-represented plaintiff filed an opposition with one false case quotation and one misstated record or submission point.

But Powell does not make any allegations regarding her plans to return to Bergenfield, including the definiteness of her plan to return and the frequency of traveling there. Therefore, the Court will GRANT Defendant’s Motion and DISMISS Plaintiffs claim for injunctive relief as pled. D. Plaintiff’s Apparent Use of Generative Artificial Intelligence Finally, when reviewing …

2026-05-12 · United States District Court for the Eastern District of California · provisional

The Eastern District of California on 2026-05-12 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Pyle v. Glenn County Sheriff's Department. The self-represented plaintiff filed a submission with one fabricated or AI-like submission item and one fabricated factual or other assertion, including Sheriff Owens.

, 559 F. 3d 1061, 1071 (9th Cir. 2009). The Court notes that Plaintiff’s SAC appears to have been drafted with the help of generative artificial intelligence (“GenAI”) or similar tools because it contains apparent GenAI responses to prompts. See SAC at 2:19-21, 3:26-28, 4:25-28, 6:22-24, 7:11-13. Of particular concern is an apparent reference to …

2026-05-11 · United States District Court for the Eastern District of Wisconsin · 2026 WL 1283883 · provisional

The Eastern District of Wisconsin on 2026-05-11 granted the County leave to file a corrected reply brief after the same-day removal of a fictitious citation and found no prejudice in Armstrong v. City of Milwaukee. Counsel filed a reply brief with one fabricated case citation.

As a preliminary matter, the County moved for leave to file a corrected reply brief. ECF No. 44. Although the Court agrees withArmstrong'sassessmentthatthemotionwasnecessitated bytheinclusionofafictitiouscase,ECFNo. 47at2,theCourt does not have more information as to why that happened. Regardless, the County caught and corrected the error the same day, meaning that there is no prejudice in allowing the …

2026-05-11 · Superior Court of Pennsylvania · 2026 WL 1286509 · provisional

The Superior Court of Pennsylvania on 2026-05-11 vacated the portion of the custody order awarding primary physical custody, remanded, and noted the mother’s cited case was unlocatable in Dorothea Bell v. Kelly Bell. The self-represented mother filed a brief with one fabricated case citation.

As will be borne out by our discussion infra, that would be a gross misreading of the burdens of proof for the § 5327(b) parental presumption. 3 Mother testified that she has a medical marijuana card, but the trial court reminded her that the Medical Marijuana Act does not permit individuals to smoke marijuana. 4 …

2026-05-11 · United States District Court for the Eastern District of Louisiana · provisional

The Eastern District of Louisiana on 2026-05-11 ordered the self-represented plaintiff to pay $500 for filing unverified or fabricated authorities in Burches v. Equifax Information Services, LLC, et al. The self-represented plaintiff filed a reply brief with two fabricated case citations, one false case quotation, and one mischaracterized case citation, including Hays v. HCA Holdings.

m. BACKGROUND Plaintiff has repeatedly filed briefs containing fabricated, inaccurate, or unverifiable legal citations. The issue first arose in connection with Plaintiff’s Motion for Leave to File a Third Amended Complaint,1 when Defendant Trans Union LLC (“Trans Union”) filed an Ex Parte Motion for Leave to File a Surreply,2 representing that “[a] closer examination of …

2026-05-11 · United States District Court for the Northern District of Illinois · provisional

The Northern District of Illinois on 2026-05-11 ordered defense counsel to file a declaration explaining how the brief was generated and how Beecham and Alvarez were located in DeVore v. McCombie. Counsel filed a motion with one fabricated case citation and one mischaracterized case citation, including Alvarez v. City of Chicago with page cites.

3 Because the Court dismisses Plaintiff’s only count for failure to state a claim, the Court declines to address Defendants’ arguments that Plaintiff’s allegations should be stricken as time-barred and that Defendant is protected by qualified immunity. Plaintiff failed to adequately address any of the deficiencies previously identified, so the FAC is dismissed with prejudice. …

2026-05-08 · Court of Appeals of Georgia · 2026 WL 1263356 · provisional

The Court of Appeals of Georgia on 2026-05-08 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Broyles v. McNeal. The self-represented party filed a brief with one fabricated case citation.

McNeal's brief argues that Broyles used a chatbot to prepare his brief. While there are incorrect citations in the brief, at least one is a correct citation. We caution parties that the products marketed to them as “artificial intelligence,” like calculators, can be useful tools, but any language-like strings of words or citation-like strings of …

2026-05-08 · Connecticut Superior Court · 2026 WL 1330009 · provisional

The Connecticut Superior Court on 2026-05-08 denied the name-change petition and contempt motion, added travel-notice directions, and noted likely AI-generated pleadings and nonexistent authority in Kyne v. Ehima. The self-represented father filed a pleading with two fabricated case citations and one fabricated factual or other assertion.

(2026) 1 In an attempt to further understand the father's arguments, the Court attempted to review his pleadings from the dissolution case. The cases he cites for some of his propositions, such as “In re David W. , 58 Conn. App. 237 (2000)” and “In re Marriage of Doyle, 190 Conn. 748 (1983)”, do not …

2026-05-07 · United States District Court for the Western District of Oklahoma · provisional

The Western District of Oklahoma on 2026-05-07 publicly reprimanded counsel, fined counsel $250, and ordered counsel to notify the client of the sanctions order in Kristina Crist v. Roy Chris West, et al. Counsel filed a brief with one fabricated case citation and one mischaracterized case citation.

Bussett blames the briefing errors on her use of a “trusted legal vendor’s AI tool” to research and draft the brief as well as some “more traditional errors. ” Id. at p. 3. Ms. Bussett concedes that she failed to perform the essential step of personally verifying the case citations and has apologized for her …

2026-05-07 · United States District Court for the District of New Mexico · provisional

The District of New Mexico on 2026-05-07 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Neri v. Board of Education for Albuquerque Public Schools. The self-represented plaintiff filed a submission with one fabricated case citation and one fabricated or AI-like submission item, including United States v. Stone.

262 at 1 (citing “United States v. Stone, 988 F. 2d 1056, 1061 (10th Cir. 1993). ”). The Court assumes Neri either erroneously combined a case name and legal citation or carelessly relied on an artificial intelligence program to craft this citation. 1 If this reference was indeed the product of artificial intelligence, then the …

2026-05-07 · Supreme Court of North Dakota · 2026 ND 94 · provisional

The Supreme Court of North Dakota on 2026-05-07 awarded double costs and $1,000 in attorney fees because the brief cited irrelevant, fictitious, or nonexistent authorities in Stokka v. Stokka. The self-represented appellant filed a brief with one fabricated case citation.

and the appellant's legal argument, including the authorities on which the appellant relies. Without these essential elements included in the appellant's brief, we decline to address the alleged errors because the case is not properly before us. [¶4] Stokka's brief lacks reference to the evidentiary record supporting his statement of the facts and the legal …

2026-05-07 · United States District Court for the Northern District of Mississippi · provisional

The Northern District of Mississippi on 2026-05-07 dismissed the case with prejudice as a sanction for repeated fabricated citations and other Rule 11 violations in Joshua Harris v. Pinnacle Bank. The self-represented plaintiff filed a motion with three fabricated case citations, one false case quotation, four fabricated legal rules, and three misstated legal rules.

(emphasis in original). Plaintiff was cautioned yet again on April 1, 2026, that his repeated violations of Rule 11 and court orders could result in dismissal of this action without further notice. See [Doc. 52]. Despite these repeated warnings, Plaintiff filed another motion containing fictitious legal authorities the day before his third show cause hearing. …

2026-05-07 · United States District Court for the Eastern District of Michigan · provisional

The Eastern District of Michigan on 2026-05-07 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Eric Tobler v. Stephen Tobler, et al. The self-represented plaintiff filed a reply brief with one false case quotation, including Bunner v. Blow-Rite Insulation Co.

But Tobler provides no factual support for his assertion that Diane Kelly told his process server that she was authorized to accept service on behalf of the firm. And the firm’s reply brief notes that Tobler’s reliance on Bunner is worse than just misplaced; Tobler included a fake quote and holding. Plaintiff hallucinates the holding …

2026-05-07 · Colorado Court of Appeals · provisional

The Colorado Court of Appeals on 2026-05-07 affirmed the $1,665 attorney-fee sanction and awarded appellate fees and costs after noting nonexistent authorities in Marriage of Nash. The self-represented father filed a motion with one fabricated case citation and one mischaracterized case citation.

¶ 29 Given this context, combined with the history of the case, we concur with the district court’s conclusion that father’s motions “lacked substantial justification” and appeared to be part of a vexatious “pattern of behavior where [father] asks for reconsideration of any decision he does not agree with, despite legal precedent. ” We therefore …

2026-05-07 · United States District Court for the Central District of California · 2026 WL 1270038 · provisional

The Central District of California on 2026-05-07 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities in Song Dow Lee, et al. v. HSBC Bank USA, National Association, et al. Counsel filed an opposition with one fabricated case citation and one mischaracterized case citation, including Inc. v. Umpqua Holding Corp.

36 at 11, Plaintiffs failed to correct those misrepresentations in their Proposed Statement of Decision filed on April 15, 2026 (Docket No. 39). Accordingly, Plaintiffs' counsel are ordered to show cause, in writing,onorbeforeMay11,2026,whythisCourtshouldnot impose sanctions on counsel in the amount of $2,500. 00 and/ ordismissthisaction. Plaintiffs'counselshallfiledeclarations in support of their response to the order to …

2026-05-06 · Oregon Court of Appeals · provisional

The Oregon Court of Appeals on 2026-05-06 ordered the self-represented plaintiff to pay $500 for filing unverified or fabricated authorities in Boersma v. Davenport. The self-represented plaintiff filed an opening brief with one fabricated case citation and one mischaracterized case citation.

We issued an order to show cause “(1) why plaintiff's opening brief should not be stricken in part or in whole and (2) why this court should not, on its own motion, impose monetary sanctions for submitting briefing to this court that contained nonexistent case law. ” In plaintiff's response to the order to show …

2026-05-06 · United States District Court for the Eastern District of New York · provisional

The Eastern District of New York on 2026-05-06 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Terrance Anthony Norris v. JPMorgan Chase Bank N.A. The self-represented plaintiff filed an opposition with one fabricated case citation and two false case quotations, including Inc. v. Homestead Vill. Ltd. P’ship.

Applewhite v. N. Y. C. Dep’t of Educ. , No. 24-cv-2131, 2025 WL 783650 (2d Cir. Mar. 12, 2025). Plaintiff is therefore denied a further opportunity to amend. III. Warning About Fake Quotes and Citations Defendant brings to the Court’s attention that Plaintiff’s Opposition includes citations to a nonexistent case, GAI Consultants, Inc. v. Homestead …

2026-05-06 · United States District Court for the Northern District of California · provisional

The Northern District of California on 2026-05-06 fined counsel $1,000, ordered live CLE, and required service of the order on the client and the California State Bar in Gregoire v. Board of Trustees of SF BART. Counsel filed an opposition with one fabricated case citation.

After reviewing Plaintiff’s opposition, the Court was unable to locate three of the four cases cited therein. 1 Concerned that these inaccuracies suggest hallucinations from the use of The Court does not include the names of these cases here, as doing so could inadvertently amplify any error that these cases exist. United States District Court …

2026-05-05 · Texas Court of Appeals · provisional

The Texas Court of Appeals on 2026-05-05 affirmed the order awarding attorney fees and dismissing the case, rejecting arguments supported by nonexistent cases and false quotations in Amanda Adams v. Allen Butler Construction, Inc. The self-represented party filed a brief with one fabricated case citation, one false case quotation, one mischaracterized case citation, and one misstated record or submission point.

It points to, among other deficiencies in her brief, several citations by Adams that appear to be non-existent. It points also to fictitious quotations Adams attributed to real cases that do not contain such language, Adams’s inaccurate descriptions of case holdings and mischaracterizations of the clerk’s and reporter’s records, and Adams’s failure to comply with …

2026-05-05 · Supreme Court of the State of New York · provisional

The New York Supreme Court on 2026-05-05 granted dismissal motions, denied the Article 78 petition, and noted counsel’s withdrawal and apology for AI-fabricated citations in DOE, J. et al v. The Trustees of Columbia University. Counsel filed a reply brief with one fabricated case citation.

For this reason, the Court need not reach the other dismissal arguments made, including those regarding service. A Caution on AI Hallucinations As a postscript to these motions, the Court must address certain AI-generated hallucinations in Petitioners’ papers. After the fake citations were pointed out in the reply papers, Petitioners’ counsel wrote a letter to …

2026-05-05 · United States District Court for the District of Nevada · provisional

The District of Nevada on 2026-05-05 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Seeto v. Kendall. The self-represented plaintiff filed a brief with one false case quotation, one mischaracterized case citation, and one fabricated factual or other assertion, including Withrow v. Larkin.

ECF No. 50 at 4. While AI tools can be useful, and this court does not prohibit litigants from using them, those services pull information from across the web—including from unreliable sources—and they often hallucinate (or make up fake) legal authority. Using AI to supply legal authority for briefs an unrepresented litigant or attorney signs …

2026-05-05 · Missouri Court of Appeals · 2026 WL 1216594 · provisional

The Missouri Court of Appeals on 2026-05-05 dismissed the appeal because the appellant’s brief violated appellate briefing rules and included inaccurate or nonexistent caselaw citations in Van Deel v. A-Plus Contracting, LLC. Counsel filed a brief with two fabricated case citations, including B.M. v. J.S.

3d ----, 2026 WL 1216594 Footnotes 1 All Rule references are to Missouri Supreme Court Rules (2018) unless otherwise specified. Van Deel v. A-Plus Contracting, LLC, --- S. W. 3d ---- (2026) 2 Appellant's brief contains other deficiencies impeding appellate review, including multiple inaccurate or nonexistent caselaw citations. It also mistakenly denominates this Court as …

2026-05-05 · United States District Court for the District of Minnesota · provisional

The District of Minnesota on 2026-05-05 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Randolph v. Erick Berscheid Trucking, LLC et al. The self-represented party filed a motion with one fabricated case citation and one false case quotation.

7. 1(j). Because Randolph failed to obtain prior permission, his motions are unauthorized and are therefore denied. The Court notes that Randolph’s motions contain citations to non‐existent cases as well as quotes that do not appear in the cited case, suggesting that he used generative AI to create his memoranda and did not verify that …

2026-05-05 · United States District Court for the District of Maine · provisional

The District of Maine on 2026-05-05 struck the defective opposition, ordered counsel to serve the order on the client, complete CLE, and certify firm AI procedures in Jessica Fuller v. Hyde School, et al. Counsel filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation.

An attorney who chooses to use such tools must ensure that every citation and quoted passage has been independently confirmed using reliable legal sources, and that any limitations of AI tools are fully understood and accounted for. Here, the Courtfinds that several specific aspects of counsel’s conductdid notsatisfy thestandard required by Rule 11. She relied …

2026-05-05 · United States District Court for the District of Hawaii · provisional

The District of Hawaii on 2026-05-05 ordered counsel to pay $1,000 after oppositions contained multiple record- and case-citation errors tied to AI use. Counsel accepted responsibility for filing the client’s AI-assisted material, and the court imposed the sanction for inadequate verification duties.

S. 544, 570 (2007)). The complaint “may not simply recite the elements of a cause of action,” and instead “must contain sufficient allegations of underlying facts to give Before the April 8, 2026 hearing, the court issued an order identifying a number of record- and case-citation issues in Moore’s oppositions and directing Moore’s counsel to …

2026-05-05 · Supreme Court of Georgia · provisional

The Supreme Court of Georgia on 2026-05-05 vacated and remanded the trial-court order, barred the prosecutor from appearing for six months, and ordered twelve CLE hours in Hannah Renee Payne v. The State. The prosecutor and trial court filed an opposition with two fabricated case citations and two mischaracterized case citations.

1. On March 20, 2026, after oral argument in this case, this Court entered an order directing counsel for the State to file a supplemental brief explaining, among other things, how the September 12, 2025 order of the trial court denying Payne’s motion for new trial (which reflects that ADA Leslie prepared that order) came …

2026-05-04 · United States District Court for the District of Utah · provisional

The District of Utah on 2026-05-04 imposed Rule 11 sanctions and ordered plaintiffs’ counsel to pay defendants $7,000 for expenses caused by non-existent case law in Regan Wilkes, et al. v. Canyons School District, et al. Counsel filed an opposition with three fabricated case citations and one mischaracterized case citation, including A.S. v. Norwalk Public Schools.

Defendants, during the hearing, asserted that they were wary of Plaintiffs’ explanation, given that the holdings of the “correct” cases were not the holdings that were cited to in the Amended Complaint, and likewise were not cited in Plaintiffs’ Opposition to the Motion to Dismiss. Defendants requested that the court, at a minimum, award attorney …

2026-05-04 · United States District Court for the District of Maryland · provisional

The District of Maryland on 2026-05-04 granted defendants’ motion to dismiss and dismissed the third amended complaint with prejudice after noting non-existent cases and quotations in Devin A. Robinson v. Velosio, LLC. The self-represented party filed a reply brief with one fabricated case citation and one false case quotation.

Defendants filed the pending motion to dismiss, Mr. Robinson filed a response, and Defendants filed a reply. ECF Nos. 34, 36, 40. Mr. Robinson also filed a “Declaration Regarding Citation Clarifications” in which he attempts to explain why his response brief contains nonexistent cases and quotations, as pointed out in Defendants’ reply brief. ECF No. …

2026-05-04 · United States Court of Appeals for the Eleventh Circuit · provisional

The Eleventh Circuit on 2026-05-04 affirmed dismissal with prejudice after the magistrate judge found willful misuse of nonexistent and misquoted cases in Eliott Williamson v. TransUnion LLC, Experian Information Solutions, Inc. The self-represented party filed a submission with one fabricated case citation, one false case quotation, and one mischaracterized case citation.

At this second show-cause hearing, Williamson stated that the errors were unintentional and based on his lack of legal knowledge. He admitted that some of the cases he cited did not exist, and that he had found them using artificial intelligence. He also admitted that he did not follow the Local Rules because they were …

2026-05-01 · Supreme Court of the State of New York · 2026 WL 1279092 · provisional

The New York Supreme Court on 2026-05-01 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities in Drip Capital, Inc. v. SGM Socher Inc. Counsel filed an opposition with two fabricated case citations, including Gildea v Sheridan.

However, in light of the history of this action and baseless arguments that have been proffered defendants are strongly cautioned that if they fail to comply or engage in further frivolous conduct serious coercive sanctions may be imposed. The court also may reconsider whether a receiver is necessary if it appears that the approach here …

2026-05-01 · United States District Court for the District of New Mexico · provisional

The District of New Mexico on 2026-05-01 fined counsel $1,000 payable to the clerk, ordered bar reporting, required proof of AI CLE, and barred passing costs to clients in Rasheem Carter, et al. v. UZGlobal LLC, et al. Counsel filed a brief with four fabricated case citations.

On June 27, 2025, theCourtissued its first showcauseorder,identifying threeadditionalcases in theMarch response brief that it could not locate. [Doc. 101, at 2]. The Court ordered Plaintiffs to (1) produce PDF versions of every case cited in the March response brief and three motions to compel; (2) describetheactionsofeachattorneyinvolvedinthecreationofthebriefs; (3)describehowcounsel became aware of the non-existent cases; (4) …

2026-05-01 · United States District Court for the Southern District of Mississippi · 2013 WL 12173926 · provisional

The Southern District of Mississippi on 2026-05-01 admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct in Johnny Fuselier v. John S. Riscassi. Counsel filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation, including Rodriguez v. It’s Just Lunch.

Mississippi, 2025 WL 3691876, at *3-5 (discussing an attorney’s obligations under Rule 11 and their duty to conduct a reasonable inquiry into the law and facts of the case). Based on the instances outlined above, Mr. Rice is directed to SHOW CAUSE on or before May 15, 2026, why the Court should not impose sanctions …

2026-05-01 · United States District Court for the District of Maryland · provisional

The District of Maryland on 2026-05-01 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Yasmani Gurri Rubio v. Markwayne Mullin, et al. The self-represented party filed a pleading with five false case quotations, including Hahn v. United States.

therefore, Defendants state that, although they are no longer able to promise adjudication within sixty days of remand, they still request that the case be remanded to USCIS to comprehensively review Mr. Gurri Rubio’s application. ECF No. 37 ¶ 6. First, the Court must again note that Mr. Gurri Rubio’s complaint and his response to …

2026-05-01 · Kentucky Court of Appeals · provisional

The Kentucky Court of Appeals on 2026-05-01 warned the self-represented appellant to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Sherdena Rocky Ali v. Carlos Efre Idiokitas. The self-represented appellant filed a brief with two fabricated case citations.

However, her status as a pro se litigant does not exempt her from following the Kentucky Rules of Appellate Procedure (RAP). Koester v. Koester, 569 S. W. 3d 412, 415 (Ky. App. 2019). Pertinent to the case sub judice, RAP 32(4) mandates an appellant’s argument must have “ample . . . citations of authority pertinent …

2026-05-01 · United States District Court for the Middle District of Georgia · provisional

The Middle District of Georgia on 2026-05-01 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Chamberlain v. City of Albany. The self-represented plaintiff filed a submission with one fabricated case citation.

(2) the claims, defenses, and other legal contentions therein are warranted by existing law or by a nonfrivolous argument for the extension, modification, or reversal of existing law or the establishment of new law; [and] (3) the allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary …

2026-05-01 · United States District Court for the Middle District of Florida · 2026 WL 1197241 · provisional

The Middle District of Florida on 2026-05-01 ordered counsel to notify the client about mis-cited and nonexistent cases and required a client-signed certification in Richard Paul Smith v. Verra Mobility Corporation et al. Counsel filed a motion with three fabricated case citations and one mischaracterized case citation, including Morgulis v. BusPatrol Am.

48) at 32–33, 41. Sullivan timely responded and “does not dispute the errors identified in the Order. ” Resp. (Doc. 50) at 2. Sullivan acknowledges that he used artificial intelligence tools, including ChatGPT, to research and draft the School Board's motion to dismiss. See id. at 2–3. He admits that he did not “complete an …

2026-04-30 · Texas Court of Appeals · 2026 WL 1190661 · provisional

The Texas Court of Appeals on 2026-04-30 affirmed the family-violence protective order after disregarding unsupported arguments based on false quotations and nonexistent cases in K.C. v. D.R. The self-represented party filed a submission with three fabricated case citations, one false case quotation, and two mischaracterized case citations.

3d 341, 345 (Tex. App. —El Paso 2015, no pet. ); and Clements v. Haskovec, 251 S. W. 3d 79, 83 (Tex. App. —Corpus Christi–Edinburg 2008, no pet. ). Moreover, from Allen, Cane provided a purported quote that does not exist, and regarding Clements, she represented that the court of appeals reversed a trial court's …

2026-04-30 · United States District Court for the Eastern District of Pennsylvania · provisional

The Eastern District of Pennsylvania on 2026-04-30 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jamal Berry v. Early Warning Services. The self-represented plaintiff filed an opposition with one fabricated case citation, one false case quotation, and one mischaracterized case citation, including McIvor v. Credit Control Servs.

Agents, Emps. or Officers, 855 F. 2d 1080, 1091 (3d Cir. 1988). It has come to the court’s attention that plaintiff, in his opposition to the motion to dismiss, submitted legal citations to cases that do not exist, fake quotes from real cases, and inaccurate legal arguments attributed to real cases. For example, plaintiff quoted …

2026-04-30 · United States District Court for the Southern District of New York · provisional

The Southern District of New York on 2026-04-30 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions. The self-represented party filed a pleading with one fabricated case citation, three false case quotations, and two mischaracterized case citations, including Inc. v. Neewra.

Y. 2008) exists, but it has nothing to do with removal, and none of the quoted language appears in the opinion; Whitaker v. Am. Telecasting, Inc. , 261 F. 3d 196 (2d Cir. 2001) exists and involves removal, but says nothing about whether a removed complaint may be filed as an exhibit to another document. …

2026-04-30 · United States District Court for the Southern District of New York · provisional

The Southern District of New York on 2026-04-30 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Mercy Wellington v. City of New York. The self-represented party filed an opposition with one fabricated case citation.

Nonexistent Legal Authority Before this Court begins its analysis, it must address Wellington’s pervasive citations to non-existent authority in her briefing. This is unacceptable. Defendants point out that Wellington’s initial opposition brief contains six “purported authorities that, on information and belief, do not appear in any legal database. ” Reply at 1-2. The Court was …

2026-04-30 · United States District Court for the Eastern District of New York · 2025 WL 2256653 · provisional

The Eastern District of New York on 2026-04-30 ordered counsel to pay $1,500 for filing unverified or fabricated authorities in Superb Motors Inc. et al. v. Anthony Deo et al. Counsel filed a submission with two fabricated case citations, including In re Marcus, 491 F.2d 56, 60 (2nd Cir. 1974).

Under the circumstances presented here and considering Thomasson’s response to the OSC, this Court is left with no choice but to impose sanctions under Rule 11 which is well in line with the developing case law. See e. g. , United States v. Cohen, 724 F. Supp. 3d 251, 258 (S. D. N. Y. 2024) …

2026-04-30 · Court of Common Pleas of Montgomery County, Ohio · provisional

The Court of Common Pleas of Montgomery County, Ohio on 2026-04-30 awarded $5,237 against the filing party for expenses caused by fabricated or misrepresented authorities in Ascent Management, Inc. et al v. Shell Oil Company et al. Counsel filed a submission with one fabricated case citation and three mischaracterized case citations, including Perrico v. Verizon.

), quoting Black's Law Dictionary, 1103 (6 Ed. 1991). ensure that they support the proposition they are representing. 19 It goes without saying that submitting fake or materially misleading citations means that the attorney failed to read and verify the cases. R. C. 2323. 51(A)(2) defines “frivolous conduct” as: Conduct of … other party to …

2026-04-30 · Michigan Court of Appeals · 2026 WL 1194667 · provisional

The Michigan Court of Appeals on 2026-04-30 affirmed summary disposition for the township and noted the appellant’s cited Michigan Supreme Court case was hallucinated in Eagle Township v. Shaun VanAlstine. The self-represented party filed a submission with one fabricated case citation.

The Supreme Court case cited by VanAlstine, Highland Park v Grifith Motors, 336 Mich 588, 592; 59 NW2d 54 (1953), does not exist—it's a hallucinated citation that is likely the product of generative artificial intelligence (AI). *6 VanAlstine contends that he “made diligent efforts to comply with local requirements, including consulting with Clinton County Building …

2026-04-30 · United States District Court for the District of Maryland · provisional

The District of Maryland on 2026-04-30 ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities in Darrin L. Johnson, Jr. v. Nationstar Mortgage, LLC, et al. The self-represented party filed a pleading with one fabricated case citation.

“[I]n exercising that discretion to impose sanctions for a pleading or paper’s lack of legal support, the court must apply an objective standard, inquiring whether ‘a reasonable attorney in like circumstances could not have believed his actions to be legally justified. ’” Lokhova, 30 F. 4th at 354 (quoting Hunter v. Earthgrains Co. Bakery, 281 …

2026-04-30 · United States District Court for the Northern District of Illinois · provisional

The Northern District of Illinois on 2026-04-30 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Faisal Rahman v. Michael J. Burton, et al. The self-represented plaintiff filed an opposition with two fabricated case citations.

R. Civ. P. 11(b) (emphasis added). Rule 11 applies to pro se plaintiffs, and filing documents containing citations to nonexistent cases or arguments wholly unsupported by the record violates Rule 11. In both his complaint and his opposition to defendants’ motions to dismiss, Rahman cites cases that do not exist. See, e. g. , [38] …

2026-04-30 · United States District Court for the Southern District of Iowa · provisional

The Southern District of Iowa on 2026-04-30 ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities in Burnside v. Verdick, et al. The self-represented party filed a pleading with six fabricated case citations, including Jones v. County of Los Angeles.

Genuine Parts Co. , 463 F. Supp. 2d 928, 934 (E. D. Wis. 2006). These erroneous citations suggest that artificial intelligence was used to draft the complaint, producing the phenomenon known as “hallucinations,” i. e. , fabricated cases that do not exist. Unfortunately, this has become an unwelcome fixture in court filings across the country. …

2026-04-29 · United States District Court for the Southern District of New York · provisional

The Southern District of New York on 2026-04-29 fined counsel $2,500 and ordered counsel to notify the client about the AI-related citation errors in Sai Malena Jimenez-Fogarty v. Thomas Fogarty et al. Counsel filed a brief with seven fabricated case citations.

” 1st OSC at 2. While most attorneys provide such an explanation, which often involves an admission of reliance on artificial intelligence (“AI”) platforms, Lindsay’s brief sworn statement in response offers only airy generalities and conclusory statements. Her response contains no coherent explanation for how the two memoranda of law came to contain the fabricated …

2026-04-29 · United States District Court for the District of Maryland · provisional

The District of Maryland on 2026-04-29 granted defendants’ summary-judgment motion in part, denied plaintiff’s summary-judgment motion, and refused to rely on a fabricated case in Jane Doe v. Baltimore City Board of School Commissioners. Counsel filed a reply brief with one fabricated case citation.

(2) November 8, 2021 – Plaintiff asserts that, during her meeting with , he “stated her accommodations were being violated by ‘repeatedly giving her work with deadline demands,’” but told her that the accommodations were “‘guiding principles’to be followed only ‘tothe extent possible,’” and that she “needed to be ‘more flexible’ratherthan insisting on adherence to …

2026-04-29 · Appellate Court of Maryland · 2026 WL 1162579 · provisional

The Appellate Court of Maryland on 2026-04-29 struck the portions of the appellant’s brief that relied on three nonexistent nunc pro tunc cases in Amparo Trejo v. Miguel Angel Amaya Hernandez. Counsel filed a brief with three fabricated case citations.

For example, the “Standard of Review” section does not contain a single citation. 4 We strike the portions of Appellant's brief as it pertains to this argument because the three cases cited as support do not exist. 5 While not binding on this Court, this case was acknowledged as persuasive support in the following cases: …

2026-04-29 · United States District Court for the District of Kansas · provisional

The United States District Court for the District of Kansas on 2026-04-29 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Justin Spiehs v. Erik Smith. Counsel filed a brief with one false case quotation.

Second, the court will allow Plaintiff’s excessive force complaint against Defendants Byttner and Manker to move forward as he alleges that they unnecessarily kneed him and struck Defendants point out to the court that three cases cited and quoted by Plaintiff in support of this proposition are defective as the quotes used in Plaintiff’s brief …

2026-04-29 · Iowa Court of Appeals · 2026 WL 1162553 · provisional

The Iowa Court of Appeals on 2026-04-29 deemed issues waived where the appellant relied on nonexistent or irrelevant authorities instead of valid supporting law in Nisland Asset Investment, LLC v. Carissa Ann Gericke. The self-represented appellant filed a brief with two fabricated case citations and one mischaracterized case citation.

903(2)(a) (8) (requiring for each issue “[a]n argument containing the appellant's contentions and the reasons for them with citations to the authorities relied on” and warning that “[f ]ailure to cite authority in support of an issue may be deemed waiver of that issue”). To the contrary, Gericke repeatedly cited two cases that do not …

2026-04-29 · California Court of Appeal, Fifth District · provisional

The California Court of Appeal, Fifth District on 2026-04-29 warned the self-represented mother to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in In re W.B. The self-represented mother filed an opening brief with one fabricated case citation.

DISCUSSION As a preliminary matter, we address mother’s statement in her opening brief that she used “something…on [her] phone” to draft her brief. Given the context of mother’s statement, and the content and style of the brief itself, we infer that mother may be referring to a generative Artificial Intelligence (AI) system. We accept that …

2026-04-29 · United States Court of Appeals for the Fifth Circuit · provisional

The Fifth Circuit on 2026-04-29 affirmed the bankruptcy orders denying motions to void property sales and rejected arguments supported by nonexistent or inapposite authority in In the Matter of Ikechukwu H. Okorie. The self-represented party filed a submission with one fabricated case citation and one mischaracterized case citation.

see Cult Awareness Network, Inc. v. Martino (In re Cult Awareness Network, Inc. ), 151 F. 3d 605, 607 (7th Cir. 1998) (“Debtors, particularly Chapter 7 debtors, rarely have [] a pecuniary interest [in a bankruptcyorder]becausenomatterhowtheestate’sassetsaredisbursedby the trustee, no assets will revert to the debtor. ” (citing In re Schultz Mfg. Fabricating Co. , 956 …

2026-04-29 · United States District Court for the District of Arizona · 2026 WL 1162306 · provisional

The District of Arizona on 2026-04-29 struck the defective motion and warned the self-represented plaintiff that future fabricated citations may result in sanctions in Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al. The self-represented plaintiff filed a pleading with two fabricated case citations, including Ellsworth v. Am. Arbitration Ass'n.

38-1 at 17–18); see Lary v. Trinity Phys. Fin. & Ins. Services, 780 F. 3d 1101 (11th Cir. 2015). These hallucinations allow the Court to infer that Plaintiff prepared her filing with the use of generativeartificialintelligence(“AI”). Whiletheuseofsuch a tool is not necessarily problematic, the failure to confirm the accuracy of the filing is. Rule 11 …

2026-04-28 · United States District Court for the Eastern District of Tennessee · provisional

The Eastern District of Tennessee on 2026-04-28 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Pate v. CMG Mortgage, Inc., et al. The self-represented plaintiff filed a submission with two fabricated case citations.

Brooks Farms, LLC, 624 S. W. 3d 601 (Tenn. Ct. App. 2020). ” (See Doc. 31, at 3 n. 1; Doc. 35, at 4. ) Plaintiffs have filed a notice of errata acknowledging some of these errors. (Doc. 36. ) The Court does not find it necessary to address sanctions at this time, but Plaintiffs …

2026-04-28 · United States District Court for the Middle District of North Carolina · provisional

The Middle District of North Carolina on 2026-04-28 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Brandon Rulund Akins v. Tashi Latwon Ratliff, et al. The self-represented plaintiff filed a submission with nine fabricated case citations.

Scharf, No. 3:25cv1015, 2026 WL 642917, at *2 (W. D. N. C. Feb. 25, 2026); see also id. (“Even a cursory Google search would [have] reveal[ed] that these cases do not exist [as cited]. ”). More pointedly, Plaintiff’s submissions foreground an issue that “[c]ourts across the country are grappling with,” In re Nwaubani, No. 25-9517, …

2026-04-28 · United States District Court for the Eastern District of Michigan · provisional

The Eastern District of Michigan on 2026-04-28 ordered counsel to attend an ethics seminar and file proof of attendance after finding AI-supplied bogus case law in Loyer v. Wayne County Michigan et al. Counsel filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation.

Kumar Magistrate Judge Curtis Ivy, Jr. ORDER TO SHOW CAUSE Counsel for plaintiff, Ronnie E. Cromer, Jr. (“Cromer”) filed a response brief containing multiple citations that were entirely fictitious, had different citations, and/or did not contain the quote or content attributed to them. See ECF No. 50. Cromer admitted at a hearing before the Court …

2026-04-28 · United States District Court for the Northern District of California · provisional

The Northern District of California on 2026-04-28 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Louis L. Ligon III v. Meta Platforms, Inc. The self-represented plaintiff filed a reply brief with one mischaracterized case citation.

(FAC ¶ 8. ) Plaintiff received a verification code on May 8 for additional vetting. (FAC ¶ 9. ) On May 9, he created six political ads for his Defendant argues in its reply that Plaintiff’s response should be given little weight because he improperly used artificial intelligence (“AI”) to draft his filing, leading to …

2026-04-28 · United States District Court for the Northern District of California · provisional

The Northern District of California on 2026-04-28 admonished counsel, fined counsel $1,001, required four hours of live CLE, and ordered circulation of the sanction order in Anthony C. Hill v. Workday, Inc. Counsel filed a submission with one fabricated case citation and one mischaracterized case citation.

Long before the public launch of various AI or large language models such as ChatGPT, the Fifth Circuit affirmed an award of sanctions by noting that “[f]iling mountainous piles of unorganized documents and citing to nonexistent rules of law are precisely the sort of conduct that, under the objective test of Rule 11, could lead …

2026-04-28 · United States District Court for the Central District of California · provisional

The Central District of California on 2026-04-28 fined counsel $2,500 and required reporting the sanction order to other courts where counsel had appeared in Tekoma Chaney v. Transdev Services Inc. et al. Counsel filed a submission with three fabricated case citations, including In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015).

2d 1391, 1393 (1980) (quoting Roadway Express, 447 U. S. at 767). Two overarching factors drive the Court’s sanctions order. First, the imposition of sanctions for submitting generative-AI hallucinations is so well-documented at this point that the Court finds the failure to verify citations after using generative-AI rises to the level of bad faith. According …

2026-04-28 · United States District Court for the Northern District of Alabama · provisional

The Northern District of Alabama on 2026-04-28 admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct in Tunstall v. Alabama Department of Corrections. Counsel filed a submission with one false case quotation, including Thomas v. Dillard.

3d 1432, 1433-34 (11th Cir. 1997), and attributes to it the following quotation: “‘Resign or be fired’ scenarios are classic jury questions. ” (Doc. # 48 at 15-16). The court’s own review of Thomas reveals that no such language appears anywhere in that opinion. The court declines to speculate as to how this misattribution occurred, …

2026-04-27 · United States District Court for the Southern District of Texas · provisional

The Southern District of Texas on 2026-04-27 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Moore v. Wireless CCTV LLC. The self-represented party filed a pleading with two fabricated case citations, including Thomas v. City of San Marcos.

14, 2020). private cause of action; that claim is dismissed, with prejudice, because amendment would be futile. Moore has one final opportunity to amend and must do so no later than May 15, 2026. 8 SIGNED on April 27, 2026, at Houston, Texas. ________________________________ Lee H. Rosenthal Senior United States District Judge Wireless also asserts …

2026-04-27 · United States District Court for the Middle District of Pennsylvania · provisional

The Middle District of Pennsylvania on 2026-04-27 admonished the self-represented plaintiff for unverified or fabricated authorities and cautioned against repeating the citation misconduct. The self-represented plaintiff filed a brief with one fabricated case citation, one fabricated or AI-like submission item, and one invented legal doctrine, including TRO brief attributes a holding to Manuel v. City of Joliet that it….

See Kay v. Ehrler, 499 U. S. 432, 438 (1991). In this variety of hallucination, the Almodel appears to have provided the plaintiff with a legal doctrine that he wanted to exist without it actually existing. also filed an accompanying Al-aided motion for a temporary restraining order (“TRO”) along with an Al-aided brief in support. …

2026-04-27 · Supreme Court of the State of New York · 2026 WL 1279715 · provisional

The New York Supreme Court on 2026-04-27 granted the motion to dismiss the election petition and noted that sanctions were unavailable because the respondent did not request them in In the Matter of the Application of Jonathan David Rinaldi. The self-represented party filed a submission with one fabricated case citation.

This Court notes that upon review of the petition, petitioner's citations were either for New York cases that were general election law matters and inapplicable to the facts in this case, or to nonexistent case law. Respondent's argument that the case law petitioner presented was AI hallucinations and fabricated has some merit, but since respondent …

2026-04-27 · United States District Court for the Southern District of New York · provisional

The Southern District of New York on 2026-04-27 allowed refiling but warned the self-represented plaintiff after AI-like placeholders and repeated nonsensical text appeared in Rhonda L. H.-B. v. Commissioner of Social Security. The self-represented plaintiff filed an opposition with two fabricated or AI-like submission items.

and • a 179-page "Memorandum of Law in Opposition to Defendant's Motion to Dismiss and in Support of Emergency Relief, Mandamus, and Judicial Enforcement. " (Dkt. 40 at 3. ) As discussed in more detail below, portions of plaintiff's papers appear to constitute the unedited output of a generative artificial intelligence (AI) tool. Plaintiff's Motions …

2026-04-27 · United States District Court for the District of Maryland · provisional

The District of Maryland on 2026-04-27 imposed page limits and warned the self-represented plaintiffs after identifying a nonexistent forfeiture case citation in Ali Behroz Aziz, et al. v. United States of America, et al. The self-represented plaintiff filed a motion with one fabricated case citation, including United States v. $17,900 in U.S. Currency.

53–55, 56–58) comprising over 40 pages of coherent legal analysis all on April 10, 2026, the day after the Court’s prior order, ECF No. 52. The latest flurry worsens a pattern of repeated filings: the Court’s previous order denied four of Plaintiffs’ motions that were filed within the space of a few weeks. ECF No. …

2026-04-24 · Supreme Court of the State of New York · 2026 N.Y. Slip Op. 31794(U) · provisional

The New York Supreme Court on 2026-04-24 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Keefe v. BMakin Film Ltd. The self-represented party filed a motion with one fabricated case citation, two false case quotations, and one mischaracterized case citation, including Klapper v. Graziano.

BMakin Film Ltd, 2026 WL 1164759 (2026) sanctions or both shall be entered as a judgment of the court. In no event shall the amount of sanctions imposed exceed $10,000 for any single occurrence of frivolous conduct. ” *3 Submissions that rely on non-existent cases generated by artificial intelligence, resulting in AI “hallucinations” and cases …

2026-04-24 · United States Court of Appeals for the Fifth Circuit · provisional

The Fifth Circuit on 2026-04-24 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in United States v. Jose Marquez. The self-represented plaintiff filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation.

2023). Before concluding, we note that Marquez’s deceptive briefing practices deserve special mention and admonition. After an exhaustive reviewofMarquez’sbrief,weconcludethatsomeofthecasesMarquezcites do not exist and nearly every quotation from the caselaw that he cites from existing caselaw is either misquoted or fabricated. Further, most of the legal propositions that Marquez posits are supported by our caselaw are …

2026-04-24 · United States Court of Appeals for the Tenth Circuit · 2026 WL 1122106 · provisional

The Tenth Circuit on 2026-04-24 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Ryan-Michael Jarvis v. County of Teton Wyoming. The self-represented party filed a pleading with one false case quotation and one mischaracterized case citation, including Spinelli v. United States that does not appear in the opinion.

S. 213 (1983): “The mere assertion of a complaint ... without corroboration or personal knowledge of a crime, fails to establish probable cause. ” Aplt. Opening Br. at 21 (alteration in original) (internal quotation marks omitted). But we cannot find this quote (or any similar proposition) in Spinelli. Nor does the quotation appear in any …

2026-04-24 · Supreme Court of Alabama · provisional

The Supreme Court of Alabama on 2026-04-24 doubled appellate costs, awarded $17,200, prohibited further filings without counsel, and referred counsel to the Alabama State Bar in Laurie Ibach and Mark Stewart v. Bruce Stewart. Counsel filed a submission with five fabricated case citations and three false case quotations, including Quoted Janowiak v. Tiesi as supporting a proposition.

, concurring) ("offer[ing] … preliminary thoughts about whether and how [AI-powered large language models] might aid lawyers and judges in the interpretive enterprise"). Rather, the problem of fake citations in court filings is the result of attorneys failing to properly research and verify the results of AI-generated citations -- in short, attorney negligence in checking …

2026-04-23 · Texas Court of Appeals · 2026 WL 1097101 · provisional

The Texas Court of Appeals on 2026-04-23 affirmed the judgment for Buffalo Creek after finding no reversible error and noting unsupported or nonexistent authorities in the brief in Joann Crawford v. Buffalo Creek Properties, LLC. The self-represented party filed a brief with two fabricated case citations and one invented legal doctrine, including Hercenberger v. Proctor' without a reporter citation.

She does not specify in her brief what amendment she refused to accept. She cites cases that she purports support the proposition that any amendments to the Contract had to be in writing. However, Crawford's cited cases are either “hallucinated” cases or do not support the proposition that the mere proposal of an amendment nullified …

2026-04-23 · Texas Court of Appeals · 2026 WL 1137938 · provisional

The Texas Court of Appeals on 2026-04-23 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in IN RE PAULA M. MILLER, Relator. Counsel filed a submission with one fabricated case citation and one false case quotation.

IN RE PAULA M. MILLER, Relator NO. 01-26-00319-CV | Opinion issued April 23, 2026 Original Proceeding on Petition for Writ of Mandamus Panel consists of Chief Justice Adams and Justices Caughey and Morgan. Adams, C. J. , concurring. CONCURRING OPINION Terry Adams Chief Justice *1 I write separately to note that the mandamus petition herehasattributionsandquotationstocaselawwhichstrongly …

2026-04-23 · Appellate Court of Maryland · 2026 WL 1101776 · provisional

The Appellate Court of Maryland on 2026-04-23 affirmed the custody judgment, assessed costs to the appellant, and exercised discretion not to strike a brief with fictitious citations in Fatima Meziane v. Abdelouahab Aitouche. The self-represented appellant filed a brief with two fabricated case citations, including Hurd v. Hurd.

” In support, she cites In re Yves S. , 373 Md. 551, 586–87 (2003) and Karanikas v. Cartwright, 209 Md. App. 571, 589–90 (2013). Neither of these cases support the stated proposition. To be sure, citations of inapposite authority is not uncommon in pro se filings, and, alone, it does not necessarily indicate the …

2026-04-23 · United States District Court for the Southern District of Indiana · provisional

The Southern District of Indiana on 2026-04-23 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Philip D. Dennison v. June Caudill et al. The self-represented party filed a pleading with one fabricated case citation, including Coleman v. Hudson.

However, Dennison is accordingly warned of the possibility of sanctions if any future filings violate Rule 11(b). The Court notes that when Dennison filed his complaint, he did not know which judge would preside over the matter. However, this Court entered a supplemental notice to pro se litigants regarding the use of artificial intelligence on …

2026-04-23 · California Court of Appeal, Second District · provisional

The California Court of Appeal, Second District on 2026-04-23 affirmed the judgment, awarded appellate costs to O.K., and rejected record-augmentation arguments tied to alleged fabricated citations in O.K., LLC v. Melka. The self-represented party filed a reply brief with one fabricated case citation and one mischaracterized case citation.

’s respondent’s brief highlights the deficits in the appellate record and asks this court to affirm on that basis. The respondent’s brief also complains that several of the cases cited by Melka in her opening brief either do not exist or do not support the claimed proposition for which they were cited— hallmarks, in respondent’s …

2026-04-23 · United States District Court for the District of Alaska · provisional

The District of Alaska on 2026-04-23 admonished the self-represented party for unverified or fabricated authorities and cautioned against repeating the citation misconduct. The self-represented party filed a submission with three mischaracterized case citations, one fabricated legal rule, and one fabricated or AI-like submission item, including Jimerson v. Tetlin Native Corp. as holding that transactions affecting ANCSA l.

The Court recognizes the difficulty of making this showing and thus does not reach this conclusion lightly. However, Gunter is not advancing a debatable interpretation of an ambiguous law, which would clearly give rise to federal jurisdiction. He is relying on a phantom provision ofANCSAthat does not exist. Beyond that, Gunter offers no explanation for …

2026-04-22 · United States District Court for the District of Utah · provisional

The District of Utah on 2026-04-22 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson. Counsel filed an opposition with one fabricated case citation and one false case quotation.

46 Significantly, here, Ms. Johnson’s request is not premised on the need to respond to newly-raised issues or to proffer newly-discovered evidence. As Mr. Finlayson has suggested, it appears that the initial Opposition may have resulted from the improper use of artificial intelligence (“AI”). Ms. Johnson’s initial Opposition was riddled with case citations and quotations …

2026-04-22 · Texas Court of Appeals, Fourth District · provisional

The Texas Court of Appeals, Fourth District on 2026-04-22 affirmed the summary judgment for the bank and declined to initiate sanctions proceedings over two non-existent cases in Meyer v. Castroville State Bank. The self-represented party filed a submission with two fabricated case citations.

at 124 (“In accord with the substance and sense of our decisions in Lassiter and Santosky, [citation omitted], we place decrees forever terminating parental rights in the category of cases in which the State may not ‘bolt the door to equal justice[. ]’”). We overrule the Meyers’s second issue. D. Nonexistent Authority Before concluding, we …

2026-04-22 · Oregon Court of Appeals · provisional

The Oregon Court of Appeals on 2026-04-22 struck the brief, awarded $8,044 in costs, and allowed appellant to file a replacement brief by a fixed deadline in Carol L. Williams v. Tracy Honl. Counsel filed an opening brief with one fabricated case citation, one false case quotation, and three mischaracterized case citations, including Tubra v. Cooke.

” On receipt of the parties’ responses, the court, through the Chief Judge, referred the matter to the Motions Department for resolution by way of precedential opinion issued by a three-judge panel because of the important and concerningly recurrent nature of the issue. As an initial matter, the professional choice for appellant's attorney to have …

2026-04-22 · Supreme Court of Nevada · provisional

The Supreme Court of Nevada on 2026-04-22 fined counsel $250, referred counsel to the State Bar, and denied leave to file a corrected opening brief in Yanling Zhang v. Yanhui Zhang. Counsel filed an opening brief with two fabricated case citations and two mischaracterized case citations, including City of Henderson v. Bldg. & Constr. Trades Council.

BROWN EME COURT IN THE SUPREME COURT OF THE STATE OF NEVADA YANLING ZHANG, Appellant, vs. YANHUI ZHANG, Respondent. ORDER IMPOSING SANCTIONS, REFERRING COUNSEL TO THE STATE BAR FOR INVESTIGATION, AND DENYING REQUEST TO CORRECT OPENING BRIEF On March 23, 2026, we entered an order toshow cause why this court should not impose sanctions or …

2026-04-22 · United States District Court for the Eastern District of Michigan · provisional

The Eastern District of Michigan on 2026-04-22 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Alishia Monique Jones v. Ahmed Taylor, et al. The self-represented plaintiff filed a submission with two fabricated case citations, including Tokio Marine & Fire Insurance Company v. Flota Mercante Grancolombiana.

Cf. id. at 625. Jones’s citation to Tokio Marine&FireInsuranceCompanyv. Flota Mercante Grancolombiana, S. A. , 35 F. 3d 1134 (6th Cir. 1994) is not to a real case, which suggests that Jones might be using artificial intelligence (AI) software prone to creating fake cases. And citing to cases that do not exist is a sanctionable …

2026-04-22 · California Court of Appeal, Sixth District · 2026 WL 1102361 · provisional

The California Court of Appeal, Sixth District on 2026-04-22 affirmed the status-only judgment and postjudgment orders and ordered the parties to bear their own appellate costs in In re the Marriage of Joanne Rodrigues and Nathan Craig. The self-represented appellant filed a brief with nine fabricated case citations.

) Appellant's brief does not engage with the applicable standards of review. It contains little if any legal argument or citations to relevant authority. Instead, the brief cites authorities that do not support the propositions for which they are cited; decisions that have been disapproved by the Supreme Court; 10 and numerous nonexistent cases. 11 …

2026-04-22 · United States District Court for the Eastern District of California · 2026 WL 1092496 · provisional

The Eastern District of California on 2026-04-22 fined counsel $1,000 and referred counsel to the State Bar after finding false quotations in the remand papers in Krista C. Geddes v. LoanCare, LLC, et al. Counsel filed a submission with two false case quotations.

However, the undersigned finds that while the scope of the violation here may be distinguishable from Tercero, the existence of an intent to gain an unfair advantage through a misrepresentation of legal citation is the same in both cases, and here warrants both a monetary sanction and reporting to the bar. Although its use is …

2026-04-22 · United States District Court for the District of Arizona · provisional

The District of Arizona on 2026-04-22 granted Circle K’s motion to dismiss in part, denied it in part, and identified a nonexistent Navient citation in the complaint in Daniel D’Agostino v. Circle K Stores Incorporated, et al. The self-represented plaintiff filed a motion with one fabricated case citation, including LLC v. Law Offices of Jeffrey Lohman.

In support of this claim, Plaintiff cites to Navient Solutions, - 18 - LLC v. Law Offices of Jeffrey Lohman, 2020 WL 1864871, at *12 (D. Ariz. 2020). This case does not exist. As Circle K notes in its Motion to Dismiss, a search of “2020 WL 1864871” returns an Ohio Public Utilities Commission Finding …

2026-04-21 · Supreme Court of Puerto Rico · provisional

The Supreme Court of Puerto Rico on 2026-04-21 admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct in In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry. Counsel filed a submission with six fabricated case citations, including Otero-Burgos v. Inter Med. Supplies.

Supp. 3d 443 (2023), constituye el primer caso donde se analizó extensamente el uso de inteligencia artificial generativa para producir citas ficticias y donde se impusieron sanciones detalladas por el mal uso de ChatGPT en un escrito judicial. 2 En lo concerniente a la conducta sancionable específica, el Tribunal de Distrito para el Distrito Sur …

2026-04-21 · Superior Court of the District of Columbia · 2026 WL 1345470 · provisional

The Superior Court of the District of Columbia on 2026-04-21 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jurkowski v. Berkowitz. The self-represented plaintiff filed a pleading with one fabricated case citation and one mischaracterized case citation.

4 Because the Court is granting Plaintiff an additional opportunity to move to amend the Complaint, the Court will at this time deny the pending Motions to Dismiss as moot, and without prejudice. The Defendants may renew their motions to dismiss at a later date, if the motions remain relevant. F. Use of Artificial Intelligence …

2026-04-20 · Washington Court of Appeals · 2026 WL 1069752 · provisional

The Washington Court of Appeals on 2026-04-20 admonished the self-represented party for unverified or fabricated authorities and cautioned against repeating the citation misconduct in Arthur West v. Lower Duwamish Waterway Group. The self-represented party filed a brief with one fabricated case citation and one false case quotation.

see also Telford, 95 Wn. App. at 162 & n. 17 (discussing 1991 Att'y Gen. Op. No. 5). This is not persuasive to the instant record. 13 Atcertainpointsinhisbriefing,Westprovidesfictitiousquotationsfromexistentcases. Werebukesuchlackof candor as detrimental and offensive to the legal process and not worthy of judicial review. Everyone, including pro se litigants, are responsible to confirm their pleadings, …

2026-04-20 · United States District Court for the Northern District of Alabama · provisional

The Northern District of Alabama on 2026-04-20 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities. Counsel filed an opposition with two fabricated case citations, three false case quotations, and three mischaracterized case citations, including Jarrod Johnson v. Water Light & Sinking Fund Comm’n.

The court did not, however, give Plaintiffs a deadline to file that amendment because Plaintiffs must respond to this order first. While reviewing the parties’ briefs on 3M’s Rule 12(c) motion, the court noticed that Plaintiffs’ opposition (doc. 39) was riddled with misquotes, false quotes, strained case interpretations, and citations that seem to have been …

2026-04-18 · United States Bankruptcy Court for the Southern District of New York · provisional

The Bankruptcy Court for the Southern District of New York on 2026-04-18 received the firm’s corrective letter identifying AI hallucinations, accepted corrected citations, and noted the apology in In re Prince Global Holdings Limited, et al. Counsel filed a motion with two fabricated case citations, one false case quotation, and one mischaracterized case citation.

I became aware Thursday evening that the JPLs’ Emergency Motion for Entry of Orders Granting (I) Ex Parte Relief and (II) Provisional Relief, Pursuant to Section 1519 of the Bankruptcy Code filed with the Court on April 9, 2026 (the “Motion”) [D. I. 9] includes inaccurate citations and other errors, each of which is identified …

2026-04-17 · United States District Court for the Central District of California · 2026 WL 1104324 · provisional

The Central District of California on 2026-04-17 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Robert Harris v. Elementis Specialties, Inc. Counsel filed a motion with one fabricated case citation and one mischaracterized case citation.

Plaintiff argues Defendant's Motion to Dismiss was filed “without reliable legal support” and cites “multiple authority defects. ” Mot. at 11. Among other things, Plaintiff cites (and Defendant has confirmed) its use of AI resulted in several citation errors, including a completely hallucinated cite and other cites that do not support the proposition Defendant's claimed …

2026-04-16 · United States District Court for the Eastern District of Texas · 2026 WL 1040383 · provisional

The Eastern District of Texas on 2026-04-16 admonished the self-represented plaintiff about inaccuracies in a joint discovery report caused by generative-AI reliance. The order required future disclosures identifying any generative-AI use and certifications that the filer reviewed AI work product for accuracy and relevance.

LAUD ESSANDOH v. United States District Court, E. D. Texas, Sherman Division. LAUD ESSANDOH v. CAPITAL ONE BANK NA NO. ORDER ON DISCLOSURE AND CERTIFICATION REQUIREMENTS FOR USE OF GENERATIVE ARTIFICIAL INTELLIGENCE Bill Davis United States Magistrate Judge *1 Today, the court held a discovery hearing based on the parties' joint report, Dkt. 25, following …

2026-04-16 · United States District Court for the District of Colorado · 2026 WL 1040465 · provisional

The District of Colorado on 2026-04-16 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jamie Lee Saunders v. Albertsons/Safeway, LLC. The self-represented party filed a reply brief with one fabricated case citation.

72(a) (“When a pretrial matter not dispositive of a party's claim or defense is referred to a magistrate judge to hear and decide, the magistrate judge must promptly conduct the required proceedings and, when appropriate, issue a written order stating the decision. ”). 3 As a preliminary matter, in its surreply, Safeway includes an embedded …

2026-04-15 · Texas Court of Appeals, Fifth District · provisional

The Texas Court of Appeals, Fifth District on 2026-04-15 affirmed summary judgment for Rockwall Rental Properties after appellants relied on unsupported and hallucinated case citations in Fofanah v. Rockwall Rental Properties. The self-represented appellant filed a reply brief with one fabricated case citation and two mischaracterized case citations, including Khan v. GBAK Properties.

After appellee filed its brief, cogently and logically demonstrating the lack of merit in appellants’ appellate argument and showing that the case citations briefed by appellants do not stand for the claimed propositions of law, appellants filed a replybrief. Thereplybriefattemptedtoaddanappellateissue,anditincludedfifteen opinion citations. Of those, one is a purported opinion from this court for which the …

2026-04-15 · Minnesota Court of Appeals · 2026 WL 1065922 · provisional

The Minnesota Court of Appeals on 2026-04-15 affirmed the district court’s order and noted that the husband cited an unlocatable DeMars decision resembling an AI hallucination in Nelson v. Derry. The self-represented party filed a brief with one fabricated case citation, including DeMars v. DeMars.

, 783 F. Supp. 3d 959, 960 (N. D. Tex. 2025) (“It is no secret that generative [artificial intelligence (AI)] programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in …

2026-04-15 · Appellate Court of Illinois, First District · 2026 IL App (1st) 242451-U · provisional

The Appellate Court of Illinois, First District on 2026-04-15 struck the defective brief after finding Centient AI links, false quotations, and numerous nonexistent authorities. The self-represented plaintiff filed an opening brief with one fabricated case citation and two mischaracterized case citations, including Dunn v. Old Orchard Ctr.

” McCann v. Dart, 2015 Il App (1st) 141291, ¶ 15. “Arguments that do not comply with Rule 341(h)(7) do not merit consideration on appeal and may be rejected by this court for that reason alone. ” Wells Fargo Bank, N. A. v. Sanders, 2015 IL App (1st) 141272, ¶ 43. ¶16Plaintiffs’convolutedbriefsincludeabundantcitationsto both hallucinated cases …

2026-04-15 · Government Accountability Office · B-423066.2 · provisional

The Government Accountability Office on 2026-04-15 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Matter of: LOGMET LLC, B-423066.2. The self-represented party filed a submission with one fabricated case citation and one mischaracterized case citation.

While we do not specifically address all of the protester’s arguments, we have considered them and conclude that they do not provide a basis to sustain the protest. We note that in reviewing the protester’s filings, we identified several irregularities in citations provided by the protester. In this regard, the protester cited decisions of our …

2026-04-14 · United States District Court for the Northern District of Mississippi · provisional

The Northern District of Mississippi on 2026-04-14 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Brian Smith v. TD Auto Finance LLC, et al. The self-represented party filed a motion with one fabricated case citation.

Smith’s claims against the non-signatories—SBI, A & A, and B & C—must be hashed out in arbitration. The Court declines to lift the stay as to the non-signatory defendants. Artificial Intelligence Though the Court has found good reason to deny Smith’s motion, it pauses to address Smith’s use of generativeAI. In response to the motion, …

2026-04-14 · United States District Court for the Southern District of Indiana · provisional

The Southern District of Indiana on 2026-04-14 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Cynthia White v. Walmart, Inc. Counsel filed a submission with one fabricated or AI-like submission item and one misstated record or submission point.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION CYNTHIAWHITE, ) ) Plaintiff, ) ) v. ) No. 1:25-cv-01120-RLY-TAB ) WALMART, INC. , ) ) Defendant. ) DISCOVERY ORDER FOLLOWING APRIL10, 2026, TELEPHONIC STATUS CONFERENCE Artificial intelligence can be a useful discovery tool. However, as discussed below,AI is not a substitute for attorneys and …

2026-04-14 · California Court of Appeal, Sixth District · 2026 WL 1004593 · provisional

The California Court of Appeal, Sixth District on 2026-04-14 admonished the self-represented appellant for unverified or fabricated authorities and cautioned against repeating the citation misconduct. The self-represented appellant filed a reply brief with one fabricated case citation and two false case quotations, including Tennessee v. Lane that do not appear in that opinion.

4th 737, 750, for the following quotation: “a judge may not act on personal knowledge of facts not presented in evidence or conduct an independent investigation of facts not in evidence. ” However, no such quotation appears in that case, or in any other case this court was able to locate. In addition to the …

2026-04-14 · United States District Court for the Eastern District of California · provisional

The Eastern District of California on 2026-04-14 ordered the self-represented plaintiff to show cause why sanctions or corrective action should not issue for the defective authorities in Shaw v. City of Portola, et al. The self-represented plaintiff filed a reply brief with one fabricated case citation and five mischaracterized case citations, including People v. Dang.

The Court not found any such case and therefore finds Plaintiff has cited a nonexistent case. 6 Plaintiff fails to address Boyd in her reply despite Defendants directing Plaintiff’s attention to the error, ECF No. 24, pg. 4. Plaintiff instead asserts that “Plaintiff has not cited fictitious cases and there is no basis to infer …

2026-04-13 · Ohio Court of Appeals, Third District · 2026-Ohio-1335 · provisional

The Ohio Court of Appeals, Third District on 2026-04-13 affirmed the traffic conviction, assessed appellate costs, and noted that some of the appellant’s cited cases did not seem to exist in State of Ohio v. Abdullah M. Alqahtani. The self-represented appellant filed a submission with one fabricated case citation, one mischaracterized case citation, and one misstated legal rule.

” Prof. Cond. R. 8. 4(c)-(d). “It is well established that courts possess inherent authority to manage proceedings essential to their function, to control the conduct of those who appear before them, and to sanction conduct that abuses the judicial process. ” State v. Coleman, 2026-Ohio-965, ¶ 39 (11th Dist. ). Striking a filing containing …

2026-04-13 · United States District Court for the Northern District of Illinois · provisional

The Northern District of Illinois on 2026-04-13 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Allen v. Hunt. The self-represented plaintiff filed a brief with two fabricated case citations, including LLC v. Sotera Health Co.

Hunt may re-raise his statute of limitations argument in a motion for summary judgment, if this action progresses to that stage. But a motion to dismiss can only be granted on a statute of limitations argument if the plaintiff’s own complaint makes evident that her claim falls outside of the prescribed time period. Allen’s complaint …

2026-04-10 · United States District Court for the District of Oregon · 2021 WL 5397472 · provisional

The District of Oregon on 2026-04-10 granted the motions to dismiss, denied the motions to strike, allowed amendment, and warned that AI-generated legal authorities must be verified in Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao. The self-represented plaintiff filed a brief with four fabricated case citations, including Hernandez v. Cnty. of Yamhill.

com/watch? v=oqSYljRYDEM. PAGE 3 – ORDER it is advisable to use AI tools to conduct legal research or draft legal briefs will explain that any legal authorities or legal analysis generated by AI need to be verified. Plaintiff opposes both Alyssa Alao and Kelsey Alao’s motions on two grounds. First, Plaintiff argues, Defendants did not …

2026-04-10 · Florida District Court of Appeal, Sixth District · 2026 WL 785016 · provisional

The Florida District Court of Appeal, Sixth District on 2026-04-10 ordered counsel to show cause why sanctions or corrective action should not issue for the defective authorities in Bruno Roberto Rodriguez v. Kathryn Louise Rodriguez. Counsel filed a brief with one fabricated case citation and one mischaracterized case citation.

We recently addressed a similar scenario where a pro se litigant submitted a filing to this Court that cited to non-existent cases, as well as cited to actual cases which did not stand for the legal propositions asserted in the filing. See Hessert v. Hessert, No. 6D2026-0121, 2026 WL 785016 (Fla. 6th DCA Mar. 20, …

2026-04-09 · U.S. Bankruptcy Court for the Western District of Louisiana · provisional

On 2026-04-09, U.S. Bankruptcy Court for the Western District of Louisiana struck counsel’s objection and supplemental response, imposed a $2,750 sanction, ordered AI-focused CLE, and barred further filings until compliance. Counsel submitted a filing with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities, including In re Garcia and In re Buttermilk Towne LLC.

the underlying promissory note.” 2 Regardless of what Ms. Wilson may have intended by citing to In re Garcia, the Court finds that her failure to review and verify the AI-generated Objection caused her to file a false and misleading pleading in this Court. Ms. Wilson also acknowledges that her Supplemental Response (ECF # 67) …

2026-04-09 · U.S. District Court for the Northern District of Illinois · provisional

On 2026-04-09, U.S. District Court for the Northern District of Illinois struck the motion and imposed a $4,999 sanction for repeated AI-generated fake cases, quotations, and statements of law and fact. A self-represented party submitted a complaint with 13 false quotations and fabricated or nonexistent authorities, including Marshall v. Marshall and Andrade v. Arby Concessions.

such possibility. Plaintiff generated each brief using AI. Plaintiff’s motion is riddled with AI hallucinations, made up cases, quotes, and statements of law and fact. (Dkt. 90); (see also Dkt. 92-1) (identifying 13 hallucinated cases, quotes, and statements of law). For example, Plaintiff quotes Marshall v. Marshall, 547 U.S. 293 (2006) for the rule that …

2026-04-09 · Illinois Appellate Court, Third District · 2026 IL App (3d) 240628-U · provisional

On 2026-04-09, Illinois Appellate Court, Third District denied dismissal and striking of the appellate brief but awarded appellees $3,178 in attorney fees for responding to the AI-produced brief. A self-represented party submitted an appellate brief with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including In re Marriage of Lehr.

Robert to show cause as to why he Boy, 2025 IL App (4th) 241427, ¶ 57. Our supreme should not be sanctioned based on his violations of Illinois court's policy authorizes the use of AI when compliant Supreme Court rules and AI policy by citing nonexistent with legal and ethical standards. Ill. Sup. Ct., Illinois …

2026-04-08 · U.S. District Court for the Southern District of Florida · 2026 WL 943756 · provisional

On 2026-04-08, U.S. District Court for the Southern District of Florida recommended staying discovery and mediation pending two motions to dismiss. A self-represented party submitted a response brief with The response brief cited FSIA discovery authorities, including In re Clerici, for propositions those authorities did not support.

SOCIETE GENERALE DE..., Slip Copy (2026) The Court ends its analysis by noting that, in his Responses, IV. CONCLUSION Zoghaib cites to various cases for certain propositions that *7 For the reasons explained above, I respectfully do not support his arguments, leading the Court to suspect RECOMMEND that BdL's Motion to Stay, ECF No. [75] …

2026-04-08 · U.S. Bankruptcy Appellate Panel for the Eighth Circuit · provisional

On 2026-04-08, U.S. Bankruptcy Appellate Panel for the Eighth Circuit affirmed the bankruptcy court’s order limiting one debtor’s advocacy for the other and noted that several cited bankruptcy cases did not exist or support the argument. A self-represented party submitted a motion with fabricated or nonexistent authorities and mischaracterized authorities, including In re Cherrett and In re Pringle.

2012), was retrieved. The Swanson case begins on page 495 of volume 475 of the Bankruptcy Reporter and ends on page 535. The case concerns a Uniform Commercial Code issue, not the imposition of sanctions for discovery violations as argued by the Debtors in their brief. The citation for In re Cherrett, 873 F.3d 1060 …

2026-04-08 · U.S. District Court for the Northern District of Alabama · 2026 WL 948793 · provisional

On 2026-04-08, U.S. District Court for the Northern District of Alabama dismissed the case without prejudice after the plaintiff ignored orders to address Rule 11 concerns about nonexistent cases and fabricated quotations. A self-represented party submitted a complaint with at least one false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

Defendants Laura Burns, Autumn Caudell, and the Alabama intentional or in bad faith cannot be supported by the fact State Bar alleging constitutional and state law violations. that she was unaware that Ms. Burns brought these errors to (Doc. 1). Ms. Pleasant later filed multiple documents that the court's attention. After all, Ms. Pleasant's “inaccuracies …

2026-04-07 · Commonwealth Court of Pennsylvania · provisional

On 2026-04-07, Commonwealth Court of Pennsylvania affirmed the unemployment board and declined to consider the claimant’s recoupment argument because it relied on a nonexistent case and a misplaced statute. A self-represented party submitted a petition with fabricated or nonexistent authorities, including Beck v. Unemployment Comp. Bd. of Rev.

CHRISTINE FIZZANO CANNON, Judge Beck v. Unemployment Comp. Bd. of Rev. (Pa. Cmwlth., No. 459 C.D. 2013, filed September 11, 2013). This Court declines to consider Claimant’s final argument that the “Board’s decision to deduct from [Claimant’s] Social Security benefits to recover previously approved funds violates fundamental due process principles and conflicts with 43 P.S. …

2026-04-07 · U.S. District Court for the Western District of Oklahoma · provisional

On 2026-04-07, U.S. District Court for the Western District of Oklahoma denied the motion in limine and warned that the plaintiff’s mischaracterized treating-physician authorities implicated Rule 11. A self-represented party submitted a motion with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hall v. United States and Poppino v. Berryhill, an unrelated decision.

At a minimum, Plaintiff’s cited authority fails to demonstrate an entitlement to relief on the merits of her Motion. In addition, such mischaracterizations of case law, whether or not the product of generative artificial intelligence, implicate consideration of Plaintiff’s representations for purposes of Federal Rule of Civil Procedure 11(b) and (c). See Clark v. CoreCivic, …

2026-04-07 · U.S. District Court for the District of Nevada · 2026 WL 948233 · provisional

On 2026-04-07, U.S. District Court for the District of Nevada denied the discovery motions and warned the plaintiff that unchecked AI-generated or unsupported citations could expose her to Rule 11 sanctions. A self-represented party submitted a motion with The motion cited fabricated or mischaracterized discovery cases, including Cruz and DuPont authorities, for propositions the cases did not support.

is not an Motion; however, the Court finds such efforts would be futile attorney, offers arguments not germane to the issue of her and, thus, this failure is not a basis to deny Plaintiff's Motion. refusal to proceed with answering questions at her deposition, It is true that Defendants had previously filed a Motion to …

2026-04-07 · U.S. District Court for the Northern District of California · provisional

On 2026-04-07, U.S. District Court for the Northern District of California declined to sanction counsel after a corrected brief was filed, but warned all parties to verify the existence and accuracy of cited authorities. Counsel submitted an opposition brief with fabricated or nonexistent authorities.

of the bar of this Court to “comply with the standards of professional conduct required of members of the State Bar of California.” Civil L.R. 11-4(a)(1). Under California Rule of Professional Conduct 3.3, lawyers have a duty of candor, which prohibits a lawyer from “knowingly mak[ing] a false statement of fact or law to a …

2026-04-06 · Oregon Court of Appeals · provisional

On 2026-04-06, Oregon Court of Appeals dismissed the judicial-review petition after the petitioner failed to explain fabricated AI-sourced citations in her opening brief and show-cause response. A self-represented party submitted a petition with 10 fabricated or nonexistent authorities, including Ass’n v. Washington County, 309 Or App 112, 124-25, 482 P3d 827.

still failed to acknowledge the egregiousness of her conduct and, instead, continued to minimize it. Nothing in petitioner’s response to the show cause order demonstrates, even an attempt at, transparency. Petitioner continued to avoid explaining how any of the fabricated case citations came to be, despite the fact that they are clearly the type of …

2026-04-06 · U.S. District Court for the Southern District of New York · provisional

On 2026-04-06, U.S. District Court for the Southern District of New York admonished the self-represented defendant to verify that cited cases exist and support the propositions asserted in future AI-assisted filings. A self-represented party submitted a motion with false quotations and fabricated or nonexistent authorities, including In re SunEdison, Inc. Sec. Litig.

motion to dismiss for failure to state a claim. Nor was I able to locate the quoted text in any case available on Westlaw. I therefore conclude that the citation is an AI-generated hallucination. I understand the difficulties of litigating pro se and the reasons why a pro se litigant might choose to use AI- …

2026-04-06 · U.S. District Court for the District of Nevada · provisional

On 2026-04-06, U.S. District Court for the District of Nevada granted default judgment in part, denied paralegal costs, and warned the plaintiffs that fake AI-drafted cases may lead to sanctions. A self-represented party submitted a motion with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities.

in briefs, usually as the result of using generative AI software, like ChatGPT, to draft court filings. Johnson v. MINI of Las Vegas, No. 2:25-cv-00725-APG-EJY, 2025 WL 2718525, at *3 (D. Nev. Sept. 24, 2025). Generative AI often invents fake cases and legal precedent, and using it is no excuse to not verify the veracity …

2026-04-06 · U.S. District Court for the Eastern District of Michigan · provisional

On 2026-04-06, U.S. District Court for the Eastern District of Michigan struck the motion to consolidate and gave the plaintiff a final warning after he repeated fake quotations following an earlier AI-citation sanction order. A self-represented party submitted a motion with false quotations, including Berndt v. Tennessee does not appear in and United States v. Frazier does not appear in.

R&R explained, “Courts and opposing counsel are [ ] burdened by the careless use of AI by pro se filers.” Hardy v. Whitaker, ___ F.R.D. ___ 2026 WL 575225, at *10. Hardy apologized for his “inclusion of inaccurate citations generated by an AI tool” in his objections to the R&R. Case No. 24-cv-11270, ECF No. …

2026-04-06 · U.S. Judicial Panel on Multidistrict Litigation · provisional

On 2026-04-06, U.S. Judicial Panel on Multidistrict Litigation the Panel transferred the listed action to MDL No. 3014 and warned that unverified AI-generated fictional citations undermine truthful court filings. Counsel submitted a filing with mischaracterized authorities, including In re Xarelto and In re Bard IVC Filters.

Nathaniel M. Gorton Matthew F. Kennelly Roger T. Benitez Dale A. Kimball Madeline Cox Arleo See Reilly v. Connecticut Interlocal Risk Mgmt. Agency, No. 3:25-00640, 2025 WL 1726366, at *2 (D. Conn. June 20, 2025) (“Artificial intelligence is known to result in . . . fictional or hallucinatory citations . . . . [B]ecause artificial …

2026-04-06 · U.S. District Court for the Eastern District of California · provisional

On 2026-04-06, U.S. District Court for the Eastern District of California ordered counsel to show cause why sanctions should not issue for an opposition brief with nonexistent authority, fabricated quotations, and unsupported legal assertions. Counsel submitted an opposition brief with nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

Defendant County of Fresno’s Motion for a More Definite Statement. (ECF No. 12). It appears to the Court that Plaintiff’s brief (1) cited authority that does not exist; (2) fabricated quotes from authority that does exist; and (3) made material legal representations without supporting authority. Such issues suggest that Attorney Little relied on generative artificial …

2026-04-06 · U.S. District Court for the Central District of California · provisional

On 2026-04-06, U.S. District Court for the Central District of California dismissed the action for lack of subject-matter jurisdiction and admonished the plaintiff for false quotations and an apparently fake Ninth Circuit citation. A self-represented party submitted a filing with several false quotations and fabricated or nonexistent authorities, including Chicago v. International College of Surgeons and Co. v. Monsanto Co.

provides direct quotations to several cases. (Reply 6–7, Dkt. No. 14.) For example, Jordan provides this quote from City of Chicago v. International College of Surgeons, 522 U.S. 156, 172–73 (1997): “When the federal claim is eliminated early in the litigation, the district court must decline jurisdiction over the remaining state-law claims.”4 (Opp’n 6.) However, …

2026-04-03 · U.S. District Court for the Western District of Washington · provisional

On 2026-04-03, U.S. District Court for the Western District of Washington granted the arbitration-related relief and warned the plaintiff that further fictitious legal authority could produce an order to show cause for sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities and mischaracterized authorities.

was able to locate Gile v. Dolgen Cal., LLC, 2022 WL 17248087 (9th Cir. 2022)—but that case does not support Ward’s waiver claim. There, the Ninth Circuit found that a “motion to compel arbitration over eleven months after [Defendant] removed [the] case to federal court” amounted to waiver. 2022 WL 17248087, at *1. Such a …

2026-04-03 · Supreme Court of the State of New York · provisional

On 2026-04-03, Supreme Court of the State of New York held the plaintiff’s papers sanctionable as frivolous because they were riddled with fictitious cases and authorities that did not support the propositions asserted. Counsel submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Winston & Strawn LLP and Matter of Witham v Witham.

st Dept 2007]) ( on page 10). The memorandum again cites the fictitious case Matter of Winston & Strawn LLP (on page 11) and cites the fictitious case Edgeworth Food Corp. v Stephenson (53 NY2d 962 [1981]). 12 The memorandum again misrepresents the holdings in Fontanetta and David (on page 11 ), again cites the …

2026-04-03 · Supreme Court of the State of New York · 2026 WL 959797 · provisional

On 2026-04-03, Supreme Court of the State of New York denied the renewed post-judgment request and enforced its generative-AI certification rule after finding hallucinated citations throughout the self-represented filing. A self-represented party submitted a motion with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Sakow and Kruger v. Kruger, 107 AD3d 1285, 1287.

she AD3d 1285, 1287 [3d Dept. 2013], does not exist. Rather, the provides no reasonable justification for not presenting citation is for Matter of Blocker v. Fischer, 107 AD3d 1285 this "newly discovered" evidence on her prior motions. [3d Dept. 2013], which involves an Article 78 proceeding. First, Plaintiff's only explanation for not presenting the …

2026-04-03 · U.S. Bankruptcy Court for the District of Connecticut · provisional

On 2026-04-03, U.S. Bankruptcy Court for the District of Connecticut denied the debtor’s contract arguments and ordered counsel to show cause separately under Bankruptcy Rule 9011 for apparently false citations. Counsel submitted a motion with 7 false quotations. The response requirement preceded any sanction decision.

rejected any proposal that did not recognize him as the sole buyer of the Note. St.Germain blamed Daniel Malchman’s “eleventh hour tactic to get his wife and Russ named as co-assignees[,]” which St.Germain stated “kind of pissed me off[.]” 10 St.Germain, having initiated the Berkshire Bank transaction, unilaterally believed that he should own and control …

2026-04-03 · U.S. District Court for the Northern District of California · provisional

On 2026-04-03, U.S. District Court for the Northern District of California dismissed the ECOA claim with prejudice and prohibited the plaintiff from using artificial intelligence to assert legal arguments in future filings. A self-represented party submitted a complaint with multiple fabricated or nonexistent authorities and mischaracterized authorities.

his complaint, plaintiff cites case law that supposedly states that Wells Fargo’s “shifting Northern District of California explanations” for its actions support an inference of discriminatory intent and “contradictory underwriting determinations create a plausible inference of pretext.” (TAC ¶ 41.) Plaintiff—for the third time—cites to “cases” that do not exist. Plaintiff presumably used artificial intelligence …

2026-04-03 · U.S. District Court for the Central District of California · provisional

On 2026-04-03, U.S. District Court for the Central District of California granted the city defendants’ motion to dismiss and ordered counsel to file a declaration or show cause regarding the potentially hallucinated Mabee citation. Counsel submitted a filing with fabricated or nonexistent authorities, including Mabee v. County of Orange and Cochran v. City of Wichita.

v. Anderson, 50 Cal. 3d 205, 212 (1990). The privilege even extends to “any publication required or permitted by law in the course of a judicial proceeding to achieve the objects of the litigation, even though the publication is made outside the courtroom and no function of the court or its officers is involved.” Id. …

2026-04-03 · U.S. Court of Appeals for the Sixth Circuit · provisional

On 2026-04-03, U.S. Court of Appeals for the Sixth Circuit disqualified counsel, denied compensation for time served, locked the briefs, directed notice of the opinion, and referred counsel for discipline. Counsel submitted a brief with nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including United States v. Washington and United States v. Anthony.

even when new tools are sponsored by trusted legal technology providers. See Varun Magesh et al., Hallucination-Free? Assessing the Reliability of Leading AI Legal Research Tools, J. of Empirical Legal Stud. 9–16 (2025). No. 25-5623 United States v. Farris Page 5 Further, attorneys who choose to use artificial-intelligence tools must do so in a manner …

2026-04-02 · Texas Court of Appeals · provisional

On 2026-04-02, Texas Court of Appeals affirmed the judgment, denied costs, and admonished the self-represented appellant that the fabricated Anderson v. Hood authority was unacceptable. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities, including Anderson v. Hood.

his gross misrepresentations of the record and misstatements of the law are unacceptable,12 but On page eighteen of his appellate brief, Stanford cites to Anderson v. Hood, 472 S.W.3d 524, 529 (Tex. App.—Dallas 2015, no pet.). “Anderson v. Hood” is a fabricated case and appears to be a “hallucinated” authority generated from the use of …

2026-04-02 · U.S. District Court for the District of Arizona · provisional

On 2026-04-02, U.S. District Court for the District of Arizona denied the plaintiff’s pending motions and warned that further false citations, including AI hallucinations, may warrant sanctions. A self-represented party submitted a complaint with nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Gao v. United States and Miller v. United States.

Wash. Oct. 22, 2025). Second, courts have dismissed cases based on litigants filing “frivolous and duplicative motions [which] needlessly disrupted the litigation and burdened the court and opposing counsel.” See, e.g., Scott v. Cunningham, 516 F. App’x 672, 673 (9th Cir. 2013). Third, the Court will not tolerate any further “presentation of false citations, including …

2026-04-01 · Iowa Court of Appeals · 2026 WL 892837 · provisional

On 2026-04-01, Iowa Court of Appeals struck the fabricated-citation portions of the petition on appeal, declined to dismiss the appeal, and considered only arguments untainted by the false authorities. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities and mischaracterized authorities.

admitted that the case we believed to be our discretion, we elect a lesser sanction here. We strike hallucinated was in fact “non-existent” and her citation “d[id] the problematic portions of K.M.’s petition on appeal and not correspond to any Iowa appellate decision.” She also consider only the arguments we can discern without the taint …

2026-04-01 · U.S. District Court for the Northern District of Indiana · provisional

On 2026-04-01, U.S. District Court for the Northern District of Indiana imposed a $1,500 sanction on counsel and directed the clerk to send the sanction orders to the Rhode Island disciplinary authority. Counsel submitted a brief with mischaracterized authorities, including Animals v. NIH and FEC v. Akins.

Jackson v. Auto-Owners Ins. Co., No. 7-24-cv-136, 2025 WL 1932274, at *5 (M.D. Ga. July 14, 2025) (imposing a $1,000 fine for the submission of filings with hallucinated cases), and Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281, 2024 WL 4882651, at *3 (E.D. Tex. Nov. 25, 2024) (imposing $2,000 sanction on attorney who …

2026-04-01 · U.S. District Court for the Northern District of California · provisional

On 2026-04-01, U.S. District Court for the Northern District of California denied the preliminary-injunction motion and warned that future filings containing nonexistent cases may be stricken from the docket. A self-represented party submitted a motion with fabricated or nonexistent authorities, including In re Grand Jury Subpoena.

(Dkt. No. 29-2 at 13; Dkt. No. 31 at 9.) However, Apple confirmed that it is complying with its preservation duties in this lawsuit “notwithstanding any contractual right to delete materials.” (See Dkt. No. 29 at 15; Dkt. No. 29-5 at 7.) Apple’s preservation duties in this lawsuit would clearly prohibit deletion of Kafeel’s e-books, …

2026-04-01 · Arkansas Court of Appeals · 2026 Ark. App. 205 · provisional

On 2026-04-01, Arkansas Court of Appeals dismissed the appeal because the self-represented appellant’s brief was noncompliant and relied on fictitious authorities that prevented meaningful review. A self-represented party submitted an appellate brief with multiple fabricated or nonexistent authorities. The court resolved the merits while identifying the defective legal research.

mischaracterized. Fabricated citations—whether cites multiple cases that, upon review, do not exist. The created intentionally or through unverified use of artificial authorities relied on in support of his arguments are not found intelligence—waste judicial resources, delay resolution of in the Arkansas Reports, the South Western Reporter, or cases, and erode confidence in the judicial system. …

2026-03-31 · U.S. District Court for the Western District of Washington · provisional

On 2026-03-31, U.S. District Court for the Western District of Washington granted leave to amend only in part and ordered the plaintiff to show cause within seven days for continued citation of nonexistent authority. A self-represented party submitted a motion with fabricated or nonexistent authorities.

SAC are the same as the claims brought in her FAC, except that Plaintiff appears to seek to add an additional Defendant (WSRMP) to Counts Three and Five. Dkt. No. 96-3 at 36–46. Further, Plaintiff seeks to add 11 new claims (Counts Seven through Seventeen). Id. at 47–64. Plaintiff does not specify which claims are …

2026-03-31 · U.S. District Court for the Southern District of Ohio · provisional

On 2026-03-31, U.S. District Court for the Southern District of Ohio ordered counsel to explain how nonexistent citations and nonexistent quoted language entered Hunt’s briefing despite counsel’s denial that AI caused the errors. Counsel submitted a brief with The brief cited nonexistent cases and quoted language that the court could not find in any actual decision.

_ F.4th __, 2026 WL 710568, at *3 (6th Cir. Mar. 13, 2026) (citation omitted). Hunt’s briefing provided this Court with nonexistent case citations and purported to quote nonexistent case language; Hunt’s representation that artificial intelligence was not the cause of these errors is not an explanation sufficient to address how these errors actually happened. …

2026-03-31 · U.S. District Court for the Eastern District of New York · 2026 WL 522624 · provisional

On 2026-03-31, U.S. District Court for the Eastern District of New York recommended an adverse fee award after finding Rule 11 safe-harbor compliance and repeated nonexistent or misrepresented AI-generated authorities. A self-represented party submitted a complaint with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Ramirez v. Humala, 24-CV-242.

claims with prejudice. nonexistent legal authority or misrepresenting the import of legal authority resulting from a lack of effort to verify the content of AI-generated drafts is sanctionable. See, 1. Defendants Met Rule 11’s Procedural Requirements e.g., Ramirez v. Humala, 24-CV-242, 2025 WL 1384161, at *1 (E.D.N.Y. May 13, 2025) (listing cases addressing The undersigned …

2026-03-31 · U.S. District Court for the District of Nevada · provisional

On 2026-03-31, U.S. District Court for the District of Nevada dismissed the case with prejudice and imposed nominal monetary sanctions after finding fabricated authorities, factual misrepresentations, and bad faith. A self-represented party submitted a filing with false quotations and nonexistent or mischaracterized authorities, including Christian and Warren cases the court found did not contain the quoted language.

were accurate or the result of benign typographical errors while simultaneously citing to additional misrepresented or fabricated authorities. The Court is left to assume that Mr. Allen either himself fabricated authorities and lied to the Court by claiming the inaccuracies were the result of typos or clerical errors, or enlisted the assistance of AI, which …

2026-03-31 · U.S. District Court for the Eastern District of Missouri · provisional

On 2026-03-31, U.S. District Court for the Eastern District of Missouri ordered the plaintiff to show cause by April 17, 2026 why Rule 11 sanctions should not issue for nonexistent cases and mischaracterized authorities. A self-represented party submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Egelhoff v. Egelhoff and Wilkerson v. Wilkerson.

P. 11(b). “Every filing in a federal court that contains citations to phony case law amounts to a violation of Rule 11(b) of the Federal Rules of Civil Procedure.” Turnage, 2025 WL 3052638, at *3; see also Mills v. City of St. Louis, 2025 WL 3470293, at *1 (E.D. Mo. Dec. 3, 2025) (“Providing the …

2026-03-31 · Minnesota Court of Appeals · 2026 WL 905119 · provisional

On 2026-03-31, Minnesota Court of Appeals allowed the dismissal of the appellant’s action without prejudice to stand after rejecting his challenge to the AI-citation sanction. A self-represented party submitted a complaint with fabricated or nonexistent authorities. The court resolved the merits while identifying the defective legal research.

SPECIAL TERM ORDER1 409 (Minn. App. 1989), rev. denied (Minn. July 12, 1989). Jennifer L. Frisch Chief Judge Appellant contends that the March 5, 2026 order dismissing *1 BASED ON THE FILE, RECORD, AND appellant's action without prejudice affected appellant's PROCEEDINGS, AND FOR THE FOLLOWING substantial rights. Appellant notes that the dismissal was REASONS: “based …

2026-03-31 · U.S. District Court for the District of Kansas · provisional

On 2026-03-31, U.S. District Court for the District of Kansas denied the plaintiff’s review and default motions and warned that future fabricated or incorrect legal authority could bring sanctions or dismissal. A self-represented party submitted a filing with false quotations and fabricated or nonexistent authorities, including Clark v. City of Shawnee, Kansas, No. 21-2223-EFM.

from projects, derogatory questions and comments about plaintiff’s country of origin and hygiene, and disparaging comments about Martin Luther King, Jr. holiday weren’t severe or pervasive); Morris v. City of Colorado Springs, 666 F.3d 654, 665–69 (10th Cir. 2012) (affirming summary judgment because doctor flicking plaintiff on the head, throwing bloody heart tissue, and yelling …

2026-03-31 · U.S. District Court for the Southern District of Indiana · 2026 WL 994492 · provisional

On 2026-03-31, U.S. District Court for the Southern District of Indiana granted summary judgment to the defendant and warned the self-represented plaintiffs that their contract-voiding authorities were inaccurate. A self-represented party submitted a motion with nonexistent or misstated legal provisions and fabricated or nonexistent authorities, including Kramer v. Trans-Lux Corp., 24 F.3d 1001 and Indiana Code § 23-2-1-2.

opposing Defendant's summary judgment motion, so the Court need not address it. In support of their argument that the contract is void, Plaintiffs cite “Indiana Code § 23-2-1-2” and “Kramer v. Trans-Lux Corp., 24 F.3d 1001 (7th Cir. 1994)” for the proposition that transactions involving unregistered securities are void. (Docket No. 107 at ECF p. …

2026-03-31 · U.S. District Court for the Northern District of Illinois · 2026 WL 891866 · provisional

On 2026-03-31, U.S. District Court for the Northern District of Illinois denied the sanctions motion and dismissed nonparty Travelers-related defendants while noting the movant’s admitted AI use and repeated legal misstatements. A self-represented party submitted a complaint with The complaint and sanctions papers cited nonexistent or irrelevant Illinois insurance authorities while relying on admitted AI-drafted legal research.

the argument that Travelers claims, alleged failure to investigate, and reliance on allegedly Insurance Company does not exist as a legal entity. In fact, to false information does not meaningfully depart from a basic some extent, he appears to concede that it might not. 1 breach of contract claim. In the Court's view, such alleged …

2026-03-31 · U.S. District Court for the Central District of Illinois · provisional

On 2026-03-31, U.S. District Court for the Central District of Illinois resolved the motion to dismiss and warned counsel that further false quotations or unsupported legal authorities could trigger sanctions. Counsel submitted a complaint with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Rost v. Steamboat Springs RE-2 Sch. Dist and Busse v. Motorola, Inc.

true and construing all reasonable inferences in the plaintiff’s favor. Id. at 458. To state a claim for relief, a plaintiff need only provide a short and plain statement of the claim showing he is entitled to relief and giving defendants fair notice of the claims. Maddox v. Love, 655 F.3d 709, 718 (7th Cir. …

2026-03-31 · U.S. District Court for the District of Columbia · provisional

On 2026-03-31, U.S. District Court for the District of Columbia warned the plaintiffs after cataloging fake quotations, nonexistent cases, and misrepresented holdings that appeared to be AI-generated. A self-represented party submitted a filing with fake quotations, nonexistent cases, and misrepresented procedural rules in support of strike and response arguments.

id. at (citing a fake quotation from Thomas v. Patton, 939 So. 2d 139 (Fla. Dist. Ct. App. 2006)); id. (citing a case, Young v. District of Columbia, 752 F. Supp. 2d 1 (D.D.C. 2010), that does not exist); Pls.’ Mot. Strike Response at 3 (misrepresenting the effect of Fla. R. App. P. 9.110(b)); id. …

2026-03-31 · U.S. District Court for the District of Columbia · provisional

On 2026-03-31, U.S. District Court for the District of Columbia granted judgment to the employer and rejected the plaintiff’s filings after finding inaccurate citations and unsupported legal propositions. A self-represented party submitted a filing with nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

are the people of Sudan, Ethiopia, Somalia.” Id. at 156 (Nguedi Dep. 156:1–3). “[T]he people who built the pyramids in Africa” are “the true . . . Jews and me, because I’m the Second Coming of course.” Id. (Nguedi Dep. 156:3–7). Plaintiff further believes that “[t]he Jews that are at the Federal Reserve, they are …

2026-03-31 · Connecticut Superior Court · 2026 WL 948918 · provisional

On 2026-03-31, Connecticut Superior Court considered the special motion to dismiss without the AI-generated portions and required counsel to explain the use and extent of AI in the brief. Counsel submitted a complaint with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

MOHAMED HUSSAIN ET AL. the defendant has statutory right to file the special motion v. to dismiss, the court will consider the defendant's motion to MANSOOR QURAISHI ET AL. dismiss without the AI generated portions of the brief. See order at Docket Entry 123 for a list of the AI generated/ DOCKET NO. TTD-CV25-5019431-S hallucinated …

2026-03-31 · U.S. District Court for the District of Connecticut · provisional

On 2026-03-31, U.S. District Court for the District of Connecticut cautioned the self-represented defendant that severe AI-assisted misreadings of law could lead to sanctions under Rule 11. A self-represented party submitted a brief with fabricated or nonexistent authorities and mischaracterized authorities, including Tyler v. Tyler and Martin v. Hearst Corp.

334 F.3d 204, 206 (2d Cir. 2003) (per curiam); S. New Eng. Tel. Co. v. Glob. NAPs Inc., Given Defendant’s serious misreading of Tyler, the Court suspects she used artificial intelligence (“AI”) to draft at least that portion of her brief. The Court cautions Defendant that the use, without verification, of the accuracy of the …

2026-03-31 · U.S. District Court for the Central District of California · 2026 WL 931542 · provisional

On 2026-03-31, U.S. District Court for the Central District of California admonished counsel after finding a false statutory quotation and no supporting case, federal or state, for the quoted language. Counsel submitted an opposition brief with multiple nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Mata v. Avianca, Inc.

Compl. ¶¶ 13-20. Plaintiff's Opposition includes a quotation of purported language from § 845.4 (Opp. at 5); however, the court could not locate the quoted statutory language in § 845.4 or any other section of the California Government Code. Nor could the court find any case, federal or state, containing the quoted language. This suggests …

2026-03-31 · U.S. District Court for the District of Arizona · provisional

On 2026-03-31, U.S. District Court for the District of Arizona denied the emergency stay request and warned the self-represented movant that future inaccurate citations may expose him to sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities, including Ghadimi v. Ariz. Bank & Trust.

logical vehicle for seeking some of the categories of relief sought in the emergency stay request. provision of future inaccurate citations may expose them to sanctions. Ghadimi v. Ariz. Bank & Trust, 2025 WL 2928933, *4 (D. Ariz. 2025) (“Ghadimi is proceeding pro se but he still must follow the same rules of procedure that …

2026-03-31 · U.S. District Court for the District of Arizona · provisional

On 2026-03-31, U.S. District Court for the District of Arizona ordered cost reimbursement, remedial AI education, and notice measures after finding counsel’s filed motion contained fake cases and quotations. Counsel submitted a motion with The motion cited fake cases and quotations, including supposed Arizona privilege authorities, that looked real but did not exist as cited.

from an actual case” that “looks correct.” Francis & Jarral, supra, at 5-6; see also Hayes, 763 F. Supp. 3d at 1065 (“fictitious case citations created by generative AI tools” can “look[] like a real case with a case name”). Thus, Defendant’s adjustment of language in the filed motion, by noting that some of the …

2026-03-31 · Arizona Court of Appeals, Division One · provisional

On 2026-03-31, Arizona Court of Appeals, Division One affirmed and denied costs while noting that both self-represented appellate briefs contained hallucinated or unsupported citations. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities and mischaracterized authorities. The court resolved the merits while identifying the defective legal research.

argument because he has shown no error—neither cumulative nor singular. ¶15 It’s worth noting that though Father urges us to disregard Mother’s brief for failing to include citations to the record or legal authority as required by ARCAP 13, Father’s opening brief contained only minimal citations to the record, some of which were hallucinated, supra …

2026-03-31 · U.S. District Court for the Southern District of Alabama · provisional

On 2026-03-31, U.S. District Court for the Southern District of Alabama publicly reprimanded counsel, ordered payment of $55,597 in fees and costs, required notice in related cases, and referred the matter for discipline. Counsel submitted a filing with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

Avianca, Inc., 678 F. Supp.3d 443, 448 (S.D.N.Y. 2023). This concept is well known and is a longstanding principle in the practice of law. Yet, the improper use of generative AI is a problem that sadly is not going away despite the general knowledge in the legal community that AI can hallucinate and make up …

2026-03-31 · U.S. District Court for the Middle District of Alabama · provisional

On 2026-03-31, U.S. District Court for the Middle District of Alabama adopted the recommendation, dismissed claims, and noted that the plaintiff’s response and objections used nonexistent cases and false quotations. A self-represented party submitted a motion with false quotations and fabricated or nonexistent authorities, including Kidd v. Mando Am. Corp and Osorio v. Miami-Dade Cnty.

Cir.2013) (same). The Supreme Court progenitor in both cases, however, Swierkiewicz v. Sorema N.A., 534 U.S. 506, 122 S. Ct. 992, 152 L.Ed.2d 1 (2002), was overturned in [Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007),] As the Defendants point out, in his response to the motion to dismiss and his objections to the …

2026-03-30 · U.S. District Court for the Western District of Tennessee · provisional

On 2026-03-30, U.S. District Court for the Western District of Tennessee denied the appeal and warned that continued nonexistent, erroneous, or misrepresentative citations after admitted AI drafting could lead to sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities.

DENIED. Lastly, Appellee’s response raises its discovery that Page relied on three nonexistent, erroneous or misrepresentative case citations in his motion for summary reversal. (D.E. 20 at PageID 423 (citing D.E. 11 at PageID 345-46).) The Court’s research confirms Appellee’s report about these citations. In his affidavit, Page addresses these “citation errors,” after admitting that …

2026-03-30 · U.S. District Court for the Western District of Tennessee · provisional

On 2026-03-30, U.S. District Court for the Western District of Tennessee affirmed the magistrate judge’s order and warned that continued fabricated authority could result in dismissal without further warning. A self-represented party submitted a brief with multiple fabricated or nonexistent authorities.

routinely strike or disregard overlength briefs filed without leave” are fake ones. (See ECF No. 26 at PageID 272.) The cases either do not exist, or they exist but are not decisions from the courts Plaintiff cites. Nor do the cases stand for the proposition Plaintiff asserts. Judge Christoff exercised her discretion with marked restraint. …

2026-03-30 · U.S. District Court for the District of Oregon · provisional

On 2026-03-30, U.S. District Court for the District of Oregon declined to sanction the plaintiff for a single erroneous citation but warned that fabricated authority can lead to monetary sanctions, striking, or dismissal. A self-represented party submitted a brief with fabricated or nonexistent authorities, including Abbott v. Washington County.

pages 514-15. Neither Tyler nor O’Donnell have any relevance to the third-party beneficiary issue for which plaintiff cites “Abbot v. Washington County,” nor can the Court locate another relevant case by that name. Although the Court declines to sanction plaintiff for this single erroneous citation for an uncontroversial proposition, plaintiff is warned that inclusion of …

2026-03-30 · U.S. District Court for the District of Oregon · provisional

On 2026-03-30, U.S. District Court for the District of Oregon ordered screening conditions and warned that any further hallucinated legal citations would expose the plaintiff to sanctions or dismissal. A self-represented party submitted an appellate brief with The appellate brief attributed a quotation to a non-existent case and relied on that authority for a proposition not supported by real law.

case” and the only source on Westlaw that includes the quote that Fleck attributes to the non-existent case is Fleck’s response in this case. Cf. Whiting v. City of Athens, No. 24-5918, --- F.4th ---- , 2026 WL 710568, at *1, *3, *10-13 (6th Cir. Mar. 13, 2026) (sanctioning lawyers for submitting briefing that “cited …

2026-03-30 · U.S. District Court for the Western District of New York · provisional

On 2026-03-30, U.S. District Court for the Western District of New York struck the January 2026 filings and ordered the plaintiff to submit any future request to file additional papers as a motion. A self-represented party submitted a filing with fabricated or nonexistent authorities.

Under the policy, each instance of employee misconduct is assigned a level of accountability, up to and including termination, based on the severity of the conduct and/or where the employee is in the progressive discipline process. (Id.). The first level of accountability is a yellow disciplinary action (“DA1-Yellow”), followed by an orange disciplinary action (“DA2- …

2026-03-30 · U.S. District Court for the Southern District of New York · provisional

On 2026-03-30, U.S. District Court for the Southern District of New York dismissed the complaint and admonished counsel to verify quotations and authorities after finding nonexistent quotations and misstated precedent. Counsel submitted a complaint with The complaint quoted language from McEachin and Goel that the court found did not appear in those cases.

Mar. 31, 2023) (concluding 30-month gap too lengthy). In the Complaint, Plaintiff has not alleged when the comment pertaining to AAA Carting were made, or when the waste hauling bidding occurred. (See generally Compl.) Without allegations as to the timeline—when the comments might have been made years or even decades earlier—the Court cannot rely on …

2026-03-30 · U.S. District Court for the District of Massachusetts · provisional

On 2026-03-30, U.S. District Court for the District of Massachusetts dismissed the complaint. A self-represented party submitted an opposition brief with multiple fabricated or nonexistent authorities, including Mata v. Avianca, Inc., No. 22-cv-1461 and Allbaugh v. U. of Scranton, No. 3:24-CV-2237.

United States District Judge It is apparent to the Court that Plaintiff relied on generative AI in multiple instances to create his filings. [See e.g. ECF No. 8 at 4 (multiple instances where it appears the generative AI program is speaking directly to Plaintiff, using terms like “you” and “your” to refer to Plaintiff, and …

2026-03-30 · Indiana Court of Appeals · 2026 WL 860644 · provisional

On 2026-03-30, Indiana Court of Appeals reached the merits despite briefing defects and warned that the self-represented brief included an apparently hallucinated Indiana case. A self-represented party submitted a brief with fabricated or nonexistent authorities, including Pavan v. Smith. The warning applied to later filings in the same case.

“must treat a wife as a parent even if she did born in wedlock, while denying an equivalent presumption not provide an egg.” Id. In coming to this conclusion, it to parents in same-sex marriages. Because Ind. Code § found that sections 31-9-2-15, -16, and 31-14-7-1 worked 31-14-7-1(1) does that, its operation was properly enjoined.” …

2026-03-30 · U.S. District Court for the Northern District of Illinois · provisional

On 2026-03-30, U.S. District Court for the Northern District of Illinois ordered counsel to file a statement explaining the nonexistent quotations, the Engquist misstatement, and whether the same source caused other errors. Counsel submitted a response brief with two false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

Arlington Heights, 782 F.3d 911, 917 (7th Cir. 2015): “not every governmental activity that might incidentally prevent crime constitutes ‘police protection service’ within the meaning of section 4-102.’” Pl.’s Resp. Br. at 9. But this quote does not exist. This kind of totally made-up quotations might very well be hallucinated quotations from generative artificial intelligence. …

2026-03-30 · Supreme Court of Hawaiʻi · provisional

On 2026-03-30, Supreme Court of Hawaiʻi denied the mandamus petition and warned that non-existent or hallucinated citations in a family-court filing violate the reasonable-inquiry duty. A self-represented party submitted a petition with fabricated or nonexistent authorities and mischaracterized authorities, including State v. Burdett and State v. Masaniai, 63 Haw. 354, 628 P.2d 1018.

without merit, as the statute contains no language terminating jurisdiction in the manner asserted. The petition included four additional inaccurate citations, none of which supported the propositions for which they were cited. The petition’s reliance on non-existent or hallucinated case citations strongly suggests that portions of the filing were generated using artificial intelligence (AI). HFCR …

2026-03-30 · U.S. District Court for the District of Connecticut · provisional

On 2026-03-30, U.S. District Court for the District of Connecticut admonished the plaintiff that hallucinated citations and excessive exhibits waste judicial resources and undermine the validity of his filings. A self-represented party submitted a brief with The brief relied on hallucinated or irrelevant CUTPA authorities, including Hottle and Wyndham citations that did not support the propositions asserted.

to the undersigned, is a hallucinated case citation.6 Third, Hottle v. BDO Seidman, LLP, does not discuss CUTPA at all. 268 Conn. 694 (2004). Finally, F.T.C. v. Wyndham Worldwide Corp. is an out-of-circuit case entitled to nothing more than The Court takes this opportunity to address Plaintiff’s inclusion of hallucinated case citations and excessive inclusion …

2026-03-30 · U.S. Court of Appeals for the Seventh Circuit · provisional

On 2026-03-30, U.S. Court of Appeals for the Seventh Circuit admonished counsel for non-existent citations and a false quotation, but declined monetary sanctions because counsel accepted responsibility and showed contrition. Counsel submitted a brief with false quotations and fabricated or nonexistent authorities, including Jones v. Kankakee Cnty. Sheriff’s Dep’t and In re Nwaubani.

No. 25-2417 B This court recently acknowledged the promise and pitfalls of AI in pro se litigation. See Jones v. Kankakee Cnty. Sheriff’s Dep’t, 164 F.4th 967, 970 (7th Cir. 2026). Other courts have also grappled with the use of generative AI in briefing, referring to AI hallucinations and non-existent case citations as repeat offenders. …

2026-03-27 · Superior Court of New Jersey, Appellate Division · provisional

On 2026-03-27, Superior Court of New Jersey, Appellate Division affirmed in part, remanded for dismissal without prejudice, and imposed a $1,000 personal sanction on appellate counsel. Counsel submitted an appellate brief with The appellate brief cited four fabricated insurance cases that resembled real reporter citations but did not exist.

look like real cases as they are identified by a case name, a citation dismissal. Indeed, we do not know whether the proper to a reporter, the name of a district or appellate [*9] insurance company would have denied the claim as it court, and the year of the decision. But they are not real …

2026-03-27 · U.S. District Court for the Eastern District of Michigan · provisional

On 2026-03-27, U.S. District Court for the Eastern District of Michigan dismissed the claims and warned that factitious citations in the complaint and motion could be treated as AI-created hallucinations. A self-represented party submitted a complaint with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Williams v. City of Cleveland, No. 1:18-CV-2911 and Jensen v. Utah Cnty.

Court has noticed factitious citations in other filings by Plaintiff, such as the complaint. 4 The Court is concerned by these factitious citations, which may be created by generative artificial intelligence (“AI”) tools. See United States v. Hayes, 763 F. Supp. 3d 1054, 1065 (E.D. Cal. 2025). “It is no secret that generative AI programs …

2026-03-27 · U.S. District Court for the Eastern District of Michigan · provisional

On 2026-03-27, U.S. District Court for the Eastern District of Michigan warned the plaintiff that repeated false quotations and citations, including apparent AI hallucinations, would lead to sanctions for future violations. A self-represented party submitted an appellate brief with several false quotations and fabricated or nonexistent authorities, including People v. Swafford and People v. Kennedy.

final conviction and is presumed innocent while his appeal of right remains pending.” (E.g., ECF No. 31, PageID.620 (emphasis in original)). Because his appeal of right is still ongoing, Plaintiff contends that, as a matter of law, he has not been “convicted.” (Id.). In support, Plaintiff appears to quote several cases that, upon review, appear …

2026-03-26 · U.S. District Court for the District of Nevada · 2026 WL 837418 · provisional

On 2026-03-26, U.S. District Court for the District of Nevada granted amendment in part, denied the motion to dismiss as moot, and warned that fake AI-drafted cases must be verified. A self-represented party submitted a complaint with false quotations and fabricated or nonexistent authorities.

and as the result of using generative AI software, like ChatGPT, deny the motion to dismiss (ECF No. 6) as moot. to draft pleadings. Chavez-DeRemer v. NAB, LLC, No. 2:21- Wallace moves to amend and attaches a proposed second CV-00984-JAD-EJY, 2025 WL 2308676, at *3 (D. Nev. amended complaint. ECF No. 43-1. The defendants oppose, …

2026-03-26 · U.S. District Court for the District of New Jersey · provisional

On 2026-03-26, U.S. District Court for the District of New Jersey dismissed the patent claims without prejudice and required plaintiffs to provide PDFs and highlighted support for cited cases before amendment. A self-represented party submitted an opposition brief with multiple false quotations and fabricated or nonexistent authorities.

200, 209 (3d Cir. 2021). But plaintiffs will not be permitted to file an amended complaint without also meeting additional requirements. Rastelli Defendants have requested that the Court impose a filing injunction on plaintiffs or, in the alternative, prohibit plaintiffs from using artificial intelligence to prepare filings or require that plaintiffs include affidavits with their …

2026-03-26 · U.S. District Court for the Eastern District of North Carolina · provisional

On 2026-03-26, U.S. District Court for the Eastern District of North Carolina denied leave to amend because the proposed amended complaint’s additional fabricated citations showed bad faith and amendment would be futile. A self-represented party submitted a complaint with nonexistent or misstated legal provisions and fabricated or nonexistent authorities.

so requires. Fed. R. Civ. P. l 5(a). Leave to amend should only be denied where there is bad faith on the part of the moving party, the amended would be futile , or granting leave would prejudice the non-moving party. See Johnson v. Oroweat Foods Co., 785 F.2d 503 , 509 (4th Cir. 1986). …

2026-03-26 · U.S. District Court for the District of Minnesota · provisional

On 2026-03-26, U.S. District Court for the District of Minnesota rejected defendants’ heightened-injunction argument after identifying misquotations and miscites in their brief and receiving unsatisfactory explanations at the hearing. Counsel submitted a brief with false quotations. The remedy followed the citation failures in that filing.

the hold increased detainee time at Whipple; indeed, overcrowding has decreased since the TRO. (Ex. 346 (sealed); ECF No. 143 (“Simard Decl.”) ¶¶ 12–13, 15.) B. Locating Detainees Before the TRO, Defendants transferred people so quickly that even Defendants struggled to locate detainees. (Glenn Decl. ¶ 5 (“In two of my cases, for example, [the …

2026-03-26 · U.S. Government Accountability Office · provisional

On 2026-03-26, U.S. Government Accountability Office warned the protester that future filings with non-existent authority may result in sanctions after reviewing erroneous AI-like citations. Counsel submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities. The warning applied to later filings in the same case.

propositions asserted by MCPS, and non-existent decisions. See Electronic Protest Docketing System (Dkt.) No. 8, Response to Dismissal Request; Dkt. No. 12, Appendix A, GAO Decisions Cited. MCPS’ erroneous citations bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) without adequate verification that the generated results were accurate. See …

2026-03-26 · U.S. District Court for the Northern District of Alabama · provisional

On 2026-03-26, U.S. District Court for the Northern District of Alabama publicly reprimanded counsel and ordered notice of the reprimand after counsel admitted ChatGPT and OpenCase produced made-up quotations. Counsel submitted a filing with false quotations and fabricated or nonexistent authorities, including Co. v. Houston National Bank and Whelan v. Abell.

the final version did, in fact, exist. Transcript of Show-Cause Hearing at 21–22 (March 26, 2026). Mr. May confirmed that the quotations were hallucinations of one or both of two popular generative artificial intelligence (“AI”) applications used by Mr. May—ChatGPT and OpenCase. (Doc. 69 at 2). In simpler terms, the quotes Mr. May cited were …

2026-03-25 · U.S. District Court for the Northern District of Ohio · provisional

On 2026-03-25, U.S. District Court for the Northern District of Ohio dismissed the case with prejudice and treated the repeated fake cases in successive filings as a factor supporting dismissal. A self-represented party submitted an opposition brief with fabricated or nonexistent authorities.

conference, was not in compliance with the Court’s standing order regarding discovery and sanction motions, Doc. 36. Lu then filed, in opposition to Capital One’s dismissal motion, a brief which contained numerous fake cases and other troubling citation inconsistencies. Doc. 39. After Capital One pointed this out, Doc. 41, at 2, Lu submitted another filing …

2026-03-25 · U.S. District Court for the Southern District of New York · provisional

On 2026-03-25, U.S. District Court for the Southern District of New York imposed Rule 11 sanctions for repeated arguments that included fictitious statutory language and false legal support. A self-represented party submitted a complaint with one nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Conroy v. Aniskoff.

National also requests sanctions on several different bases that essentially boil down to the following: Plaintiff has repeatedly made, without complying with the Court’s Individual Rules, seriatim filings that assert the same meritless arguments. (Dkt. No. 94 at 24– 27.) He persisted in doing so even after Safety National directed him to binding authority that …

2026-03-25 · Florida Fourth District Court of Appeal · provisional

On 2026-03-25, Florida Fourth District Court of Appeal cautioned the self-represented appellant, in prose and a limerick, that future briefs with nonexistent cases may invite sanctions. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities and mischaracterized authorities, including In re Kenney, 2025-0389.

• AI Spotted There once was a litigant pro se, Who let an AI lead the way. It briefed every claim, Cited cases—by name, That vanished by morning’s next day. Limerick on Pro Se Parties Using Artificial Intelligence (on file with the Fourth District Court of Appeal) (generated by ChatGPT 5.2). It appears to us …

2026-03-25 · U.S. District Court for the Central District of California · 2026 WL 851435 · provisional

On 2026-03-25, U.S. District Court for the Central District of California denied the motion for discovery sanctions and advised that false citations in future briefs may result in sanctions. A self-represented party submitted a complaint with The complaint cited a nonexistent Plantronics decision while seeking discovery sanctions.

apply. properly served with process. See Fed. R. Civ. P. 4(b), (c) (1). Absent such service, the Court lacks personal jurisdiction over Defendants and Plaintiff may not seek sanctions against *2 Courts may deny discovery motions for failure to comply such unserved parties. with the Local Rules' requirements for such motions. See Pina v. Lewis, …

2026-03-25 · U.S. District Court for the Middle District of Alabama · provisional

On 2026-03-25, U.S. District Court for the Middle District of Alabama dismissed the complaint without prejudice and warned that hallucinated citations and shotgun pleading defects did not state a claim. A self-represented party submitted a complaint with fabricated or nonexistent authorities, including Lipham v. General Motors LLC and Zinnerman v. Williams.

Complaint such as “Lipham v. General Motors LLC, 665 F.3d 1314 (11th Cir. 2011),” “Zinnerman v. Williams, 749 So. 2d 453 (Ala. Civ. App. 1999),” and “FTC v. Sage Auto Group, No. 16-cv-07329 (C.D. Cal. 2016)” that do not appear to exist and therefore appear to be hallucinated. The hallucinated case citations and overall nature …

2026-03-24 · U.S. District Court for the Southern District of Florida · provisional

On 2026-03-24, U.S. District Court for the Southern District of Florida recommended dismissal without prejudice and admonishment after finding that the plaintiff’s quotations and legal concepts were AI-hallucinated. A self-represented party submitted an opposition brief with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

Response in opposition to all of Defendants’ arguments. As noted in Defendants’ Reply, Plaintiff has cited in large part to artificial intelligence (“AI”)-hallucinated law. While the cases Plaintiff relies on do exist, the quotations, and even most of the legal concepts, are fake. Plaintiff filed a Notice of Spoliation in which he apologizes to the …

2026-03-24 · U.S. Court of Appeals for the Tenth Circuit · provisional

On 2026-03-24, U.S. Court of Appeals for the Tenth Circuit affirmed dismissal and warned that further failure to check cited authority before filing could result in sanctions. A self-represented party submitted a reply brief with several false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Burton v. Ghosh and Iseminger v. Dist. Ct.

any relevance to the argument Biglow attributes to the corresponding nonexistent case is Bentley, which states that “[f]ailure to plead an affirmative defense results in a waiver of that defense,” 41 F.3d at 604. There are similar fabrications in three of Biglow’s motions and in his reply briefs in support of all four motions. 10 …

2026-03-24 · U.S. District Court for the District of Arizona · provisional

On 2026-03-24, U.S. District Court for the District of Arizona ordered plaintiffs’ counsel to show cause why sanctions should not be imposed for citing a nonexistent Arizona RICO limitations case. Counsel submitted a motion with fabricated or nonexistent authorities, including Barker v. Brown & Brown, 210 Ariz. 321, 110 P.3d 1011.

(Doc. 26 at 20.) This case does not exist. Additionally, the proposition for which it is cited is also incorrect: the four-year period established by Agency Holding Corp., 483 U.S. 143 (1987), applies to federal civil RICO claims only. Arizona’s private RICO action is governed by the three-year period set forth in A.R.S. § 13-2314.04(F). …

2026-03-23 · U.S. District Court for the District of Utah · provisional

On 2026-03-23, U.S. District Court for the District of Utah required AI-related CLE and payment of $1,525.50 already agreed to reimburse fees for two nonexistent cases and a nonexistent quotation. Counsel submitted a brief with two false quotations and fabricated or nonexistent authorities.

on an Order to Show Cause1 after Defendants’ counsel discovered two non-existent cases and one non-existent quote cited in Plaintiffs’ briefing. Prior to hearing, the Court also ordered Defendants’ counsel to provide an estimate of the legal expenses incurred in responding to the Order to Show Cause. Defendants’ counsel informed the Court that, after initially …

2026-03-23 · U.S. District Court for the District of Oregon · provisional

On 2026-03-23, U.S. District Court for the District of Oregon declined sanctions because defendants did not request them, but warned that the plaintiffs’ false citations appeared to be unverified AI hallucinations. A self-represented party submitted an appellate brief with multiple fabricated or nonexistent authorities, including Campbell v. MERS and Tucker v. HSBC.

Plaintiffs cite to “Schweitzer v. FHLMC, No. 3:13-cv-0181, 2013 WL 4279629 (D. Or. Aug. 29, 2013)” on pages 11 and 34 of the SAC. Once again, no such case exists and the case number Plaintiffs provide is for a Social Security appeal. Presenting false citations is a grave matter and suggests an intention to mislead …

2026-03-23 · U.S. District Court for the Eastern District of Michigan · provisional

On 2026-03-23, U.S. District Court for the Eastern District of Michigan granted summary judgment in part and ordered plaintiffs’ counsel’s firm to reimburse the defense costs of researching the hallucinated case. Counsel submitted a brief with multiple fabricated or nonexistent authorities, including Doe v. Univ. of Mich., No. 18-11914.

63, PageID.783. Plaintiff’s response is that they did not use AI to complete their briefing; instead, the Frankenstein citation appears to result from multiple case citations inadvertently being combined during efforts to condense their brief. ECF No. 66, PageID.984. The Court notes that it, too, could not find the case, Doe v. Univ. of Michigan, …

2026-03-23 · U.S. District Court for the Eastern District of Michigan · 2026 WL 801202 · provisional

On 2026-03-23, U.S. District Court for the Eastern District of Michigan struck the motion and issued a final sanctions warning after the plaintiff repeated fake quotations previously attributed to AI use. A self-represented party submitted a motion with false quotations, including Berndt v. Tennessee and United States v. Frazier.

R&R). The R&R explained, “Courts and opposing counsel Gregory Hardy, Flint, MI, Pro Se. are [ ] burdened by the careless use of AI by pro se filers.” Hardy v. Whitaker, ___ F.R.D. ___ 2026 WL 575225, at *10. Bennet J. Bush, Genesee County Corporation Counsel, Flint, Hardy apologized for his “inclusion of inaccurate citations …

2026-03-23 · Armed Services Board of Contract Appeals · provisional

On 2026-03-23, Armed Services Board of Contract Appeals the Board granted dismissal and warned the self-represented contractor that future citations to non-existent authority may lead to sanctions. A self-represented party submitted a brief with fabricated or nonexistent authorities and mischaracterized authorities, including LLC v. United States and Corp. v. United States.

– have a tendency to hallucinate non-existent cases. Sanders v. United States, 176 Fed. Cl. 163, 169 (2025) (“It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited …

2026-03-20 · U.S. District Court for the Eastern District of Louisiana · 2026 WL 787563 · provisional

On 2026-03-20, U.S. District Court for the Eastern District of Louisiana personally sanctioned counsel $1,250 and formally admonished him after he admitted using ChatGPT without checking nine hallucinated cases. Counsel submitted a brief with The brief cited nine hallucinated cases generated through ChatGPT that counsel admitted he had not checked.

problem of attorneys’ improper use of A.I. cases on Westlaw but admitted that he eventually resorted to ChatGPT. Mr. Harris took full responsibility for his misuse Both Mr. St. Raymond and City Attorney Gipson outlined of generative A.I. and conceded that he did not check the the actions the City Attorney's Office has taken to …

2026-03-20 · Kentucky Court of Appeals · 2026 WL 784501 · provisional

On 2026-03-20, Kentucky Court of Appeals struck the appellant’s brief and allowed refiling after repeated hallucinated precedent and deficient AI certifications. A self-represented party submitted an appellate brief with nine false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Co. v. Thompson, 11.

principles. [Goodyear Tire & Rubber Co. v. Thompson, 11 to dismiss the appeal as Blair's latest brief again contained S.W.3d 575, 581 (Ky. 2000).] hallucinated precedent. Blair responded by admitting her brief contained one hallucinated case that was “erroneously ... repeated.” In an abundance of grace, this Court denied the HOA's motion to dismiss. Even …

2026-03-20 · Florida Sixth District Court of Appeal · 2026 WL 785016 · provisional

On 2026-03-20, Florida Sixth District Court of Appeal ordered the petitioner to show cause why sanctions should not issue for a petition with nonexistent cases and inaccurate legal propositions. A self-represented party submitted a petition with fabricated or nonexistent authorities and mischaracterized authorities.

--- So.3d ----, 2026 WL 785016 Footnotes “Generative AI[—i.e., generative artificial intelligence—]are deep-learning models that compile data to generate statistically probable outputs when prompted.... Generative AI can create original images, analyze documents, and draft briefs based on written prompts. Often, these programs rely on large language models. The datasets utilized by generative AI large language …

2026-03-19 · Utah Court of Appeals · 2026 WL 787382 · provisional

On 2026-03-19, Utah Court of Appeals reversed and remanded for a new trial while criticizing counsel’s incorrect Utah citations, misquotations, and authorities made out of whole cloth. Counsel submitted an appellate brief with seven fabricated or nonexistent authorities and mischaracterized authorities.

to support his propositions. Of these six citations, four are incorrect for various reasons (e.g., the cited material has nothing to do with the proposition for which the case is cited, the case name is incorrect, or the cited paragraph does not exist). (3) In the argument section, which is just over four pages long, …

2026-03-19 · Oregon Land Use Board of Appeals · provisional

On 2026-03-19, Oregon Land Use Board of Appeals struck the petition for judicial review after concluding that fabricated authorities permeated the assignments of error and consumed tribunal resources. A self-represented party submitted an appellate brief with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities.

of law. When a party submits briefs based on invalid authorities, that party engages in conduct that jeopardizes the integrity of the LUBA appeal process. Regardless of who submits fabricated citations, or whether they originate from the use of artificial intelligence or otherwise, such citations strain LUBA's and the parties' limited resources. Ringo, 345 Or …

2026-03-19 · U.S. District Court for the Eastern District of Oklahoma · provisional

On 2026-03-19, U.S. District Court for the Eastern District of Oklahoma denied the plaintiff’s sanctions motion but imposed a $500 sanction for citing fictitious or inaccurate authorities generated through AI research. A self-represented party submitted a motion with two false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Hill v. Oklahoma and Wadsworth v. Walmart.

AI in legal representation has increased, so have incidences of fictitious or inaccurate citations resulting from such AI tools. Presentation of inaccurate authorities in pleadings resulting from AI subject to the signing party to sanctions. See, e.g., Hill v. Oklahoma, 2025 WL 1840659, at *4 (W.D. Okla. July 3, 2025) (“[C]ourts have increasingly found the …

2026-03-19 · Supreme Court of the State of New York · 2026 WL 880831 · provisional

On 2026-03-19, Supreme Court of the State of New York scheduled a sanctions hearing after finding that the moving papers relied on a nonexistent Second Department case. Counsel submitted a filing with fabricated or nonexistent authorities, including Parrelli v. Temple Beth El of Great Neck.

construction management agreement (CMA at § 1.48). Furthermore, Alma Hot, project manager for M&R, testified that Shorewood was the owner's “rep” (Hot EBT at 11). In light of the uncontroverted evidence, Shorewood's arguments are unavailing. In its moving papers, Shorewood relies on the following purported authority: “Parrelli v. Temple Beth El of Great Neck, 304 …

2026-03-19 · U.S. District Court for the Southern District of Indiana · 2026 WL 772373 · provisional

On 2026-03-19, U.S. District Court for the Southern District of Indiana warned that future filings with nonexistent cases or unsupported authorities would result in Rule 11 sanctions. A self-represented party submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Knakmuhs v. Minneapolis Pub. Sch and Cooper v. Tokyo Elec. Power Co.

stating that Ms. James would not receive in the U.S. Navy. Id. at 656. The Seventh Circuit held that accommodations on the COMAT exam because NBOME "[plaintiff's] marred record is a continuing harm for which denied her testing accommodations. Dkt. 98-2 at 9. This he [could] seek redress." Id. at 666. On remand, the district …

2026-03-19 · U.S. District Court for the Northern District of Illinois · provisional

On 2026-03-19, U.S. District Court for the Northern District of Illinois dismissed the case with prejudice, struck the AI-generated response brief, and ordered counsel to pay defense fees and costs. Counsel submitted a response brief with fabricated or nonexistent authorities.

10. 4. Reliance on AI-Generated Case Citations Defendant moved to dismiss at R. 21 and Plaintiff’s counsel responded at R. 32. Defendant then moved to strike at R. 35 on the basis that Plaintiff’s counsel’s response brief was generated by artificial intelligence and cited fake cases. At R. 38, Plaintiff’s counsel admitted that he relied …

2026-03-19 · U.S. Bankruptcy Court for the District of Colorado · 2026 WL 787397 · provisional

On 2026-03-19, U.S. Bankruptcy Court for the District of Colorado dismissed the debtor’s counterclaims with leave to amend and warned that nonexistent AI-hallucinated citations did not save deficient pleading. A self-represented party submitted a complaint with several false quotations and fabricated or nonexistent authorities, including Gullickson v. Brown.

for declaratory judgment is duplicative of his defenses to Keirton Inc. Plaintiff, Keirton's § 727(a)(4) claim.3 Keirton also asserts that several v. of Rahmanovic's case citations do not exist and are the result Mersad Rahmanovic Defendant. of A.I. hallucinations. In response, Rahmanovic asserts that he sufficiently pled both claims and that even if his citations …

2026-03-19 · California Court of Appeal, First District · 2026 WL 776268 · provisional

On 2026-03-19, California Court of Appeal, First District reversed the child-support order but declined monetary sanctions after the self-represented respondent admitted AI-caused fake citations and quotations. A self-represented party submitted an appellate brief with two false quotations and fabricated or nonexistent authorities, including In re Marriage of Thomson and Keitel v. Heubel, supra.

Panas cited at least two cases 1119 [“ ‘Honesty in dealing with the courts is of paramount that do not exist: “In re Marriage of Thomson (1984) 157 importance, and misleading a judge is, regardless of motives, Cal.App.3d 568, 578” and “Marriage of Mendlowitz (2019) a serious offense’ ”].) We further caution that our redress …

2026-03-18 · North Carolina Court of Appeals · 2026 WL 762385 · provisional

On 2026-03-18, North Carolina Court of Appeals affirmed the surplus-funds ruling and chastised counsel for relying on Perplexity.AI material without adequately checking irrelevant authorities. Counsel submitted a motion with fabricated or nonexistent authorities, including Benjamin v. Costco Wholesale Corp. The court resolved the merits while identifying the defective legal research.

prescribed by statute”); N.C.G.S. § 45-21.32(a) (a surplus-funds proceeding is a special proceeding). Respondents’ speculation on the alleged “impact” of this matter on mechanics’ liens, as well as their inapplicable FDCPA claim, strongly resemble similar arguments in a record filing titled “Perplexity.AI Answers,” attached as an exhibit to Respondents’ “Motion for New Trial / Amendment …

2026-03-18 · Florida Fourth District Court of Appeal · 2026 WL 758289 · provisional

On 2026-03-18, Florida Fourth District Court of Appeal affirmed and cautioned the appellant that future briefs with nonexistent authorities may result in sanctions. A self-represented party submitted a motion with multiple fabricated or nonexistent authorities, including Friend v. Serpa and Phadael v. Deutsche Bank Tr. Co. Ams., 83 So. 3d 893, 895.

[March 18, 2026] intelligence to assist in these submissions must ensure their Appeal from the County Court for the Seventeenth Judicial accuracy.” Friend v. Serpa, 425 So. 3d 51, 51 (Fla. 4th DCA Circuit, Broward County; Michele McCaul Ricca, Judge; L.T. 2025) (cautioning the pro se litigant about sanctions for citing Case No. COCE22-048202. “phantom …

2026-03-17 · U.S. District Court for the Western District of Washington · 2026 WL 747745 · provisional

On 2026-03-17, U.S. District Court for the Western District of Washington granted the motion to dismiss claims against one defendant and warned counsel that another fictitious authority would trigger a sanctions show-cause order. Counsel submitted a motion with fabricated or nonexistent authorities, including Allen v. Bayshore Mall.

(1). In Washington, a corporation (or “represented entity,” SARAH and REGINA ALONSO, Plaintiffs, v. JAMES JACKSON,..., Slip Copy (2026) to show cause relating to use of fictitious legal authority do not request any relief in connection with this potentially generated by AI). fake case. Whether or not generative AI was used, “[c]iting nonexistent case law …

2026-03-17 · Washington Court of Appeals, Division III · 2026 WL 746700 · provisional

On 2026-03-17, Washington Court of Appeals, Division III affirmed dismissal and warned self-represented appellants that cases cited for convenient propositions must be real and supportive. A self-represented party submitted an appellate brief with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 and Osborn v. Mason County.

Freedom of Information Act, 5 U.S.C. § 552. The Richmonds do not argue that the trial court erred in dismissing their intentional infliction of emotional distress or their Consumer Protection Act claims. The Richmonds likely used AI for their briefing. AI is notorious for fabricating opinions and/or quotes. Here, the Richmonds cited an actual opinion, …

2026-03-17 · U.S. District Court for the District of Kansas · provisional

On 2026-03-17, U.S. District Court for the District of Kansas dismissed the claims and recounted the magistrate judge’s fourth warning against inaccurate or nonexistent case citations. A self-represented party submitted a motion with fabricated or nonexistent authorities and mischaracterized authorities, including Levy v. Kan. Dep’t of Soc. & Rehab. Servs and Williams v. Utah Dep’t of Corrs.

Fed. R. Civ. P. 8; and (6) the claims are time-barred. The Court will only address Defendants’ first three arguments as they are dispositive. Because the first three arguments all relate to each other, the Court will discuss them in tandem. 1. Whether Eleventh Amendment Immunity Bars Plaintiffs’ Claims against the State and its Officials …

2026-03-17 · U.S. Court of Appeals for the Fifth Circuit · provisional

On 2026-03-17, U.S. Court of Appeals for the Fifth Circuit affirmed dismissal and warned that further failure to check cited authority before filing could lead to sanctions. A self-represented party submitted an opposition brief with multiple fabricated or nonexistent authorities, including Cervantes v. New Century Mortg. Corp.

is void for failure to record the transfer in county property records, vitiating his indebtedness. However, he relies heavily on AI- hallucinated case law, and his theory finds no support in our actual case law. 2 Further failure to check the accuracy of cited authority before filing with the Court may result in sanctions. 3 …

2026-03-16 · Court of Appeals of Washington, Division One · 2026 WL 734359 · provisional

Washington Court of Appeals, Division One on 2026-03-16 in Esterra Commons Venture, LLC dba Verde Esterra Park v. Justin Norton found the self-represented party's appellate brief contained four 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.

1 Appearing pro se, Norton quotes fictitious statutory language, cites to inapplicable statutes, and relies on cases that do not exist. In the event that such fake and non-existent legal authority was generated by artificial intelligence (AI), we note this as an acknowledgment and a warning. While AI may be of assistance to parties, especially …

2026-03-16 · U.S. District Court for the Middle District of Pennsylvania · provisional

On 2026-03-16, U.S. District Court for the Middle District of Pennsylvania dismissed the habeas petition without prejudice and cautioned that AI programs can hallucinate fake cases that do not support jurisdiction. A self-represented party submitted a petition with fabricated or nonexistent authorities and mischaracterized authorities, including Santos v. Warden Allenwood FCI, No. 1:17-CV-02116 and London v. Pettit.

irrelevant to the present dispute. Beato-Estrella is cautioned that not all resources are created equal. For example, AI programs have been known to hallucinate, or create fake cases, in response to a user’s query. Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341, 342 (E.D.N.Y. 2025). The court understands legal research is difficult for …

2026-03-16 · United States District Court for the District of New Jersey · 2026 WL 735250 · provisional

District of New Jersey on 2026-03-16 in Shaquan Pridgen v. Amazon.com Services LLC found the self-represented party's opposition cited Lewis v. City of Trenton, 2020 WL 6204330, a case the court found did not exist. The court warned the self-represented party to disclose AI use when required and to verify future citations.

12 Pridgen nevertheless argues that “[c]ourts routinely permit pro se plaintiffs to plead class claims ....” MTD Opp'n at 7. Pridgen cites “Lewis v. City of Trenton, 2020 WL 6204330” for this proposition. Id. The case Pridgen cites, however, does not exist. This Court does not tolerate hallucinated citations. Litigants who use generative artificial intelligence …

2026-03-16 · United States District Court for the Central District of California · provisional

Central District of California on 2026-03-16 found the self-represented party's brief contained three citation defects, including Jorgensen v. CBS, Inc., 728 F.2d 958 (8th Cir. 1984), Lamon v. Godbolt, 2015 WL 13647670 (C.D..... The court denied the stay motion, granted CBS's motion to dismiss without leave to amend, and terminated the case.

(denying leave to amend where it “would unduly prolong resolution of this protracted litigation, and it would unduly prejudice Defendants by forcing them to continue to defend against meritless claims”). Plaintiff’s submissions in this case may have been prepared by using generative artificial intelligence. Plaintiff’s filings have misrepresented the Works at issue here and have …

2026-03-13 · Superior Court of Pennsylvania · 2026 WL 711256 · provisional

Superior Court of Pennsylvania on 2026-03-13 in A.C. Appellant v. H.D. AND J.C. found the self-represented party's appellate brief contained three citation defects, including Commonwealth v. Lyons, involving nonexistent authorities, mischaracterized authority. The court affirmed the order dismissing the custody petition with prejudice and did not rely on the defective authorities.

day deadline; the current version, effective since October 1, 2020, does not. Compare Pa.R.C.P. 1915.5(a) (current version), with Pa.R.C.P. 1915.5(a) (prior version effective until Sept. 30, 2020). 6 Based upon our review of Stepmother's brief and the cases cited therein, we suspect she used generative artificial intelligence in drafting it. See Saber v. Navy Federal …

2026-03-13 · United States District Court for the District of Nevada · provisional

District of Nevada on 2026-03-13 in Albert Taylor v. Las Vegas Metropolitan Police Department, et al. found the self-represented party's opposition used hallucinogenic citations to nonexistent cases while opposing dismissal motions. The court warned the self-represented party to verify legal authorities before future filings.

19 / / / / 20 / / / / 21 22 5 Taylor opposes this motion with hallucinogenic citations to non-existent cases. To the extent Taylor has relied on artificial intelligence to write his papers, I caution him that it is his 23 responsibility to check his case citations to ensure they are accurate …

2026-03-13 · Armed Services Board of Contract Appeals · provisional

Armed Services Board of Contract Appeals on 2026-03-13 in DSME Construction Co., Ltd. found counsel's surreply contained five citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court struck the defective filing and warned counsel to verify cited authorities before filing again.

2 Adding these concededly erroneous case citations to the 30 false case citations and four fictitious [Federal Acquisition Regulation] cites that appellant included in its Rule 11 Surreply, to date appellant has admitted to including 39 total cites across these three briefs that cite to cases that do not exist. 9 In response, on March …

2026-03-12 · United States District Court for the Western District of Virginia · provisional

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.

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 …

2026-03-12 · United States District Court for the Northern District of Texas · provisional

Northern District of Texas on 2026-03-12 in Hartmann v. Davidson found the self-represented party's brief contained one citation defect involving incorrect statutory or rule text. The court dismissed claims or denied relief after identifying the defective authorities in the challenged filing before resolving the pending matter.

2 The inaccuracies in Hartmann’s brief are typical of unverified, AI-generated filings, which have become an increasing concern for courts in recent years. While no federal or local rule explicitly prohibits the use of artificial intelligence in litigation, and Hartmann disclosed his use of generative AI in preparing his brief, see Pl.’s Resp. at 1 …

2026-03-12 · Rhode Island Superior Court · 2026 WL 771127 · provisional

Rhode Island Superior Court on 2026-03-12 found counsel's appellate brief contained two citation defects, including Smithfield v. Fanning and Duffy v. Milder, involving nonexistent authorities, fabricated or misattributed quotations. The court remanded the zoning appeal to the board for a continued public hearing and cautioned counsel about likely AI-generated citations.

have made clear that public comment should have been allowed, at least on the new evidence. 2 Although the Court does not address these arguments, it observes with great concern that Appellant's briefing on the definition of an “accessory” includes quotations of nonexistent law. Appellant cites two Rhode Island Supreme Court cases in support of …

2026-03-11 · United States District Court for the Western District of Oklahoma · provisional

Western District of Oklahoma on 2026-03-11 in Dillon v. Myles Stephenson, et al. found counsel's brief contained three citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court admonished counsel to verify cited authorities and avoid repeating the citation defects.

subsequently directed counsel for the Plaintiffs and School District to state “whether or not they used generative AI in connection with their filings in the action.” Order [Doc. No. 14] at 3. The Court also referenced the Court’s Chambers Rules regarding the use of generative AI. Id. at 2. Plaintiffs’ counsel represented to the Court …

2026-03-11 · United States District Court for the Southern District of New York · provisional

Southern District of New York on 2026-03-11 in Donte McClellon v. E. Rickard, Warden of FCI Otisville, et al. found the self-represented party's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, incorrect statutory or rule text. The court warned the self-represented party to disclose AI use when required and to verify future citations.

ultimately are not real.” Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341, 342 (E.D.N.Y. 2025). Courts in this circuit have repeatedly found that presenting AI-generated hallucinations as valid caselaw constitutes subjective bad faith. See Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 448–49 (S.D.N.Y. 2023); Benjamin, 779 F. Supp. 3d at 349–50; …

2026-03-11 · United States District Court for the Western District of Michigan · provisional

Western District of Michigan on 2026-03-11 in Checks Aciek Ateny Nai v. National Asset Mortgage, LLC, et al. found counsel's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court discharged the show-cause issue and declined Rule 11 sanctions after reviewing the explanation for the defective authorities.

See, e.g., Lothamer Tax Resolution v. Kimmel, Case No. 1:25-cv-579, ECF No. 184 (W.D. Mich. December 1, 2025) (imposing Rule 11 sanctions to address “briefs . . . riddled with incorrect citations”); United States v. Hayes, 763 F. Supp. 3d 1054, 1067 (E.D. Cal. 2025) (“Citing nonexistent case law or misrepresenting the holdings of a …

2026-03-11 · United States District Court for the District of Massachusetts · provisional

District of Massachusetts on 2026-03-11 in Traver v. General Motors Financial Company Inc., et al. found the self-represented party's complaint contained three citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

Rule 15(a) to correct a misnomer.”). 3. Nonexistent Case Citations Defendants bring to the Court’s attention that Plaintiffs’ Opposition cites cases that do not exist and contain mischaracterizations of legal precedent and rules of law. The Court has conducted its own research into Plaintiffs’ citations and concludes that they are indeed nonexistent. [See Dkt. 74 …

2026-03-11 · Appellate Court of Illinois · 2026 IL App (1st) 250702-U · provisional

Illinois Appellate Court on 2026-03-11 in Kateryna Maslovska v. Ekaterina Shigabetdinova found the self-represented party's brief contained two citation defects involving mischaracterized authority. The court warned both sides to verify authorities and quotations before filing future papers in the challenged filing before resolving the pending matter.

App. 3d 677, 682 (1993). true ‘when the judgment order states that the court is fully advised in the premises.’ ” Id. (quoting Dell'Armi Builders, ¶ 13 The parties’ briefs also appear to violate the supreme Inc. v. Johnston, 172 Ill. App. 3d 144, 149 (1988)). court's guidance concerning the use of generative artificial intelligence …

2026-03-11 · District Court of Appeal of Florida · 2026 WL 681054 · provisional

Florida District Court of Appeal on 2026-03-11 in Samantha Roussell v. The Bank of New York Mellon found the self-represented party's appellee brief contained two citation defects involving mischaracterized authority, incorrect statutory or rule text, defective exhibits or submissions. The court warned the self-represented party to verify legal authorities before future filings.

FOR PUBLICATION IN THE PERMANENT record, we affirm on the merits without discussion. We write, LAW REPORTS. UNTIL RELEASED, IT IS however, to address our concerns with the purported legal SUBJECT TO REVISION OR WITHDRAWAL. authority upon which the appellant relied in her brief. The appellant cited thirteen different cases that do not exist. We …

2026-03-10 · United States District Court for the Southern District of New York · provisional

Southern District of New York on 2026-03-10 in Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law (1) found counsel's brief contained one citation defect, including Protégé, involving nonexistent authorities, fabricated or misattributed quotations. The court referred counsel to disciplinary authorities for the defective citations.

I. Hallucinated Cases Before this Court begins its analysis, it must address Blackburn’s pervasive citations to non-existent authority in his briefing in support of Defendants’ motion to dismiss. As Plaintiff points out, Defendants’ brief contains several fake authorities and misrepresentations of the law. Opp. at 10-11; see also Dkt. 57. Blackburn does not dispute this …

2026-03-10 · Court of Appeals of Mississippi · 2026 WL 670733 · provisional

Court of Appeals of Mississippi on 2026-03-10 in Brown v. State of Mississippi found counsel's reply brief contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned counsel to verify legal authorities before future filings.

3 Brown does not assert that his statutory right to a speedy trial was violated. See Miss. Code Ann. § 99-17-1 (Rev. 2020). 4 In the State's appellate brief, the State asserts that regarding this issue, Brown cites three cases that do not exist and five others that his brief misattributes false facts, analyses, quotations, …

2026-03-10 · United States District Court for the Southern District of Indiana · provisional

Southern District of Indiana on 2026-03-10 in Michael Platt v. Volunteers of America Ohio & Indiana found the self-represented party's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court struck the defective filing and warned the self-represented party to verify cited authorities before filing again.

U.S. Dist. LEXIS 100748, at *1–4 (adopting in part a report and recommendation and imposing a $6,000 personal sanction where counsel admitted to filing briefs containing fictitious AI-generated citations); Virgil, 2026 U.S. Dist. LEXIS 29090, at *11 (recommending a $10,000 personal sanction for counsel filing five briefs that contained citations to non-existent cases); Salahuddin v. …

2026-03-10 · Indiana Court of Appeals · 2026 WL 672475 · provisional

Indiana Court of Appeals on 2026-03-10 in A.K. v. M.R. found the self-represented party's appellate brief contained four citation defects, including 994 N.E.2d 228, 106 N.E.3d 400 and 212 N.E.3d 768, involving nonexistent authorities, mischaracterized authority. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.

the vulgar language used by M.R. in her signs, her conduct fails to rise to the level of a “credible threat” to establish names stated in the brief. 8 These errors could be chalked up harassment for the purposes of issuing a protection order. to mere carelessness, but we think it more likely that they …

2026-03-10 · United States District Court for the Southern District of Illinois · provisional

Southern District of Illinois on 2026-03-10 in Tina Rose v. City of West Frankfort et al. found the self-represented party's filing contained one citation defect involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

“A person commits a hate crime when, by reason of the actual or perceived . . . physical or mental disability . . . of another individual or group of individuals, regardless of the existence 3 The Court believes that Plaintiff may be using generative AI platforms, such as ChatGPT, to draft her filings. Plaintiff …

2026-03-10 · United States District Court for the Northern District of Illinois · provisional

Northern District of Illinois on 2026-03-10 in Helen Allen v. Cass Casper and Disparti Law Group found the self-represented party's brief contained two citation defects, including Krause v. Meyers, Krause and Krause v. Meyers', involving nonexistent authorities, fabricated or misattributed quotations. The court ordered the self-represented party to pay $1,500 for the defective authorities.

that she is representing herself does not relieve her of that duty. Filing a document that contains citations to nonexistent cases, quotes language that comes from no real case, or that contains arguments wholly unsupported by the record violates Rule 11. Allen did just that. This demonstrates that Allen failed to make a reasonable inquiry …

2026-03-10 · Appellate Court of Illinois · 2026 IL App (2d) 250299-U · provisional

Illinois Appellate Court on 2026-03-10 in In re A.R. and N.R., Minors found the self-represented party's appellate brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

after the 150-day deadline. service plans and did not involve a finding of unfitness. ¶ 47 On appeal, respondent, proceeding pro se, argues that: *10 ¶ 50 Further, respondent cites a case, In re K.B., 2019 (1) the trial court's fitness finding was against the manifest IL App (3d) 180086, which does not exist. The …

2026-03-10 · California Court of Appeal, Second District · 2026 WL 673409 · provisional

California Court of Appeal, Second District on 2026-03-10 in Arno Kuigoua v. Adam Michael Sacks found the self-represented party's opening brief contained three citation defects involving nonexistent authorities, defective exhibits or submissions. The court warned the self-represented party to verify legal authorities before future filings.

motions for reconsideration are reviewable as part of this appeal. (Ibid.) All further unattributed statutory references are to the Code of Civil Procedure. 2 The settlement agreement was referenced as “Exhibit A” to respondent's opposition but was not attached to the opposition. Instead, a note read, “Redacted due to confidentiality clause will release by court …

2026-03-10 · United States District Court for the District of Arizona · provisional

District of Arizona on 2026-03-10 in Hunter v. TForce Freight Incorporated found the self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

10 Arizona law recognizes for a viable wrongful termination claim. And he must identify 11 when the defamatory statement was made, who made it, and how it was conveyed to a third 12 party. 13 Finally, some of Hunter’s filings suggest he may be using generative artificial 14 intelligence (“generative AI”).3 The court has a …

2026-03-09 · United States District Court for the Southern District of New York · provisional

Southern District of New York on 2026-03-09 found counsel's brief contained two citation defects, including NYNEX Corp. v. Discon, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

their cause to be just.” Int’l Railways of Cent. Am. v. United Brands Co., 532 F.2d 231, 239 (2d Cir. 1976). [ECF 23 at 16] Why is there a “need” for the Order? Because if fake quotes are not dealt with appropriately, they will proliferate. Tolerating them or ignoring them is a luxury the American …

2026-03-09 · Court of Appeals of Georgia · 2026 WL 656355 · provisional

Court of Appeals of Georgia on 2026-03-09 in Slay v. Ross found counsel's appellate brief cited four fictitious Georgia authorities, including Waller v. Waller, Johnson v. Johnson, Durden v. Barron, and In re Waitz. The court warned counsel to verify legal authorities before future filings.

Before addressing the merits of the case, we are troubled by *2 Pertaining to the case at hand, in 2022, Slay moved for a certain irregularities in the brief filed on Slay's behalf by his downward modification of his child support payments. Slay attorney, Loletha Hale. We note that several of the cases cited then …

2026-03-06 · United States District Court for the Western District of Oklahoma · provisional

Western District of Oklahoma on 2026-03-06 in Dewayne Clark v. CoreCivic found the self-represented party's surreply contained five citation defects, including Garrison v. Gambro, Tuckel v. Glover and Lemons v. Portfolio Recovery Assocs, involving fabricated or misattributed quotations, mischaracterized authority. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.

about the types of errors found in Plaintiff’s briefs: There is nothing inherently problematic with the use of artificial intelligence to help prepare legal materials, but its careless use can waste both judicial resources and the opposing party’s time and money, and it can damage the credibility of the legal system. . . . We …

2026-03-06 · United States District Court for the District of Nevada · 2026 WL 658913 · provisional

District of Nevada on 2026-03-06 in Kim Elizabeth Harwell v. WestCare Nevada, Inc. found the self-represented party's brief contained one citation defect, including Saila v. Circle, involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

extends to attorneys and pro se litigants alike. FRCP 11(b). However, the complaint is unclear about which There has been a rise in fake authority cited in briefs, usually defendants Harwell is suing for negligence. In different as the result of using generative AI software, like ChatGPT, parts of her complaint, she alleges that the …

2026-03-06 · United States District Court for the District of Massachusetts · provisional

District of Massachusetts on 2026-03-06 in Gregory J. Van Etten v. Stephanie K. Fattman, et al. found the self-represented party's motion contained three citation defects, including Ankenbrandt v. Richards and Seminole Tribe v. Florida, involving mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

[ECF No. 139 at 2]. This objection reflects a fundamental misunderstanding of the statutory framework governing reports and recommendations and is without merit. 1 Under 28 U.S.C. § 1 It appears to the Court that Plaintiff relies on generative AI to make statements of law. However, the Court warns Plaintiff that generative AI does not …

2026-03-06 · United States District Court for the Western District of Louisiana · 2026 WL 637419 · provisional

Western District of Louisiana on 2026-03-06 in Kattom v. Bondi found counsel's motion contained two citation defects involving fabricated or misattributed quotations, incorrect statutory or rule text. The court ordered counsel to pay $1,000 for the defective authorities and complete corrective CLE.

by Friday, April 3, 2026, at 5:00 p.m. to: 1 Specifically, Mayeaux assets that “[h]e has undertaken concrete remedial measures, including enrolling in CLEs on AI- assisted legal practice, review of governing ethical guidance, and developing strengthened verification protocols to ensure that all authorities are independently confirmed before filing ....” See id. at 12. 2 …

2026-03-06 · United States District Court for the Northern District of Illinois · 2026 WL 636816 · provisional

Northern District of Illinois on 2026-03-06 in Hatch v. College Ave Student Loans found counsel's brief contained two citation defects, including Jones v. TransUnion and Horan v. Equifax Info. Servs, involving nonexistent authorities, incorrect statutory or rule text. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

question regarding the application of section 523(a)(8)(A) 1681i(a)), IV (willful violation of 15 U.S.C. § 1681i(a)), (i)”. Mader v. Equifax Info. Sols., Inc., 56 F.4th 264, 270 V (negligent violation of 15 U.S.C. § 1681e(b)), and VI (2d Cir. 2023) (plaintiff failed to allege an inaccuracy within (willful violation of 15 U.S.C. § 1681e(b)) are …

2026-03-06 · United States District Court for the District of Columbia · provisional

District of Columbia on 2026-03-06 in Andre Lamont Goddard, Jr. v. City University of Seattle found the self-represented party's motion contained five citation defects involving mischaracterized authority, incorrect statutory or rule text. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.

includes citation to several cases that do not appear to exist. 8 The cases bear the stamp of having been invented by artificial intelligence, given that they resemble authentic case citations, but when the reporter numbers are searched, turn up entirely unrelated cases that do not match the same name, date, or jurisdiction cited in …

2026-03-05 · United States District Court for the District of New Jersey · provisional

District of New Jersey on 2026-03-05 found the self-represented party's motion contained three citation defects, including Duff v. Trenton Beverage Co and Jordan v. Fox, involving fabricated or misattributed quotations, incorrect statutory or rule text. The court granted defendants' motion to dismiss, dismissed the complaint without prejudice, and reminded the plaintiff that false authorities may draw Rule 11 sanctions.

now or heretofore owing or accrued. (Settlement Agreement ¶ 2.) To the extent Plaintiff used artificial intelligence in drafting her papers, the Court reminds Plaintiff “[w]hile courts afford pro se litigants considerable leeway, that leeway does not relieve pro se litigants of their obligation under Rule 11 to confirm the validity of any cited legal …

2026-03-05 · United States District Court for the Eastern District of Louisiana · provisional

Eastern District of Louisiana on 2026-03-05 in Woodward Harbor L.L.C., et al. v. City of Mandeville found counsel's brief contained three citation defects, including Wood v. City of Utica, Qutb v. Ramsey and Wood v. City, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to pay $1,000 for the defective authorities and complete corrective CLE.

III. ANALYSIS The problem of AI-fabricated case citations is well-documented throughout the judiciary, including in this circuit. See, e.g., Fletcher v. Experian Info. Sols., Inc., 2026 WL 456842, at *2 (5th Cir. Feb. 18, 2026) (“Regrettably, despite numerous news stories, CLE presentations, scholarly articles, and judicial entreaties, AI-hallucinated case citations have increasingly become an even …

2026-03-05 · California Court of Appeal · provisional

California Court of Appeal on 2026-03-05 found counsel's brief contained two citation defects, including 34 Cal.3d 926, Marriage of Twigg and In re Marriage of Teegarden, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to pay $5,000 for the defective authorities and referred the matter for discipline and complete corrective CLE.

therefore affirm the family court’s order. III We next consider whether to impose sanctions against Bonar for citing and relying on fictitious legal authorities in her oppositions to the motions to reinstate this appeal. Business and Professions Code section 6068, subdivision (d), states it is the duty of an attorney “[t]o employ . . . …

2026-03-05 · Court of Appeals of Arizona · 2026 WL 619894 · provisional

Arizona Court of Appeals on 2026-03-05 in In the Matter of the Estate of Kuerschner found the self-represented party's appellate briefs contained 25 made-up or substantially erroneous citations, including fake quotes and unsupported propositions. The court dismissed the appeal under ARCAP 25 and awarded appellee reasonable attorney fees and costs for repeated fabricated citations.

1,200 documents, many of which are over a hundred pages result. long and were submitted after briefing was completed. We need not assume the duties of an advocate to search the record and support Stefanie's claims. See Adams v. Valley Nat'l Bank CONCLUSION of Ariz., 139 Ariz. 340, 343 (App. 1984). ¶14 We dismiss Stefanie's …

2026-03-04 · United States District Court for the Western District of Washington · 2026 WL 607769 · provisional

Western District of Washington on 2026-03-04 in Ryan Adam Dixon v. MultiCare Health System (1) found the self-represented party's brief contained five citation defects, including Mazza v. Washoe Cnty, Shirley v. Precision Castparts Corp and Bounds v. Smith, involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

Dixon's ERISA claims is DENIED. However, MultiCare's treated more favorably than parties with attorneys of record. request to compel arbitration on those claims is GRANTED. Jacobsen v. Filler, 790 F.2d 1362, 1364 (9th Cir. 1986). Dixon's ERISA claims are STAYED pending arbitration. The parties shall file a Joint Status Report within 30 days of the …

2026-03-04 · United States District Court for the Western District of Washington · provisional

Western District of Washington on 2026-03-04 in Medal v. Amazon.com Services, LLC found counsel's opening brief included erroneous citations generated by AI-based search engines, combining captions, unrelated citations, and unsupported principles. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

3 GRANTS the Motion and ORDERS Plaintiffs’ counsel to explain: (1) each signatory’s role in 4 the use of the “juxtaposed” language and accompanying false citation in Plaintiffs’ Opposition to 5 Defendant’s Motion to Stay (Dkt. No. 122) (“Opposition”); (2) whether and how the drafting or 6 research for the Opposition was aided by the …

2026-03-04 · United States District Court for the Northern District of New York · provisional

Northern District of New York on 2026-03-04 in Jeri'yah Ford v. Troy City School District, et al. found counsel's response contained two citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

rely. Indeed, we can think of no other way to ensure that the arguments made based on those authorities are “warranted by existing law,” Fed. R. Civ. P. 11(b)(2), or otherwise “legally tenable.” Cooter & Gell, 496 U.S. at 393[ ]. As a District Judge of this Circuit recently held when presented with non-existent precedent …

2026-03-03 · Court of Appeals of Washington · 2026 WL 586674 · provisional

Washington Court of Appeals on 2026-03-03 in In the Matter of the Estate of CAROL M. CAREY found the self-represented party's appellate brief contained six citation defects, including Perez v. Pappas, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered the self-represented party to pay or reimburse $1 in fees or costs for the defective filing.

concerns the TEDRA Agreement. ORDER ON MS. WHITMAN’S AND MR. MAY’S MOTION FOR SUMMARY JUDGMENT Ms. Whitman also requests sanctions against Todd for filing Todd argues the court's order on summary judgment this frivolous appeal, his failure to comply with the RAPs, in favor of Ms. Whitman and Mr. May was inappropriate. and his multiple …

2026-03-03 · United States Bankruptcy Court for the Central District of California · provisional

United States Bankruptcy Court for the Central District of California on 2026-03-03 in In re Lusine Hakhverdyan found counsel's motion cited Whittaker v. Otto, 2014 WL 37845 (9th Cir.), which the court described as inaccurate or nonexistent. The court denied the debtor's Rule 60 motions after noting an inaccurate or nonexistent Whittaker citation in the debtor's papers.

21 3. FRCP 60(b)(4) – Orders Void for Lack of Jurisdiction 22 23 Under FRCP 60(b)(4), a judgement or order may be set aside as void for lack of 24 2 25 In these motions, Debtor occasionally refers to inaccurate or nonexistent case citations. For example, in the First Relief Motion, Debtor cites “Whittaker v. …

2026-03-02 · Court of Appeals of Washington · 2026 WL 579399 · provisional

Washington Court of Appeals on 2026-03-02 in Put A Bird On It, LLC v. Seattle Arena Holdings, LLC found counsel's opening brief included several AI-generated erroneous citations and false quotations with mismatched captions, citations, and legal principles. The court affirmed dismissal of the contract claims with prejudice and noted counsel's AI-based erroneous citations and false quotations.

2 While not germane to our substantive analysis, the court notes that appellant's opening brief included several erroneous citations that the responsible attorneys at Corr|Downs PLLC have since indicated were generated by “AI-based search engines.” The citations for these cases appear to be a compilation of (a) a real or fictitious caption, (b) citations to …

2026-03-02 · United States District Court for the Eastern District of Texas · provisional

Eastern District of Texas on 2026-03-02 in Fabian Antonio Thomas v. Officer Skylar Sillivent, et al. found the self-represented party's objection cited United States v. Lopez, 817 F.3d 541, 545 (5th Cir. 2016), which the court described as a phantom case. The court adopted the report and recommendation, granted defendants' motions to dismiss, and dismissed the action with prejudice.

opportunity to amend his complaint in response to the motion (Docket No. 23), which was addressed in the Report. Judge Love considered that the amended complaint did 1 Plaintiff’s citation in support of one of these objections, United States v. Lopez, 817 F.3d 541, 545 (5th Cir. 2016), appears to be a phantom case that …

2026-03-02 · United States District Court for the Eastern District of North Carolina · provisional

Eastern District of North Carolina on 2026-03-02 in Derence V. Fivehouse v. United States Department of Defense et al. found counsel's motion contained seven citation defects involving fabricated or misattributed quotations, incorrect statutory or rule text. The court admonished counsel to verify cited authorities and avoid repeating the citation defects.

v. Sullivan, 915 F.2d 129, 130 (4th Cir. 1990). 4. The inclusion of a fabricated quotation from 32 C.F.R. § 199.21(d) in Defendants’ response opposing Fivehouse’s motion for a preliminary injunction (D.E. 39). 5. The inclusion of a fabricated quotation from 32 C.F.R. § 199.21(d) in Defendants’ response opposing Fivehouse’s motion for summary judgment (D.E. …

2026-03-02 · United States District Court for the Eastern District of Michigan · 2026 WL 575225 · provisional

Eastern District of Michigan on 2026-03-02 found the self-represented party's brief contained four citation defects, including Patel v. City of Ferndale, 308 F.3d 511, 517 (6th Cir. 2002), Thompson v. City of Lebanon, 813 F.3d.... The court adopted the report and recommendation, dismissed the amended complaint with prejudice, and entered a filing injunction.

cases and to avoid congestion in the calendars of the District 100% 100% Courts.” Link v. Wabash R. Co., 370 U.S. 626, 629–30 (1962). Exercising that power is increasingly important in the wake The office of the Eastern District of Michigan's Court of the exploding use of generative AI. Damien Charlotin, a Administrator provided the …

2026-02-27 · Court of Appeals of Arizona · 2026 WL 555638 · provisional

Arizona Court of Appeals on 2026-02-27 in In the Matter of the Estate of Arturo Lopez found the self-represented party's opening brief contained two citation defects involving fabricated or misattributed quotations, mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

influence. See Rosenberg, 256 Ariz. at 364 ¶ 26. her amended opening brief, Sister-in-law does not specify which fees were excessive. Thus, the superior court's award ¶24 Sister-in-law cites no legal authority to support her of attorney fees is affirmed. position that expert testimony is required for a finding of unsound mind. Her argument is …

2026-02-26 · United States District Court for the Western District of Texas · 2026 WL 594760 · provisional

Western District of Texas on 2026-02-26 in David Thomas v. The Quikrete Companies, LLC found counsel's summary-judgment briefing misrepresented Ash v. Flowers Foods and used hallucinated quotations that do not appear in that opinion. The magistrate judge recommended granting Quikrete summary judgment and denying plaintiffs' summary-judgment motion despite the hallucinated quotation.

3 Plaintiffs cite Ash throughout their briefing as standing for the proposition that bread products stored in local warehouses for various lengths of time were not in a continuous stream of interstate commerce because they were held in storage “without a fixed and persisting intent to ship to a particular customer.” (See, e.g., Resp. [#99], …

2026-02-26 · United States District Court for the District of Nevada · 2026 WL 540272 · provisional

District of Nevada on 2026-02-26 in United States v. Robert Ponce, Jr. found counsel's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned counsel to verify legal authorities before future filings in the challenged filing before resolving the pending matter.

1 Both of Ponce's motions and replies are filled with hallucinogenic citations to non-existent cases. To the extent Ponce has relied on artificial intelligence to write his papers, I caution him that it is his responsibility to check his case citations to ensure they are accurate and say what he claims they do. The failure …

2026-02-26 · Supreme Court of North Dakota · 2026 WL 533638 · provisional

Supreme Court of North Dakota on 2026-02-26 in Volker v. Nygaard found the self-represented party's brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court dismissed the appeal with prejudice as a Rule 11 sanction for repeated fictitious AI-generated citations.

II [¶1] Scott Volker appeals from a district court judgment dismissing his claims with prejudice as a Rule 11, [¶6] This Court must have jurisdiction to consider the merits N.D.R.Civ.P., sanction for repeatedly submitting fictitious, of an appeal. Desert Partners IV, L.P. v. Benson, 2014 ND AI-generated case citations. Danielle Hough, formerly known 192, ¶ …

2026-02-26 · Court of Appeals of Georgia · 2026 WL 537755 · provisional

Court of Appeals of Georgia on 2026-02-26 in Hicks v. City of Albany found counsel's brief contained two citation defects, including Knight v. Pierson, involving nonexistent authorities, incorrect statutory or rule text. The court warned counsel to verify legal authorities before future filings.

1 The notice states that photographs of the stormwater drainage intake are attached, but no such photographs are included in the appellate record. 2 In his initial brief on appeal, Hicks cited two cases we could not locate, either by case name or citation. Those cases are Knight v. Pierson, Inc., 206 Ga. App. 514 …

2026-02-26 · California Court of Appeal · 2026 WL 539183 · provisional

California Court of Appeal on 2026-02-26 in Samuel K. v. Winsley Focia found the self-represented party's opening brief contained three citation defects, including Medical Board v. Superior Court and People v. Panah, involving nonexistent authorities, fabricated or misattributed quotations. The court dismissed the appeal, assessed appellate costs, and addressed the defective authorities.

authorities necessarily dooms her appeal. (Id. at p. 436.) v. Frederickson (2020) 8 Cal.5th 963, 1000 [“Self-represented [parties] are ‘held to the same standard of knowledge of law In total, Focia's opening brief contains 12 quotations, 11 and procedure as is an attorney[.]’ ”]; Rappleyea v. Campbell of which are fabrications. Several of these fake …

2026-02-26 · United States District Court for the Central District of California · provisional

Central District of California on 2026-02-26 in Estate of Khallid Muhammad et al v. Tupac Shakur Estate et al found counsel's response contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

CIVIL MINUTES – GENERAL Case No. 2:25-cv-02540-JLS-JPR Date: February 26, 2026 Title: Estate of Khallid Muhammad et al v. Tupac Shakur Estate et al Having reviewed Plaintiffs’ response, the Court finds it both vague and deficient. Plaintiffs are ORDERED TO APPEAR on March 6, 2026 at 10:30am in Courtroom 8A to show cause as to …

2026-02-26 · United States District Court for the District of Arizona · provisional

District of Arizona on 2026-02-26 found the self-represented party's filing contained three citation defects, including Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014), Matterhorn, Inc. v. NCR Corp., 763 F.2d.... The court warned the self-represented party to verify legal authorities before future filings.

for at least two cases cited in Plaintiff’s opposition—Anderson v. Dean Witter Reynolds, 24 Inc., 306 F.3d 726 (9th Cir. 2002), and Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014)—the citation provided does not return the case identified. Furthermore, Plaintiff’s 25 opposition misattributes apparently fake quotations to real cases. (See, e.g., Doc. …

2026-02-25 · Court of Criminal Appeals of Tennessee · 2026 WL 518478 · provisional

Court of Criminal Appeals of Tennessee on 2026-02-25 in Moses v. State found the self-represented party's appellate brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court dismissed claims or denied relief after identifying the defective authorities.

defective. On January 16, 2025, Moses filed a motion seeking argues that Moses failed to properly cite the record or to additional time to file an amended complaint in the event legal authority as required by Tennessee Rule of Appellate the Claims Commission found she needed leave to do so. Procedure 27(a)(7). Moses’ brief contains …

2026-02-25 · United States District Court for the Southern District of Ohio · provisional

Southern District of Ohio on 2026-02-25 found counsel's brief contained nine citation defects, including In re Protech, 51 F.4th 714 (6th Cir. 2022), United States v. Pendergraft and Inc. v. Impact Office Prods, involving nonexistent authorities, fabricated or misattributed quotations. The court found contempt, struck the defective filing, and ordered counsel to pay $7,500.

before the successor judge with accurate citations. The imposition of sanctions for misuse of generative Al is relatively new; for instance, Mata v. Avianca, Inc., one of the first significant federal cases on the topic, was not published until June 22, 2023. 678 F. Supp. 3d 443 (S. D. N. Y. 2023). reflects the proliferation …

2026-02-25 · United States District Court for the District of Kansas · 2026 WL 516955 · provisional

District of Kansas on 2026-02-25 in Roosevelt Hunt, Jr. v. True Sky Federal Credit Union found the self-represented party's brief contained one citation defect, including Howard v. CitiMortgage, Inc., 2019 WL 1401348 (D. Kan. Mar. 28, 2019) and Howard v. CitiMortgage, involving nonexistent authorities. The court warned the self-represented party to verify legal authorities before future filings.

2 Although Plaintiff's argument section is titled “Plaintiff's contract claims are properly pled,” Plaintiff only addresses his claim of breach of the implied duty of good faith. (Doc. 20 at 3.) 3 Plaintiff also cites to a non-existent case in support of his arguments on the FCRA claim. (Doc. 20 at 1) (citing to Howard …

2026-02-25 · District Court of Appeal of Florida · 2026 WL 516317 · provisional

Florida District Court of Appeal on 2026-02-25 in Straub v. Henderson found the self-represented party's appellee brief contained one citation defect involving nonexistent authorities. The court affirmed the judgment while identifying the defective authorities in the appellate briefing in the challenged filing before resolving the pending matter.

NOTICE: THIS OPINION HAS NOT BEEN RELEASED *1 Affirmed. See Clerk of Ct. & Comptroller for 13th Jud. FOR PUBLICATION IN THE PERMANENT Cir., Hillsborough Cnty. v. Rangel, No. 2D2024-1772, 2025 LAW REPORTS. UNTIL RELEASED, IT IS WL 2486314, at *2 (Fla. 2d DCA Aug. 29, 2025) (“[T]he SUBJECT TO REVISION OR WITHDRAWAL. dangers of …

2026-02-25 · California Court of Appeal · 2026 WL 521913 · provisional

California Court of Appeal on 2026-02-25 in Anthony Jama Hall v. Superior Court of Sacramento County found the self-represented party's appellate brief contained three citation defects, including Sacramento v. Superior Court, involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

appeal or forever lose the opportunity to obtain appellate v. Alvarez (2025) 114 Cal.App.5th 1115, 1119.) Appellant review’ ”]; People v. Ramirez (2008) 159 Cal.App.4th 1412, is warned that by using fabricated legal authorities in legal 1420-1421 [“ ‘A timely notice of appeal, as a general matter, filings, his filings may be stricken (Cal. Rules …

2026-02-25 · United States District Court for the Western District of Arkansas · provisional

Western District of Arkansas on 2026-02-25 in Christina Leas Dunn v. Nelnet found the self-represented party's motions cited several cases that Nelnet said did not exist; the party admitted the citations were incorrect and filed no correction. The court granted Nelnet's motion to dismiss, denied the plaintiff's motions, and dismissed the case without prejudice.

required before a creditor can enforce a debt. That may be true, but this is not an 4 Nelnet points out in its response to this motion that none of Ms. Dunn’s cited case law actually exists, and Nelnet believes the citations to be AI hallucinations. (Doc. 60, ¶ 15). Ms. Dunn admits in her …

2026-02-25 · Court of Appeals of Arizona · 2026 WL 517864 · provisional

Arizona Court of Appeals on 2026-02-25 in In re termination of parental rights (HK) found counsel's brief contained four citation defects, including Raymond F. v. Dep't, involving nonexistent authorities, fabricated or misattributed quotations. The court referred counsel to disciplinary authorities for the defective citations.

on appeal. See Alma S., 245 Ariz. at 151, ¶ 18. Reasonable relying on inappropriate legal authorities). We will forward evidence supports the court's best interests findings. this decision to the State Bar of Arizona to determine whether Mother's counsel violated any rules of professional conduct. IV. Mother's Answering Brief ¶26 Mother's answering brief contains …

2026-02-24 · United States District Court for the Western District of Virginia · provisional

Western District of Virginia on 2026-02-24 in Gail Fung v. Liberty University found the self-represented party's complaint contained one citation defect involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

Fung fails to allege sufficient facts to pass even the first element of this test—her complaint merely alleges “Liberty failed to adhere to its established graduation policies,” without establishing what those policies are or what “false representations” Liberty made regarding her graduation. Dkt. 38 at 1. And further, Fung’s complaint is silent as to the …

2026-02-24 · United States District Court for the District of Utah · 2026 WL 690784 · provisional

District of Utah on 2026-02-24 in Ryan Lee v. Capital One Bank et al. found the self-represented party's motion contained one citation defect involving mischaracterized authority, incorrect statutory or rule text, defective exhibits or submissions. The court warned the self-represented party to verify legal authorities before future filings.

Co., 15 does not support Plaintiff's position. The court agrees Amended Complaint should be dismissed as to ABC Legal. that Plaintiff's authority is misplaced. However, the court has wide discretion in considering a Rule 12(b)(5) motion. This In closing, the court notes its concern with the use of artificial includes dismissing a case if it …

2026-02-24 · United States District Court for the Eastern District of Texas · 2026 WL 555590 · provisional

Eastern District of Texas on 2026-02-24 in Wells Fargo Bank v. Frances W. Dean found the self-represented party's motion contained four citation defects involving nonexistent authorities, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

(W.D. Tex. Oct. 19, 2009). 618, 621 (5th Cir. 1985). The decision to grant or deny an injunction lies within the court's discretion. Id. II. Dean's Reliance on Nonexistent Citations Dean cites several cases, or purported cases, in her DISCUSSION motion and reply. Two of them—American Residential Services of Texas, LP v. Jimenez, 446 S.W.3d …

2026-02-24 · United States District Court for the Northern District of Oklahoma · provisional

Northern District of Oklahoma on 2026-02-24 in Chapter Kris Jackson v. BOK Financial Corporation et al. (3) found the self-represented party's brief contained three citation defects, including Inc. v. Carmen Feliciando and Badillo v. Thorpe, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered the self-represented party to pay $405 for the defective authorities.

579 U.S. 40, 47 (2016) (recognizing a district court’s inherent power to manage its docket); Moore v. City of Del City, No. 25-6002, 2025 WL 3471341, at *3 (10th Cir. Dec. 3, 2025) (recognizing the same in the context of an attorney who submitted briefs that contained hallucinated or fake case citations as a result …

2026-02-24 · United States District Court for the Western District of North Carolina · 2026 WL 642917 · provisional

Western District of North Carolina on 2026-02-24 in Ebony Sherisse Lucas v. Charles W. Scharf, et al. found the self-represented party's brief contained 13 citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court ordered the self-represented party to show cause why sanctions, striking, or referral should not issue for the defective authorities.

Court.1 10. Lindner v. Countrywide Hom Loans, Inc., 447 F. Supp. 2d 999 (D. Minn. 2006) AI can be a powerful tool for pro se plaintiffs. However, the (Doc. No. 7). In her reply, Plaintiff cites two more fake cases Court cannot blindly ignore its risks, including the increased (Eaton v. Am. Bankers Life Assurance …

2026-02-24 · Civilian Board of Contract Appeals · provisional

Civilian Board of Contract Appeals on 2026-02-24 in Louis J. Blazy v. Department of State found the self-represented party's motion contained three citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court admonished the self-represented party to verify cited authorities and avoid repeating the citation defects.

(3) Appellant’s vague, confusing, and unpersuasive responses to the Board’s orders raise questions as to the credibility and veracity of his responses. 2 In response to a Board order, appellant stated that he did not use artificial intelligence (AI) to draft his motion. A characteristic of using AI is its propensity to “hallucinate,” meaning to …

2026-02-24 · United States District Court for the Eastern District of California · provisional

Eastern District of California on 2026-02-24 in Juan Villalovos-Gutierrez, et al. v. Gerard Van de Pol, et al. (2) found counsel's motion contained two citation defects involving nonexistent authorities. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

20 respond to the troubling assertion that defendant has produced improperly redacted records. 21 Defendant also cites cases purportedly from this district that do not exist, 1 even though defendant 22 was issued a prior warning in this case that doing so is a potential ground for sanctions. (See ECF 23 No. 29 at 5-6.) …

2026-02-23 · United States District Court for the Southern District of Texas · 2026 WL 497165 · provisional

Southern District of Texas on 2026-02-23 in Kenneth Hawkins v. I.C. System, Inc. found the self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

“By presenting to the court a ... written motion ... an attorney or unrepresented party certifies that to the best of that person's knowledge, information, and belief, formed after an inquiry reasonable under circumstances the ... legal contentions are warranted by existing law.” FED R. CIV. P. 11(b)(2) (emphases added). Providing these nonexistent citations wastes …

2026-02-23 · United States District Court for the Northern District of Texas · provisional

Northern District of Texas on 2026-02-23 in Shawn Olali v. Ampex Brands, LLC found the self-represented party's filing contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

PREJUDICE. Plaintiff is admonished that any further failure to comply with the notice requirements set out in Local Civil Rule 7.2(f)(1)-(3) or filing of pleadings with citations to nonexistent cases, in violation of Fed. R. Civ. P. 11, may result in the imposition of sanctions, including the striking of filings, the imposition of filing restrictions …

2026-02-23 · United States District Court for the Central District of California · 2026 WL 563023 · provisional

Central District of California on 2026-02-23 in Zeus Realty Group LLC v. 1032 N Sycamore Owner LA, LLC et al found counsel's temporary-restraining-order motion cited nonexistent cases and inaccurate quotations while seeking to halt a state unlawful-detainer proceeding. The court dismissed the complaint without leave to amend, denied the temporary-restraining-order motion, and dismissed the action without prejudice.

1 As an initial matter, the Court notes that in Defendant's Opposition. Defendant asserts that Plaintiff has filed numerous pleadings based on the same legal and factual grounds already ruled upon by the trial court in the unlawful detainer action. Opposition at 11. Defendant further claims that it believes Plaintiff's recent filings are a product …

2026-02-20 · United States District Court for the Eastern District of Michigan · provisional

Eastern District of Michigan on 2026-02-20 found the self-represented party's motion contained two citation defects, including Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022), ABC Corp. v..... The court warned the self-represented party to verify legal authorities before future filings.

sever her claim from Sharon’s. Id. at PageID.2357–58. Fourth, she argues that Judge Morris erred in not recusing herself. Id. at PageID.2358–59. In so doing, she cites a case that does not exist— “Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022).” 3 Id. at PageID.2359. Fifth, …

2026-02-19 · United States District Court for the District of Massachusetts · 2026 WL 479029 · provisional

District of Massachusetts on 2026-02-19 in In re: Marrett found the self-represented party's complaint contained two citation defects, including Goguen v. Nason and Ridgway v. Prudential Ins. Co, involving nonexistent authorities, fabricated or misattributed quotations. The court dismissed claims or denied relief after identifying the defective authorities.

B. Count I: “Fraud on the Court” In Count I, the Complaint alleges that Kennedy-Jensen, Here, Count I fails to state a claim upon which relief can Souza, and Druary (the “Count I Defendants”)31 committed be granted because none of the alleged conduct occurred fraud on the court by “submitting fabricated orders, before this Court. …

2026-02-19 · United States District Court for the Southern District of Florida · provisional

Southern District of Florida on 2026-02-19 in Juandel Pena and Martina Ruiz v. Wells Fargo Bank, N.A. found the self-represented parties' reply misread Holden and cited a nonexistent page beyond the end of the Eleventh Circuit opinion. The magistrate judge recommended denying the renewed preliminary-injunction motion and warned that further false AI citations could require a sanctions hearing.

the FCRA. Indeed, Holden never discusses or mentions injunctive relief. At worst, Plaintiffs have obtained their Holden analysis and citation from an unreliable source, such as artificial intelligence (“AI”). The best indication of this possibility is Plaintiffs’ citation to page 1371 of Holden. Holden, 4 Case 0:25-cv-62431-MD Document 37 Entered on FLSD Docket 02/19/2026 Page …

2026-02-19 · United States District Court for the Middle District of Florida · 2026 WL 472321 · provisional

Middle District of Florida on 2026-02-19 in Johnson v. Florida Department of Juvenile Justice et al found the self-represented party's motion contained two citation defects, including Watson v. Amedisys Holding and Martin v. Dep't, involving nonexistent authorities. The court struck the defective filing and warned the self-represented party to verify cited authorities before filing again.

Brown v. Crawford, 906 F.2d 667, 670 (11th Cir. 1990). Plaintiff's response to Defendant DJJ's Motion for Summary Judgment regarding Count I, III, IV, V, and VII was then struck by the Court, Dkt. 158, as it cited to hallucinated cases. DISCUSSION See Dkt. 150 at 7, 13, 16 (citing Watson v. Amedisys Holding, LLC, …

2026-02-18 · United States District Court for the Eastern District of Texas · 2026 WL 468409 · provisional

Eastern District of Texas on 2026-02-18 in Shaerica L. Walder v. Experian Information Solutions found the self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

464 (5th Cir. 1985) (“[T]he denial of a motion for summary judgment is not the equivalent of the entry of judgment ORDER against the movant.”). Thus, plaintiff's second objection is J. CAMPBELL BARKER United States District Judge meritless. Plaintiff brought this action under the Fair Credit As to plaintiff's final objection, the court appreciates Reporting …

2026-02-18 · United States District Court for the District of Oregon · provisional

District of Oregon on 2026-02-18 in David Martin v. ODS Community Dental Insurance et al. found the self-represented party's motion quoted language not found in Zschernig and gave incomplete citations to Hartman, Estelle, and Glucksberg. The court denied the temporary-restraining-order motion and warned the self-represented plaintiff against further inaccurate or incomplete citations.

claims, the Court notes that many of Plaintiff’s citations to caselaw are inaccurate or contain incomplete citations.3 To the extent that Plaintiff is using generative artificial intelligence to aid 3 For example, Plaintiff cites to Zschernig v. Miller, 389 U.S. 429, 432 (1968), for a quote that does not exist on the cited page or …

2026-02-18 · United States District Court for the Southern District of Ohio · provisional

Southern District of Ohio on 2026-02-18 found the self-represented party's brief contained one citation defect, including Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) and Johnson v. Mitchell, involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

Moreover, both Car Source and the Dealer Loyalty Defendants point out that Plaintiff is citing hallucinated cases that do not exist, likely generated by artificial intelligence (“AI”). (See ECF No. 23, PageID 100 (explaining “Plaintiff cites Johnson v. Mitchell, 2:20-cv-1882, 2020 WL 5649609 (S.D. Ohio Sept. 23, 2020) for the proposition that Car Source’s disclosure …

2026-02-18 · United States District Court for the District of Kansas · provisional

District of Kansas on 2026-02-18 in Kennon v. Ashley found counsel's brief contained nine citation defects, including Take me to jail, Okay and It was the language, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

surrounding passages that Plaintiff omits. (Doc. 55-1 at 115-116.) The short, punctual exchange that Plaintiff quotes, does not exist. On page nine, Plaintiff quotes another long passage from the Ashley deposition that the court won’t bother to reproduce. (Doc. 55 at 9) (quoting Doc. 55-1 at 161:22-162:16). While the subject matter of the cited portion …

2026-02-18 · Government Accountability Office · provisional

Government Accountability Office on 2026-02-18 in Matter of: Adapt Forward, LLC found counsel's filing contained three citation defects, including SRA Int’l, Inc, Boeing Sikorsky Aircraft Support and Caci, Inc, involving nonexistent authorities, fabricated or misattributed quotations. The court warned counsel to verify legal authorities before future filings.

None of the original citations correctly identified both the case B-number and date; one citation contained an inaccurate B-number. Although the protester provided accurate revised citations, none of the three decisions cited support the asserted proposition. An attorney’s citation of non-existent or inapposite decisions that might have been generated by artificial intelligence may implicate applicable …

2026-02-18 · California Court of Appeal · 2026 WL 457265 · provisional

California Court of Appeal on 2026-02-18 in EFD USA, INC., et al. v. Band Pro Film and Digital, Inc., et al. found counsel's reply brief contained six citation defects, including Leaf v. City, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to pay $900 for the defective authorities and complete corrective CLE.

before the filing deadline, and did not have time to cite appeal. The OSC noted that several quotations in EFD's check it before filing. Keiter acknowledges that the mistakes briefing in the “R” appeal appear to be fabricated. Azar, who in the briefing are “unacceptable,” but he asserts that signed the opening brief, and Keiter, …

2026-02-18 · United States Court of Appeals for the Fifth Circuit · provisional

Fifth Circuit on 2026-02-18 in Fletcher v. Experian Information Solutions & Bridgecrest Credit Company found counsel's reply brief contained four citation defects, including Edwards v. General Motors Corp and Lewis v. Brown, involving fabricated or misattributed quotations, mischaracterized authority. The court ordered counsel to pay $2,500 for the defective authorities and complete corrective CLE.

Proposed Rule, https://www.ca5.uscourts.gov/docs/default-source/default- document-library/court-decision-on-proposed-rule.pdf?sfvrsn=5967c92d_2 (last visited Feb. 18, 2026). In doing so, we concluded that existing rules were sufficient to deter misconduct related to generative AI use, without the need for a rule specific to generative AI. Federal Rule of Appellate Procedure 46(c), for instance, allows a court of appeals, after notice and an opportunity …

2026-02-17 · United States Bankruptcy Court for the District of Colorado · provisional

United States Bankruptcy Court for the District of Colorado on 2026-02-17 in McDowell et al. v. Turpen found the self-represented party's motion contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

not act with malice are factual disputes that are inappropriate for consideration on a motion to dismiss. D. Warning to Turpen Concerning Artificial Intelligence Turpen has elected to proceed in this case without counsel. He may do so, but he is warned that he will be held to the same standards as parties who appear …

2026-02-17 · United States District Court for the Northern District of California · provisional

Northern District of California on 2026-02-17 in In re: Social Media Adolescent Addiction Litigation found the expert's submission contained two citation defects involving mischaracterized authority. The court declined to exclude the expert but left the incorrect AI-generated citations for cross-examination.

9 based on a lack of reliable methodology or on hearsay grounds. 10 3. AI-Generated Citations 11 Defendants contend that Osborne admitted at deposition that articles upon which he 12 purportedly relied do not exist, and that other incorrect citations were miscites generated by AI. 13 Plaintiffs respond that none of the academic articles were …

2026-02-17 · Superior Court of California, Los Angeles County · 2026 WL 638479 · provisional

Superior Court of California, Los Angeles County on 2026-02-17 in Greenberg v. First Bank, Inc. found counsel cited a nonexistent AI-generated case about certificate-of-deposit surrender and misapplied People v. Wharton and AARTS Productions. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

In opposition, Plaintiffs argue that because they still possess all five original, uncancelled CDs, a presumption of nonpayment automatically applies under Comm. Code § 3104(j) and Evid. Code § 635. Plaintiffs also argue that triable issues of material fact remain over whether the CDs were ever paid, surrendered, cancelled, or rolled over. Plaintiffs further argue …

2026-02-17 · California Court of Appeal · 2026 WL 445097 · provisional

California Court of Appeal on 2026-02-17 in Alejandro Rios v. Puente Hills Ford found the self-represented party's brief contained three citation defects, including Osumi v. Sutton, Fiore v. Alvord and Stanley v. Univ, involving nonexistent authorities, fabricated or misattributed quotations. The court warned the self-represented party to verify legal authorities before future filings.

2 We take our facts from the complaint. 3 Rios cites “Stanley v. Univ. of Southern California (2022) 98 Cal.App.5th 151” for the proposition that a defendant's unilateral misunderstanding as to a plaintiff's intent is unenforceable against the plaintiff. He cites “Eustace v. Lynch (2012) 209 Cal.App.4th 1457” for the proposition that general releases must …

2026-02-17 · United States District Court for the Central District of California · provisional

Central District of California on 2026-02-17 found defense counsel attributed a quotation to Headley that the court could not locate and cited Dann for a proposition the court could not find. The court denied the motion to dismiss, granted judicial notice, and ordered defense counsel to produce authorities or explain why sanctions should not issue.

United States v. Dann, 652 F.3d 1160 (9th Cir. 2011) containing and highlighting all stated principles of law as cited in the Motion no later than 12:00 p.m., Pacific Standard Time, on February 19, 2026. IT IS FURTHERED ORDERED that, if he is unable to do so, Cabanday shall file with the Court an explanation …

2026-02-17 · United States District Court for the District of Arizona · 2026 WL 444958 · provisional

District of Arizona on 2026-02-17 in Nia Elan Davis v. American Airlines, et al. found the self-represented party's opposition cited a fictitious case, then withdrew the citation after the defendant requested dismissal as a sanction. The court granted the motion to dismiss, entered judgment for American Airlines, and did not impose sanctions after the plaintiff withdrew the fictitious citation.

third amended complaint. Davis responded to this motion Davis filed her original complaint on June 9, 2025. (Doc. 1.) and requested leave to amend if her complaint was found A little over one month later, Davis filed a “Motion to Accept insufficient. (Doc. 35 at 4.) Davis's opposition also contained Waiver of Service.” (Doc. 13.) …

2026-02-13 · United States District Court for the Western District of Washington · 2026 WL 411837 · provisional

Western District of Washington on 2026-02-13 in Merz v. City of Kalama found the self-represented party's briefing misused Caruso for a per se defamation point and gave an inaccurate Sorensen citation later corrected to Norg. The court granted the motions to dismiss and for judgment on the pleadings, struck improper notices, and dismissed all claims with prejudice.

comic book collection to the Kalama Public Library. In July (9) Outrage. Dkt. 27. 2021 the proffered donation was discussed at the library board meeting, which Merz attended (on Zoom). Merz alleges that he was made to feel unwelcome at this meeting, and that II. HOUSEKEEPING “Jenkins stated that Plaintiff was not an appropriate person …

2026-02-13 · United States District Court for the Eastern District of Pennsylvania · 2026 WL 413438 · provisional

Eastern District of Pennsylvania on 2026-02-13 in Nydia Rosario v. Liberty Mutual Personal Insurance Company found counsel's brief contained five citation defects, including Id. at *2-3, Kiessling v. State Farm and Santiago v. Warminster Twp, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to share the decision with the firm and address the citation-verification failure internally.

‘all reasonable inferences that can be drawn from’ those allegations ... and, construing the allegations and reasonable inferences ‘in the light most favorable to the [plaintiff]’..., we determine whether they ‘plausibly give rise to an entitlement to relief.’ ” Oakwood Lab'ys LLC v. Thanoo, 999 F.3d 892, 904 (3d Cir. 2021) (internal citations omitted). 15 …

2026-02-13 · United States District Court for the District of Massachusetts · 2026 WL 412550 · provisional

District of Massachusetts on 2026-02-13 in In re: Telexfree Securities Litigation found counsel's filing contained four citation defects, including Jensen v. Phillips Screw Co, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

purpose of securing Attorney Bonsignore's status as lead Furthermore, this is not the first time that Attorney counsel and (2) any evidence supporting Dos Santos’ claims Passatempo has misrepresented the law to this Court, and is so obviously absent from the record that her attorneys must such misrepresentations bear the clear hallmark of artificial have …

2026-02-13 · Kansas Court of Appeals · provisional

Kansas Court of Appeals on 2026-02-13 in Landmark Development Group, LLC v. Lonnie LuPardus found the self-represented party's expert submission contained three citation defects, including Meadors v. Feltor, Edwards v. Scholtzs and Wilson v. Gutschenritter, involving incorrect statutory or rule text. The court deemed the arguments unsupported or waived because the cited authorities were defective.

4 Dean, 56 Kan. App. 2d 770, 772-73, 437 P.3d 46 (2018) (citing King v. Stephens, 113 Kan. 558, 560, 215 P. 311 [1923]). If no transcript or adequate substitute is provided, we will not review any action of the trial court requiring us to examine the evidence. In re Marriage of Dean, 56 Kan. …

2026-02-13 · Government Accountability Office · provisional

Government Accountability Office on 2026-02-13 in G2 Ops, Inc. found counsel's response to dismissal cited nonexistent case law that GAO said bore hallmarks of AI or large-language-model use without verification. GAO denied the protest in part, dismissed it in part, and warned that future submissions with nonexistent authority may lead to sanctions.

The agency requested dismissal of the protest and in its response, the protester cited to certain cases in support of its argument against dismissal. After the intervenor requested clarification on these cited cases, the protester’s counsel acknowledged that the response included citations to non-existent caselaw. Electronic Protest Docketing System (EPDS) Docket Entries No. 21 Request …

2026-02-13 · United States District Court for the Southern District of Florida · 2026 WL 507533 · provisional

Southern District of Florida on 2026-02-13 in Lindsey Newell v. The Law Offices of Travis R. Walker, et al. found defense counsel's sanctions response included apparent AI hallucinations, later corrected after the court notified counsel of the problem. The magistrate judge recommended granting discovery sanctions in part and noted defendants corrected AI hallucinations after the court flagged them.

1 Defendants filed an opposed motion for another extension of the discovery deadline. DE 81. Judge Middlebrooks denied the Motion, finding Defendants had “not shown they ha[d] acted with diligence” and had not established why the broad discovery they sought was needed. DE 84. Therefore, the discovery period expired on December 28, 2025. 2 After …

2026-02-13 · United States Court of Appeals for the Tenth Circuit · 2026 WL 412348 · provisional

Tenth Circuit on 2026-02-13 in Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi found counsel's reply brief contained one citation defect, including Rodriguez-Romero v. Garland, 60 F.4th 1283 (10th Cir. 2023) and Rodriguez-Romero v. Garland, involving nonexistent authorities, fabricated or misattributed quotations. The court warned counsel to verify legal authorities before future filings.

Menera, 60 F.4th 1289 (10th Cir. 2023), which involved a they were targeted because of their familial relationship to criminal defendant's challenge to his sentence, see id. at 1291. “someone perceived as defiant to a criminal organization” Petitioners’ counsel relies on or quotes from this apparently because “the threats in this case followed [the] uncle's …

2026-02-12 · Supreme Court of North Dakota · 2026 WL 392303 · provisional

Supreme Court of North Dakota on 2026-02-12 in City of Dickinson v. Helgeson found the self-represented party's appellee brief contained 15 citation defects, including Olson v. City and Stenehjem v. FreeEats.com Inc, involving nonexistent authorities, mischaracterized authority. The court ordered the self-represented party to pay $500 for the defective authorities.

N.W.2d 811 2016 ND 198 N.W.2d 807, 811 N.W.2d 399 (Wis. Ct. App. 2016) [¶17] Like our sister states, we view the use of AI- [¶15] The record also shows Helgeson submitted false related technology as a means of improving access to citations to the district court. Helgeson does not defend or explain his use …

2026-02-12 · United States District Court for the Southern District of Indiana · 2026 WL 401066 · provisional

Southern District of Indiana on 2026-02-12 in Virgil v. Experian Information Solutions, et al. found counsel's brief contained 15 citation defects, including Myers v. Passport Health, 2013 WL 5819270, Schuh v. American Express Bank and Merriman v. Equifax Info. Servs, involving nonexistent authorities, fabricated or misattributed quotations. The court referred counsel to disciplinary authorities for the defective citations.

conduct was reasonable under the circumstances." Brown 175 F.R.D. 508, 510 n.1 (N.D. Ill. 1997). Confirming that v. Fed'n of State Med. Boards of the U.S., 830 F.2d 1429, a case is good law is a basic, routine matter and something 1435 (7th Cir. 1987) (collecting cases), overruled on other that is expected from a …

2026-02-12 · United States District Court for the District of Idaho · provisional

District of Idaho on 2026-02-12 in Seifert v. Nationstar Mortgage LLC, et al. found the self-represented party's response cited McGinnis v. GMAC Mortgage for propositions the court found fabricated or hallucinated. The court granted the dismissal motions and judicial-notice request, dismissed the complaint without prejudice, and allowed an amended complaint.

standing as government actors in their efforts.” Deville v. Specialized Loan Servicing, LLC, 2020 WL 13267725, at *5 (C.D. Cal. Sept. 9, 2020). Finally, the problems are not just substantive. Seifert’s Complaint appears to contain fabricated or hallucinated case citations. For example, Seifert cites “McGinnis v. GMAC Mortg. Corp., 2013 WL 1282124 (D. Colo.).” Dkt. …

2026-02-12 · Government Accountability Office · provisional

Government Accountability Office on 2026-02-12 in CVTEK, LLC (B-423943; B-423943.2) found counsel's filing contained two citation defects involving nonexistent authorities, mischaracterized authority, incorrect statutory or rule text. The court warned counsel to verify legal authorities before future filings in the challenged filing before resolving the pending matter.

intelligence) tool, CoCounsel, in preparing the supplemental protest. Resp. to GAO at 1. The protester’s attorneys expressly acknowledged that “some of the citations the AI tool indicates that he identified some irregularities and attempted to correct them, the attorney admittedly failed to correct all the erroneous citations in the final supplemental protest filed with our …

2026-02-12 · United States District Court for the Central District of California · 2026 WL 395737 · provisional

Central District of California on 2026-02-12 in TQJ, LLC v. Jennifer Esquivel et al. found counsel's brief cited four defective authorities, including Steele v. County of San Mateo, Kogan v. Martin, and a Muller citation the court could not locate. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

apparently even an awareness that they were present in the what steps to take with respect to the Motion and with respect brief—is equally troubling; it suggests he did not review the to sanctions. authority cited before he filed the Reply under his signature or before he appeared to argue the Motion. IT IS SO …

2026-02-12 · United States District Court for the District of Alaska · 2026 WL 396509 · provisional

District of Alaska on 2026-02-12 in Andre Legarza v. Northern Star (Alaska), Inc. found counsel's filing contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned counsel to verify legal authorities before future filings.

1 Docket 14. 2 Docket 20. 3 Docket 22. 4 Additionally, Defendants have provided a list identifying 17 cases cited by Plaintiff that “quote language that does not exist in the case,” including one where the language is correct but from a different case. Docket 23-1. The rapid development of artificial intelligence (“AI”) requires caution …