Incident Tracker / United States (federal)
Maxwell v. Michael
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.
- Court
- United States District Court for the Southern District of Indiana
- Date
- 2026-05-26
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- The pro se plaintiff fabricated names, case numbers, citations, pincites, courts, and other identifying information for fake authorities at least thirty-seven times. The court imposed a $1,000 Rule 11 sanction for the fake citations.
- Outcome
- Fine
- Penalty
- US$1,000
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-08
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Maxwell v. Michael”, safelegalai.com/tracker/william-c-maxwell-v-dakota-michael-chelsey-smith (accessed 2026-10-07). Data: CC BY 4.0.