Published opinion, 22 October 2025 · source · PDF · 15 pages
VI. USE OF NONEXISTENT QUOTATIONS As Defendant observes, Plaintiff’s counsel, Donald Quinn, cites to nonexistent quotations at several points in Plaintiff’s opposition brief. See Def.’s Reply at 3 (noting that Plaintiff’s “opposition brief persistently attributes quotations to cases that do not contain the quoted material”); see also id. at 4 & n.1.
Mr. Quinn’s citations to nonexistent quotations bear the hallmarks of reliance on an artificial intelligence tool. See Williams v.
Mar. 18, 2025) (“Courts have recently seen increasing reliance on artificial intelligence in legal proceedings, leading to the use of nonexistent citations in court documents.”). Reliance on misquoted or nonexistent authorities in court filings is not acceptable: it contravenes an attorney’s duty toward his client to exercise professional judgment and responsibility.