The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Docket entry 68, 7 July 2026 · source · PDF · 3 pages
Docket text. MEMORANDUM OPINION AND ORDER by Judge Greg N. Stivers on 7/7/2026. The Show Cause Order (DN 65 ) has been satisfied and the Court declines to impose sanctions. cc: counsel (KDY)
CHANDRESH PATEL et al. 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.
2023)). “Courts routinely impose Rule 11 sanctions for the submission of fabricated authority .” Nai v. Nat’l Asset Mortg., LLC, No.
11, 2026). At this point, 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 such fake, hallucinated cases in their briefs.” Sanders v. United States, 176 Fed.
Otherwise, a ttorney misuse of AI may result in a 3 “significant use of judicial resources to investigate the suspected artificial -intelligence improprieties [and] coordinate a response.” Id. at 923. Sister courts have readily imposed sanctions when attorneys continue to rely on nonexistent citations after being put on notice or have a history of similar misconduct. See, e.g. , Kettering Adventist Healthcare v.
25, 2026). Sanctions may be significant; for example, district courts have imposed monetary sanctions of up to $6,000 for hallucinated citations. Safe Choice, LLC v.
Docket entry 65, 28 May 2026 · source · PDF · 2 pages
Docket text. SHOW CAUSE ORDER by Judge Greg N. Stivers on 5/28/2026. Petitioners' counsel shall SHOW CAUSE in writing by 6/9/2026, why they should not be sanctioned pursuant to Fed. R. Civ. P. 11(b)(2) and (c), and the inherent power of the Court, for providing false citations, attributing apparently fictitious quotations to court decisions, and misrepresenting the holdings of various cases, apparently in reliance on AI-generated content. cc: counsel (KDY) (Entered: 05/28/2026)
CHANDRESH PATEL et al. RESPONDENTS SHOW CAUSE ORDER In reviewing Petitioners’ Response to Respo ndents’ Motion to Dismiss (DN 61) the Court has identified a ser ies of citations and quo tations that appear to be generative artificial intelligence (“AI”) hallucinations. In particular, the identified cases, citations, and/or quotations include: • Page 8 - Cummings v.
P. 11(b)(2) and (c), and the in herent power of the Court, for providing false citations, attributing apparently fictitious quotations to court decisions , and misrepresenting the holdings of various cases, apparently in reliance on AI -generated content. See, e.g., Mata v.
Mich. July 28, 2025) (“The court also notes that the mere fact that the cases themselves that counsel cited were not fictitious (rather, only the quotes or parentheticals) does not help matters; if anything, it highlights the risks of AI usage and reliance on these tools. When a case cite is ‘real,’ an attorney, or for that matter a judge, might see a case they recognize and assume the quote or holding has been accurately represented, where a case that an attorney does not recognize might, at least at first blush, trigger more exacting scrutiny.”) ; K y.
Thomas and Ms. Jocelyn and shall provide, among other things, a thorough explanation of how the referenced portions of Petitioners’ response came to cite case(s) that do not exist, cite quotations that do not exist, and cases that do not stand for the propositions cited, and what role, if any, Mr. Thomas and Ms.