Florida · federal district court · 2025

ROLLINS v. PREMIER MOTORCARS INC

District Court, N.D. Florida, 15 July 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · N.D. Fla.

  1. Court. District Court, N.D. FloridaCOURT
  2. Level. federal district courtLEVEL
  3. Date. 15 July 2025DATED
  4. Docket. No. 4:24-cv-00413DOCKET
  5. Judge. Mark Eaton WalkerJUDGE
  6. Documents. one document, 3 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

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 24, 15 July 2025 · source · PDF · 20 pages

Docket text. REPORT AND RECOMMENDATION - For the reasons discussed, it is respectfully RECOMMENDED that Defendants' amended motion to dismiss, ECF No. 19, be GRANTED, and this action be DISMISSED for failure to state a claim on which relief may be granted and for lack of subject matter jurisdiction. The dismissal of the state law claims should be without prejudice. Additionally, Plaintiff is ORDERED to file a response to this Court in writing no later than 7/28/2025 explaining how she conducted legal research for her response to the amended motion to dismiss (including the use of any AI platforms), how the inaccurate citations occurred, what if anything she did to validate the citations and stated holdings, and why sanctions under Rule 11 should not be imposed on her. Signed by MAGISTRATE JUDGE MARTIN A FITZPATRICK on 7/15/2025. (baf) R&R flag set. ( Internal deadline for referral to district judge if objections are not filed earlier: 8/12/2025.) (Entered: 07/15/2025)

23 at 4. Upon review, the reporter number is non-existent and there is no Supreme Court case with that title. There is an Eastern District of Michigan case with that title, but it involves an employment discrimination action.

23 at 6. The Court could not find any cases within the S tate of Florida named Hodge v. Citifinancial or Miller v.

163, 169 (2025) (collecting cases and explaining how “[f] ake cases generated by AI often have reporter citations that lead to cases with different names, in different courts, and about different subjects ”). “It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent Page 10 of 20 4:24-cv-413-MW-MAF 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.” Id. Plaintiff does properly concede that her claim for money damages under TILA is barred by the one-year statute of limitations.

What the text mentions

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Where this fits

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More from District Court, N.D. Florida, from Florida, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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