2025 Cases
In Med. Buyer's Grp. v. Pence, No. 25-cv-105, 2025 WL 3217751, at *1 (M.D. Ga. Nov. 18, 2025), the court addressed whether the plaintiff's counsel violated Rule 11(b)(2) by submitting briefs containing flawed case citations, including citations to non-existent cases and a case that did not support the cited proposition. The court ordered sanctions, which included a public admonishment of counsel and allowed the defendants to submit motions to recoup reasonable attorney fees incurred due to the flawed citations. Id. at *2. The court stated that no further monetary sanctions will be imposed in this case, and failure to comply with these terms may result in contempt. Id. After reviewing the defendants' requests, the court awarded $10,000 in attorney fees as sanctions for citing non-existent cases. Med. Buyer's Grp., No. 25-cv-105, 2026 WL 149949 (M.D. Ga. Jan. 20, 2026). In Cruz v. United States, No. 24-cv-1087, 2025 WL 3641170, at *1 (C.D. Cal. Dec. 16, 2025), the plaintiffs filed their opposition to the defendant's motion to exclude evidence late, without seeking leave for the untimely filing, and included a citation to a non-existent case, which they attributed to a calendaring error and a mistake by outside counsel. The court ordered the plaintiff's counsel to show cause to provide a written explanation regarding the potential sanctions. Id. Judgment entered in favor of the plaintiff; case terminated without further reference to show cause order. Cruz, No. 24-cv-1087, slip op. at 2 (C.D. Cal. Jan. 21, 2026), Dkt. 63. Following the grant of summary judgment in favor of the defendants, the court addressed its concerns regarding the plaintiff's filings, which contained fabrications and misrepresentations. Pauliah v. Univ. of Miss. Med. Ctr., No. 23-cv-3113, slip op. at 1 (S.D. Miss. Dec. 30, 2025), Dkt. No. 170. The court ordered sanctions against both the plaintiff and his former counsel. Id. at 8. Counsel was ordered to pay $4,000 and attend a CLE course on AI-generated hallucinatory citations. Id. The court ordered the plaintiff to pay $1,000. Id. In a dispute concerning a property acquired by the plaintiff through a probate sale, alleged that the Deed of Trust was void due to defects and claimed various violations and breaches, including quiet title and unfair trade practices. M.T. Real Est. Inv. Inc. v. Servis One, Inc., No. 25-cv-1372, 2025 WL 3771490, at *1-2 (D. Nev. Dec. 30, 2025). The defendants filed motions to dismiss the complaint and to strike the first amended complaint. Id. at *2. After reviewing several motions, the court sanctioned the plaintiff's attorney for citing five imaginary and invalid legal authorities. Id. at *3-4. The attorney admitted that the fabrications were generated by AI used by his paralegal. Id. at *3. The court imposed the following sanctions: striking the plaintiff's responsive briefs, awarding the defendants all reasonable attorney fees and costs, ordering the attorney to serve a copy of this order on the plaintiff, and directing the clerk to serve a copy of the order on the state bar. Id. at *7. In resolving the case, the court found that these sanctions were "the least severe necessary to satisfy Rule 11(c)(4)." Id. at *4. Finally, the court granted the defendants' motion to strike the first amended complaint, denied as moot the motion to dismiss first amended complaint, granted the motion to dismiss the complaint, and dismissed the plaintiff's complaint with prejudice. Id. at *7. In Hanson v. Nest Home Lending, L.L.C., No. 25-cv-2599, 2025 WL 3312165, at *1 (D. Colo. Nov. 28, 2025), the magistrate judge addressed whether the pro se plaintiffs violated Rule 11 by including fabricated legal citations in their filings. Ultimately, the magistrate found that the plaintiffs' conduct was not objectively reaasonable and constituted a Rule 11 violation due to their reliance on inaccurate and non-existent legal authority. Id. at *4. As a result, the magistrate recommended sanctions, including striking certain filings, requiring the plaintiffs to submit a detailed certification with future filings, and referring them to the Federal Pro Se Clinic for legal research resources. Id. at *4-5. In considering whether to sanction the plaintiffs, the court found that their conduct was not objectively reasonable and constituted a Rule 11 violation due to their reliance on inaccurate and nonexistent legal citations. Hanson, No. 25-cv-2599, 2025 WL 3312165, at *2 (D. Colo. Nov. 28, 2025). As a result, the magistrate judge recommended that the plaintiffs be sanctioned by striking their problematic filings and requiring them to submit, with future filings, a detailed certification verifying the accuracy of their citations. Id. at *4-5. The district judge subsequently adopted and affirmed the recommendation. Hanson, No. 25-cv-2599, slip op. at 3-4 (D. Colo. Dec. 23, 2025). In Allen v. Amazon, No. 24-cv-2846, 2025 WL 3719889, at *1 (N.D. Tex. Dec. 23, 2025), the pro se plaintiff filed motions against the defendant in response to subpoenas served on three non-parties. The court denied the motion to compel and granted in part and denied in part the motion to modify subpoenas and for a protective order. Id. Additionally, the defendant argued that the plaintiff's motion to compel should be stricken because he failed to disclose the use of AI in preparing his brief, as required by local rule. Id. at *2. The plaintiff did not dispute his use of AI or the lack of disclosure. Id. The court declined to sanction the plaintiff at this time, given his pro se status and the absence of prior warnings, but cautioned him that future non-compliance could result in sanctions. Id. In a pro se civil rights action, the plaintiff brought nine claims, including violations of constitutional rights under 42 U.S.C. § 1983, a claim under 42 U.S.C. § 1985, and pendent state law claims. Smith v. Smith, No. 25-cv-1077, 2025 WL 3706691, at *1 (N.D.N.Y. Dec. 22, 2025). The magistrate judge recommended dismissing the constitutional claims against two defendants with prejudice, dismissing the claims against two other defendants without prejudice, and declining to exercise supplemental jurisdiction over state law claims. Id. The plaintiff filed objections to the recommendation and an amended complaint, which added new defendants and causes of action. Id. The district judge addressed whether the objections raised by the plaintiff warranted a de novo review of the magistrate judge's recommendations. Id. at *2. The district judge found that the plaintiff's objections were based on fictitious case law, likely generated by AI, and thus did not require de novo review. Id. at *2-3. The district judge adopted the recommendations in their entirety, referred the amended complaint for review, and denied the plaintiff's motion for reconsideration of a previous order denying emergency relief. Id. at *1. Notably, the district judge warned the plaintiff against using AI-generated legal content, highlighting the potential for sanctions if AI misuse continued. Id. at *5. In an age discrimination case, the plaintiff's counsel submitted a memorandum containing fabricated case citations and misrepresentations of case holdings, which resulted from the use of unverified AI. Billups v. Louisville Mun. Sch. Dist., No. 24-cv-74, 2025 WL 3691871, at *1 (N.D. Miss. Dec. 19, 2025). The court found that the attorneys involved used Grok to assist in drafting and research without verifying the accuracy of the output. Id. at *1-2, *4. The court imposed sanctions on the attorneys and the firm. Id. at *10. The sanctions included disqualifying the attorneys from further participation in the case, requiring them to provide a copy of the sanctions order to all presiding judges in every pending case where they are counsel of record, and mandating an internal audit of all substantive filings in this case. Id. The firm was also ordered to submit a report of the audit to the court. Id. In Disability Rights Mississippi v. Palmer Home for Children, No. 24-cv-99, 2025 WL 3691876, at *1 (N.D. Miss. Dec. 19, 2025), the plaintiff filed legal memoranda containing fabricated case citations and non-existent quotes attributed to existing cases. The court issued a show cause order, questioning why sanctions should not be imposed on the plaintiff's counsel. Id. The court found that counsel violated Rule 11 by failing to conduct a reasonable inquiry into the legal authorities she cited, as she admitted to not reading the cases before citing them. Id. at *6. Importantly, the court also found that counsel acted in bad faith by citing fabricated legal authority and making misrepresentations in her filings. Id. at *12. Consequently, the court imposed both monetary and non-monetary sanctions on counsel, including ordering her to pay attorney fees and costs to the defendant and attend a continuing legal education course on AI-generated hallucinatory citations. Id. at *20-21. The court directed counsel to pay $20,883.10 to the defendant. Id. at *22. In reaching a conclusion, the court did not find any bad faith on the part of the plaintiff, and that counsel's bad faith could not be imputed to the plaintiff to justify sanctions against it. Id. at *20. In a pro se action, the plaintiff alleged wrongful termination, gender discrimination, hostile work environment, workplace negligence, and negligent misrepresentation against the defendants. Fantini v. Westrock Co., No. 22-cv-4351, 2025 WL 3688000, at *1-2 (D.N.J. Dec. 19, 2025). The court granted the defendants' motion for summary judgment and denied the plaintiff's cross-motion for summary judgment. Id. at *3-7. In reaching its conclusion, the court highlighted procedural deficiencies in the plaintiff's submissions, including references to non-existent case law, which could result in sanctions under Rule 11 for failing to reasonably investigate the legal claims. Id. at *3 n.5. In a mandamus proceeding, the pro se petitioners sought to compel the trustee in their bankruptcy case to perform certain actions and to void their mortgage contract. Gerou v. George, No. 25-cv-1160,2025 WL 3677745, at *1 (E.D. Wis. Dec. 18, 2025). The court found that it did not have jurisdiction to issue a writ of mandamus against the respondents, as neither the private attorneys nor the United States are considered officers or employees of the United States, as required by 28 U.S.C. § 1361. Id. at *7. Accordingly, the court dismissed the petition for failure to state a claim and denied the petitioners' motion to dismiss the adversary proceeding, as there was no adversary proceeding in the district court to dismiss. Id. at *8-9. With respect AI implications, the court addressed issues with the petitioners' "dead-horse petition," which contained multiple direct quotes and case citations that were inaccurate or did not exist. Id. at *7. The court noted the risks associated with GAI applications, which can produce inaccurate or false case citations, and warned that future filings containing such inaccuracies could result in monetary sanctions. Id. at *8. In a pro se bankruptcy proceeding, the court addressed whether the debtors should be sanctioned for failing to comply with Federal Rule of Bankruptcy Procedure 9011, as their filings contained false or misleading case citations. In re Bryant, No. 25-bk-10147, 2025 WL 3237890, at *1 (Bankr. M.D.N.C. Nov. 19, 2025). The court found that several of the debtors' filings requested duplicative relief and contained false or misleading case citations, likely the result of hallucinations from GAI. Id. the court explained that "even unrepresented litigants are required to independently verify that the cases represented therein exist and support the proposition for which they are cited." Id. at *3. The court ordered the debtors to show cause why sanctions should not be imposed, "[s]uch sanctions may include monetary sanctions, striking of documents from the record, and denial of relief requested in violative documents." Id. The court declined to impose sanctions, considering the debtors' pro se status and their attempts to remedy the violations by withdrawing certain filings and expressing contrition. In re Bryant, No. 25-bk-10147, slip op. at 4 (Bankr. M.D.N.C. Dec. 17, 2025), Dkt. No. 167. However, the court warned that continued filing of duplicative or frivolous motions could result in sanctions, including monetary penalties or requiring filings to be signed by a licensed attorney. Id. at 5. The court also outlined potential conditions for future filings, such as requiring printouts of cited cases and limiting the length of filings. Id. at 6. In Dodge v. FirstService Residential Ariz. LLC, No. 24-cv-1550, 2025 WL 3653164, at *1 (D. Ariz. Dec. 17, 2025), the court addressed whether sanctions should be imposed on the plaintiff's attorney for violating Rule 11 due to citation-related deficiencies in a court filing. The court found numerous issues with the brief, including misrepresented case holdings, misquoted cases, and a citation to a non-existent case. Id. The attorney admitted to using an AI application called "Federally Lawyer," an add-on to ChatGPT, for research and drafting, and acknowledged that he did not independently verify the AI-generated citations before submission. Id. at *3. The court declined to impose severe sanctions on the attorney, recognizing his open admission of the improper use of AI and his efforts to self-report to the state bar. Id. Significantly, the court found that the citation deficiencies did not prejudice the plaintiff, as the case was dismissed on its merits, and the attorney did not collect any fee due to the contingency fee arrangement. Id. The court encouraged the attorney to participate in educational seminars on the legal applications of AI and decided that no further sanctions were necessary. Id. In closing, the court opined that "the public humiliation in this matter [was] a sufficient remedy." Id. In Lewis v. Eagle Cnty., No. 25-cv-2269, 2025 WL 3639608, at *1 (D. Colo. Nov. 14, 2025), the plaintiff alleged that the defendant violated the Fair Labor Standards Act by misclassifying certain employees, including those performing Aircraft Rescue and Firefighting duties, as exempt from overtime pay under the firefighter exemption, despite not primarily engaging in firefighting activities. The court addressed whether the plaintiff's counsel violated Rule 11 by submitting pleadings with non-existent case citations and whether sanctions were warranted under Rule 11 and 28 U.S.C. § 1927. Id. at *3, *6. The court found that the submission of the original complaint, the first amended complaint, and the proposed second amended complaint all violated Rule 11 due to the inclusion of fictitious case citations and other legal errors. Id. at *8. The court sanctioned counsel and her law firm in the amount of $3,000 and awarded reasonable attorney fees to the defendant under 28 U.S.C. § 1927. Id. The case was dismissed without prejudice following the plaintiff's notice of voluntary dismissal. Id. at *10. The court subsequently entered the parties' stipulation on attorney fees in the amount of $25,000. Lewis, No. 25-cv-2269, slip op. at 1-2 (D. Colo. Dec. 16, 2025). This case involved a tragic car crash that resulted in the death of Damion Farmer following a high-speed pursuit by police officers. Taylor v. Prince George’s Cnty., No. 22-cv-1129, 2025 WL 3640370, at *1 (D. Md. Dec. 16, 2025). The plaintiffs (Farmer's parents) filed a wrongful death and survival action against Prince George's County and police officers, alleging that the defendants caused the crash. Id. at *1-2. The claims included wrongful death, survival claims of assault, battery, intentional infliction of emotional distress, and gross negligence, as well as a Monell claim against the County for failure to train its officers. Id. at *2. The issue before the magistrate judge was whether the defendants were entitled to attorney fees under 42 U.S.C. § 1988, allowing for fees to be awarded to a prevailing party in certain civil rights cases. Id. at *3. The defendants argued that the plaintiffs' claims were frivolous and without basis, as the video evidence they provided refuted the claims. Id. However, the magistrate judge found that the plaintiffs' claims were not frivolous, unreasonable, or without foundation, despite the lack of success, and recommended denying the motion for attorney fees. Id. at *4-5. The magistrate judge emphasized that awarding fees to defendants was rare and should not discourage future civil rights plaintiffs from pursuing meritorious claims. Id. Additionally, the magistrate judge noted that the plaintiffs' response brief contained multiple citation errors, which were characteristic of errors made by GAI tools. Id. at *5. The magistrate judge chose not to recommend any action concerning the AI misuse, but pointed out the errors for the district judge's consideration. Id. In Gardner v. Combs, No. 24-cv-7729, 2025 WL 3632704, at *1 (D.N.J. Dec. 15, 2025), the court found that the plaintiff's counsel cited a non-existent case and fabricated legal propositions derived from GAI in support of the plaintiff's opposition to the defendants' motions to dismiss. The court imposed monetary and non-monetary sanctions on counsel, including a $6,000 fine and requirements to self-report the order to show cause and the court's opinion to the attorney licensing entities in New Jersey and New York. Id. at *4. In an insurance coverage action, the pro se plaintiff filed a claim against the defendant for refusing to pay the full amount due. Fockele v. State Farm Fire & Cas. Co., No. 24-cv-39, 2025 WL 3903948, at *1 (E.D. Ky. Dec. 15, 2025). The plaintiff filed a complaint in state court, which was later removed to federal court. Id. The issue before the magistrate judge was whether an enforceable settlement agreement was reached between the parties during mediation. Id. The court concluded that all elements of a valid contract were met, including offer, acceptance, and consideration, and that the agreement was clear and unambiguous. Id. at *3-4. Accordingly, the magistrate judge recommended enforcing the settlement agreement. Id. at *4. Additionally, the defendant filed a motion to strike the plaintiff's response due to her use of AI, which resulted in citations to non-existent case law. Id. The court granted the motion to strike, emphasizing the duty of candor required in court representations, even for pro se litigants. Id. at *5. The court warned the plaintiff that continued use of AI in this manner could lead to sanctions. Id. In a pro se action, the plaintiff (who was on probation) filed a lawsuit against his probation officer, alleging sexual assault during a search. Braica v. Frankowski, No. 24-cv-1709, 2025 WL 3644231, at *1 (D. Conn. Dec. 15, 2025). The defendant moved for partial dismissal of the claims related to cruel and unusual punishment and negligent infliction of emotional distress. Id. During the briefing, the court addressed whether sanctions should be imposed on the plaintiff under Rule 11 due to the submission of briefs containing AI-generated hallucinations, including fabricated case law, fictitious quotes, and misstatements of law. Id. The court identified ten instances of hallucinated cases within the plaintiff's filings. Id. at *1-2. The court opined that the plaintiff "acted in subjective bad faith to violate Rule 11 by repeatedly relying on AI-generated hallucinations and ignoring every opportunity to correct his briefs." Id. at *6. The court admonished the plaintiff and struck the briefs containing AI-generated hallucinations from the record. Id. at *1. The court warned that more stringent sanctions, including dismissal of the case, could be imposed if AI-generated hallucinations were found in future filings. Id. at *6. In a pro se action, physicians from the Department of Veterans Affairs (the petitioners) raised concerns about their supervisor, the competence of their colleagues, and alleged gross mismanagement within the agency. Kulkarni v. Merit Sys. Prot. Bd., No. 2025-1597, 2025 WL 3627611, at *1 (Fed. Cir. Dec. 15, 2025). The court addressed whether the petitioners made non-frivolous allegations of protected disclosures, which would establish jurisdiction before the Board. Id. at *2. The court affirmed the Board's decision, agreeing that the petitioners' allegations did not meet the necessary criteria for non-frivolous allegations. Id. at *3. Additionally, the court noted that the petitioners' reply briefs contained multiple citations to non-existent cases and mischaracterizations of existing cases, suggesting the use of AI-generated content. Id. The court criticized this conduct and granted the Board's motions to strike the petitioners' informal reply briefs. Id. In a RICO case, the court ordered the plaintiffs to show cause why they should not be sanctioned for the misuse of AI in the following oppositions to several of the defendants’ pending motions. N.Z. v. Fenix Int'l Ltd., No. 24-cv-1655 (C.D. Cal. Sep. 4, 2025), Dkt. No. 187. The court directed the plaintiffs to respond in writing by September 18, 2025, for the show cause hearing scheduled for September 25, 2025. Id. Ultimately, the court denied the plaintiffs' motion to withdraw and correct the briefs, finding that permitting corrective briefing would not remedy the harm caused by the AI misuse and would exacerbate prejudice to the defendants. Fenix, No. 24-cv-1655, slip op. at 4-5 (C.D. Cal. Dec. 12, 2025), Dkt. No. 207. The court found that the plaintiffs' counsel violated Rule 11 by submitting briefs with unverified and erroneous legal content attributed to generative AI, as well as for failing to exercise reasonable supervision. Id. at 7. The court imposed monetary sanctions: $10,000 jointly and severally against lead counsel and the law firm, and $3,000 against co-counsel. Id. at 8. Further, the court ordered remedial and reporting obligations, including notification of this order to the relevant state bar associations. Id. at 9. See Craig Clough, OnlyFans Users May Face Sanctions Over AI 'Misuse' (Sep. 5, 2025). In Couvrette v. Wisnovsky, No. 21-cv-157, slip op. at 1 (D. Or. June 16, 2025), Dkt. No. 189, the court previously warned the plaintiffs about non-compliance with local rules, which could lead to denial or dismissal of the case. Subsequent filings by the plaintiffs included inaccurate citations and misrepresented quotations, calling for the court to review alleged violations of both local and federal rules. Id. at 1-2. In response, the plaintiffs’ counsel asserted that the inclusion of inaccurate citations was unintentional and stemmed from reliance on an automated legal citation tool. Id. at 1. The court set a hearing for the plaintiffs to show cause why sanctions should not be imposed, and this action should not be dismissed. Id. at 2. In a subsequent scheduling order, the court stayed the proceedings pending a recent emergency notice filed by the plaintiff. Couvrette, No. 21-cv-157 (D. Or. July 8, 2025), Dkt. No. 195. A health issue caused the hold for the case, but in a subsequent joint status report, the defendants asserted that the absence of the plaintiff's counsel should not impede the defendants’ motion for sanctions from being decided on the merits. Joint Status Report at 1, 5, Couvrette, No. 21-cv-157 (D. Or. Aug. 11, 2025), Dkt. No. 196. Subsequently, the court denied the motion to withdraw filed by the attorney and ordered the attorney not to file any motions or other filings on behalf of the plaintiff, pending the resolution of the motion for sanctions. Couvrette, No. 21-cv-157 (D. Or. Sep. 2, 2025), Dkt. No. 212. Eventually, the court struck the plaintiffs' summary judgment briefs and amended filings without leave to refile, imposed a penalty of $15,500, and dismissed the plaintiffs' claims with prejudice. Couvrette, No. 21-cv-157, slip op. at 28-29 (Dec. 12, 2025), Dkt. No. 215. The court also awarded the defendants attorney fees for expenses related to the plaintiffs' violation, dating back to filings from January 31, 2025. Id. at 28. In House v. TH Foods, Inc., No. 24-cv-1326, 2025 WL 3552382, at *1 (D. Nev. Dec. 11, 2025), the pro se plaintiff objected to the magistrate judge's order that reopened discovery, compelled him to execute a HIPAA authorization, and required him to undergo a mental-health examination under Rule 35. The district judge overruled the plaintiff's objections, finding that he had not demonstrated any error in the magistrate judge's decisions. Id. The district judge also denied the parties' motions for summary judgment without prejudice, as discovery was still ongoing. Id. Additionally, the magistrate judge admonished House for using AI-generated or hallucinated case citations in his briefs. Id. at *3. The district judge confirmed that many of the cases the plaintiff cited were non-existent or misquoted, and reminded him to verify the authority relied on in his briefing. Id. The district judge warned that continued failure to ensure the accuracy of citations could result in sanctions. Id. In McLain v. Bd. of Cnty. Comm'rs of Sedgwick Cnty., No. 25-cv-4036, 2025 WL 3550614, at *1 (D. Kan. Dec. 11, 2025), the pro se plaintiffs alleged discrimination and civil rights violations. The court granted one of the defendants' motion to dismiss, finding that the plaintiffs failed to adequately plead their claims. Id. at *10. In reaching its conclusion, the court suspected that the plaintiffs used AI to formulate their briefing. Id. at *7 n.1. The court warned the plaintiffs to validate the information to avoid violating their duty of candor to the court. Id. In a pro se action, the plaintiff filed a lawsuit against the defendants, alleging wrongful termination from his employment as a wine consultant and sommelier. Fahey v. Wally’s Las Vegas, L.L.C., No. 25-cv-1044, 2025 WL 3552697, at *1 (D. Nev. Dec. 10, 2025). In a discovery dispute, the court granted the defendants' motion to compel, requiring the plaintiff to produce the requested documents, and denied his request for a protective order. Id. at *5. A significant aspect of the case involved the plaintiff's use of AI, who cited non-existent case law in his response. Id. at *4. The court identified the citations as AI hallucinations, warning that the plaintiff was expected to verify all authorities cited in his filings and mentioned the possibility of sanctions for using nonexistent citations. Id. In Gottlieb v. Adtalem Glob. Educ., No. 25-cv-7752, 2025 WL 3539213, at *1-2 (N.D. Ill. Dec. 10, 2025), the court addressed whether the pro se plaintiff submitted a fraudulent document to the court, which would constitute a fraud upon the court and potentially warrant sanctions, including dismissal of the case with prejudice. After reviewing the record, the court ordered the plaintiff to show cause why he should not be sanctioned with dismissal and why the defendant should not be awarded its fees and costs. Id. at *2. Plaintiff voluntarily dismissed the case; the defendant declined to pursue attorney fees and costs; and the court dismissed the case with prejudice. Gottlieb, No. 25-cv-7752, slip op. at 1 (N.D. Ill. Dec. 30, 2025), Dkt. No. 96. In Parker v. Costco Wholesale Corp., No. 25-cv-519, 2025 WL 2481280, at *1 (W.D. Wash. Aug. 28, 2025), the plaintiff brought various claims against her former employer. The issue before the court involved the conduct of the plaintiff's attorney for defective court filings. Id. The court identified material misstatements and misrepresentations in the plaintiff's filings, including hallucinated case and record citations and legal errors consistent with unverified GAI outputs. Id. The court determined that the plaintiff's summary judgment response brief was flawed due to reliance on inapplicable law, misrepresentation of legal standards and the record, citation errors, misquotations from cases, and undisclosed typographical variations from original sources. Id. at * 1-2. The court observed that the plaintiff's motion to strike and reply seemed to be generated by a GAI program lacking quality control, as evidenced by typographical errors and unsupported legal arguments, while the plaintiff's motion for leave to file an amended complaint misapplied the correct legal standard and cited irrelevant state rules. Id. at *3. The court opined: The errors addressed above are only a sampling. Taken together, they form a pattern that indicates Counsel may have used AI to generate filings without confirming the accuracy of authority relied upon, existence of evidence cited, or defensibility of positions taken. If AI was not used, these filings indicate wholesale inability to identify and marshal applicable law and a degree of sloppiness that severely impaired the briefs’ utility to [the plaintiff] and the Court. Id. at *4. The court ordered the attorney to show cause as to why the court should not impose sanctions. Id. Later, the court imposed sanctions on the plaintiff's attorney. Parker, No. 25-cv-519, slip op., at 25-26 (W.D. Wash. Nov. 7, 2025), Dkt. 60. The court publicly reprimanded the attorney and referred the matter to the Chief Judge for an ethical inquiry. Id. at 22. Additionally, the attorney was ordered to pay $3,000 in sanctions to the court and to compensate the defendant for expenses incurred in responding to his motion to strike. Id. at 24. The court also required the attorney to meet with opposing counsel to agree on the attorney fees incurred and to provide a copy of the order to the plaintiff. Id. at 26. The parties jointly agreed that the defendant’s reasonable attorney fees were $3,220.50. Parker, No. 25-cv-519, slip op., at 1 (W.D. Wash. Dec. 8, 2025), Dkt. 70. In Gittemeier v. Liberty Mut. Pers. Ins. Co., No. 24-cv-1236, 2025 WL 2939128, at *1 (E.D. Mo. Oct. 16, 2025), the court addressed the defendant's second motion for summary judgment and the plaintiff's motion for sanctions. The court found that a question of fact existed, precluding summary judgment. Id. at *6. With respect to the motion for sanctions, the plaintiff asserted that the defendant miscited cases in its filing and referenced at least one non-existent citation. Id. The court found that the defendant’s repeated citation of non-existent cases and misrepresentation of legal authorities constituted a serious oversight warranting potential Rule 11 sanctions. Id. at *7. Despite a prior warning, the defendant again cited fictitious cases and inaccurately referenced others, including a secondary source. Id. The court emphasized that such conduct undermines the integrity of judicial proceedings. Id. The court acknowledged that the defendant subsequently submitted a notice of errata identifying the erroneous citations and demonstrating legitimate citations to those cases. Id. Notwithstanding the defendant's prompt notice disclosing the two most serious errors in its filing, the additional misquotations and mischaracterizations will not be disregarded. Id. While the defendant claimed that the errors were due to typos or vision impairment, but the court found that the explanation lacked credibility. Id. According to the court, the filing contained major inaccuracies—including incorrect names, dates, court designations, and citations—that go far beyond minor typographical mistakes. Id. The court reserved its ruling and set a show cause hearing for October 22, 2025. Id. In the subsequent ruling, the court found that the errors were due to human error, not AI, but were nonetheless unacceptable. The court granted the plaintiff's motion for sanctions in part, awarding attorney fees and imposing a $1,000 penalty on the defendant's counsel. Gittemeier, No. 24-cv-1236, 2025 WL 3206484, at *3 (E.D. Mo. Nov. 17, 2025). The court denied the request to strike the defendant's affirmative defenses. Id. The court directed the plaintiff to submit documentation in support of an award of attorney fees and costs associated with the defendant's citation errors. Id. at *4. The plaintiff submitted a request for $3,725 in attorney fees. Affidavit of Attorneys' Fees at 1-2, Gittemeier, No. 24-cv-1236 (E.D. Mo. Nov. 26, 2025), Dkt. No. 87. Eventually, the court awarded the plaintiff $3,725 in attorney's fees. Gittemeier, No. 24-cv-1236, slip op. at 2 (E.D. Mo. Dec. 8, 2025), Dkt. No. 113. In Yarn v. Trader Joe's, No. 25-1403, 2025 WL 3496784, at *2 (D. Or. Dec. 5, 2025), the court addressed whether the plaintiffs' amended complaint sufficiently stated claims for relief under the alleged causes of action. The court found that the plaintiffs did not adequately plead the relevant terms of the contract or how the defendant breached it, failed to demonstrate the falsity of the alleged defamatory statements, did not show that the defendant's conduct was an extraordinary transgression for IIED, and did not plausibly allege that the defendant was a state actor for the First Amendment claim. Id. at *3-5. Ultimately, the court granted the defendant's motion to dismiss the complaint but allowed the plaintiffs leave to amend their complaint to address the deficiencies. Id. at *5. In reaching a conclusion, the court noted that the plaintiffs cited a non-existent case, which may have been generated by an AI tool. Id. at *3 n.2. The court noted that the plaintiffs’ citation was the subject of an order to show cause why the court should not impose sanctions, filed contemporaneously with the defendant's motion to dismiss. Id. In a docket entry, the court decided that a warning was sufficient in these circumstances. Yarn, No. 25-1403 (D. Or. Dec. 12, 2025), Dkt. No. 21. In a bankruptcy adversary proceeding, the plaintiff trustee sought to recover property that had been fraudulently conveyed to the defendant. In re Nupeutics Natural, Inc., No. 22-bk-2956, 2025 WL 3546838 (Bankr. S.D. Cal. Dec. 5, 2025). An issue arose when the defendant filed a motion using GAI, and counsel failed to verify the AI-generated case citations. Id. at *1. This led to a violation of Rule 9011, as the motion was filed with erroneous and non-existent legal citations. Id. Counsel compounded the issue by not being transparent with the court about her reliance on AI and the inaccuracies in the motion. Id. The court issued a show cause order to determine whether sanctions should be imposed on the counsel for her conduct. Id. at *2. After a hearing, the court found that the counsel acted in bad faith or conduct tantamount to bad faith by filing the motion without verifying the AI-generated legal citations and through subsequent misrepresentations to the court. Id. at *15. The court imposed sanctions on the counsel, including a monetary penalty and requirements for continuing legal education. Id. at *16. Specifically, the court ordered counsel to pay a penalty of $950 and to complete eight hours of CLE. Id. The court also revoked counsel's CM/ECF privileges in bankruptcy court for a period of two years. Id. In Hill v. Oklahoma County Crim. Just. Auth., No. 24-cv-1298, 2025 WL 3490507, at *1 (W.D. Okla. Dec. 4, 2025), the district judge addressed whether the plaintiff's counsel should be sanctioned for citing non-existent cases, which he attributed to the use of ChatGPT to draft legal documents. The magistrate judge previously recommended sanctions due to counsel's pattern of conduct, including missing deadlines and filing incorrect documents. Id. The district judge adopted the magistrate judge's recommendations, ordering counsel to pay the defendants' reasonable attorney fees and costs, disclose the use of GAI in future pleadings, and complete CLE in ethics and legal technology. Id. at *1-2. The district judge warned counsel that if counsel should cite to non-existent, AI-generated cases in the future, additional sanctions will be imposed. Id. at *2 n.2. In Black Oak Cap. Boca L.L.C. v. Paul Evans, L.L.C., No. 24-cv-209, 2025 WL 3485757, at *1 (D. Utah Dec. 4, 2025), the plaintiff filed a motion for sanctions under Rule 11 against the defendants, arguing that the defendants' filings, including the Second Amended Counterclaim, violated Rule 11 by being filed without leave and including claims that were unwarranted under the law and facts. The court found that the defendants' filing of the opposition brief violated Rule 11 due to the inclusion of citations to non-existent cases. Id. at *4-5. However, the court did not find the other filings to be in violation of Rule 11. Id. The court granted in part and denied in part the plaintiffs' motion for sanctions. Id. at *6. Ultimately, the court imposed a non-monetary sanction on the defendants' counsel, requiring him to read all the cases and authorities cited in the opinion and file a summary statement certifying that he has done so. Id. In an action stemming from a traffic stop, the pro se plaintiff alleged the defendant police officers unlawfully seized him, used excessive force, conducted an unlawful search, and prolonged his detention, among other allegations. Dorsey v. Ponce, No. 25-cv-1212, 2025 WL 3484962, at *1, *5 (N.D. Ill. Dec. 4, 2025). After reviewing a motion to dismiss under Rules 12(b)(1) and (6), the court granted the motion in part and denied it in part. Id. at *1, *8. In short, the plaintiff's claims for unlawful search and prolonged detention under the Fourth Amendment survived, as does his state law claim for trespass to chattels; however, his other claims, including those for unlawful seizure, excessive force, First Amendment retaliation, failure to intervene, conspiracy, and other state law claims, were dismissed. Id. at *8. In reaching a conclusion, the court noted that the plaintiff's filings contained numerous incorrect or non-existent legal citations, raising suspicions of AI misuse. Id. at *3 n.4. The court warned the plaintiff against using fabricated or hallucinated case citations in future filings, indicating potential sanctions for such conduct. Id. In an action arising from child support proceedings, the pro se plaintiff alleged violations of the Constitution and several federal laws. Allston v. DeSantis, No. 24-cv-1085, 2025 WL 3484765, at *1 (M.D. Fla. Dec. 4, 2025). Additionally, the plaintiff claimed that the defendants engaged in a conspiracy to interfere with his civil rights in retaliation for filing the suit. Id. The issue before the district judge was whether the plaintiff's second amended complaint should be dismissed as a shotgun pleading. Id. The magistrate judge recommended dismissing the complaint on these grounds, and the district judge agreed, finding that the complaint was indeed a shotgun pleading. Id. at *3. The disposition of the case was that the second amended complaint was dismissed without prejudice, allowing the plaintiff to file a third amended complaint to correct the deficiencies. Id. In reaching a decision, the district judge also addressed the issue of false or fabricated legal authority in the plaintiff's filings. Id. at *5. The district judge did not believe that sanctions were appropriate at this time, given the plaintiff's pro se status and the possibility that the plaintiff was unaware of the consequences of his actions. Id. Accordingly, the district judge gave the plaintiff the benefit of the doubt, but was now on notice off the risks associated with using AI. Id. at *6. The district judge warned the plaintiff that any future submissions citing non-existent cases or making similar misrepresentations could lead to sanctions, possibly including the dismissal of this case with prejudice. Id. In a post-sentencing proceeding, the defendant moved for clarification of his supervised release conditions, particularly concerning the requirement to install computer monitoring software on his devices. United States v. Boehm, No. 18-cr-312, 2025 WL 3473292, at *1 (M.D. Pa. Dec. 3, 2025). The court dismissed the defendant's motion without prejudice, admonishing him for misrepresenting and misquoting Third Circuit precedents in his filings. Id. at *4. The court noted that the defendant's motion appeared to rely on generative AI tools, which included false quotations and misrepresented legal arguments. Id. at *2. Accordingly, the court required the defendant to disclose any future use of AI in his filings, including the specific AI tool used and how it was applied, along with a certification of the accuracy of legal citations. Id. at *4. In Hatfield v. Pirani, No. 22-cv-5110, 2025 WL 1950112, at *1 (W.D. Ark. July 16, 2025), the court addressed several motions filed by the plaintiff, one of which implicated the use of AI. The defendant admitted to using AI to draft motions in limine that contained citations to non-existent cases and quotations of non-existent passages. Id. The court found this to be a Rule 11 violation and struck the offending filings. Id. The court opined that further sanctions against the defendant will be considered after the trial, including monetary sanctions and referral to the state's Judiciary Office of Professional Conduct. Id. The court has not yet issued a written opinion or order regarding sanctions, as of August 27, 2025. Subsequently, the court imposed sanctions on the defendant for violations of Rule 11(b)(2), including a $1,000 fine and restrictions on his ability to enter new appearances as counsel in the Western District of Arkansas until the fine is paid. Hatfield, No. 22-cv-5110, slip op. at 12-13 (W.D. Ark. Dec. 3, 2025), Dkt. 451. Additionally, the court found that striking the filings was insufficient as a sanction and imposed the aforementioned penalties to deter similar misconduct. Id. at 11-12. In Farrow v. Does, No. 25-cv-6033, slip op. at 1 (E.D.N.Y. Dec. 3, 2025), Dkt. No. 9, the pro se plaintiff filed a lawsuit against 20 unidentified defendants, alleging violations of several federal statutes. The plaintiff also filed motions for a temporary restraining order, preliminary injunction, and to seal the case, which were denied by the court. Id. Ultimately, the court concluded that venue was not proper, as the plaintiff failed to demonstrate that significant events related to his claims occurred in this district. Id. at 4. Consequently, the complaint was dismissed without prejudice for improper venue. Id. Additionally, the court noted that the plaintiff's case citations in filings were problematic. Id. at 3 n.2. The court declined to take further action on that point in lieu of its direction to the clerk to enter judgment and close the case. Id. at 4. In a pro se employment discrimination action, the plaintiff alleged discrimination based on race, sex, and national origin, as well as retaliation for her participation in Equal Employment Opportunity activities. Zhang v. Driscoll, No. 25-cv-3381, 2025 WL 3471250, at *1-2 (N.D. Cal. Dec. 3, 2025). The court addressed the plaintiff's motion for a preliminary injunction, seeking to prevent further adverse employment actions, remove a counseling letter from her file, restore her duties, and address alleged unauthorized dissemination of her EEO status, among other requests. Id. at *2. The court denied the motion, finding that the plaintiff failed to demonstrate a likelihood of success on the merits of her claims or a likelihood of irreparable harm. Id. at *4-6. Additionally, the court identified that the plaintiff's reply brief contained citations to fictitious cases, suggesting they were hallucinated by GAI. Id. at *2, *6. Accordingly, the court ordered the plaintiff to show cause why sanctions should not be imposed for including non-existent and erroneous citations in her brief. Id. at *6. After reviewing the plaintiff's response, the court concluded that her explanations to the show cause order were dishonest. Zhang, No. 25-cv-3381, 2026 WL 99759, at *1 (N.D. Cal. Jan. 14, 2026). The court sanctioned the plaintiff in the amount of $500. Id. The court stated that the imposed sanction was tailored to the specific circumstances of the case, considering the plaintiff's non-attorney status and dishonesty, and warned that any future references to fictitious cases by the plaintiff would lead to case-terminating sanctions. Id. In Villalovos-Gutierrez v. Van De Pol, No. 24-cv-2305, 2025 WL 3470253, at *1 (E.D. Cal. Dec. 3, 2025), the plaintiffs claimed that the defendants provided unlawful housing conditions, discriminated against them, paid unlawful wages, and denied meal and rest breaks. The case was in the pre-certification stage, and the plaintiffs filed a motion to compel discovery responses from the defendants. Id. The court granted the plaintiffs' motion to compel, overruling the defendants' objections, and found that the information sought was relevant to class certification. Id. Additionally, the court determined that the defendants had not adequately demonstrated that producing the requested documents would impose an undue burden or violate their privacy rights. Id. at *2-3. Regarding AI implications, the court warned the defendants' counsel about the use of fictitious or inaccurate case citations, which appeared to be generated by AI tools. Id. at *3. The court noted that counsel must confirm the existence and accuracy of legal citations and that failure to do so could result in sanctions. Id. In Quitugua v. Quitugua, No. 25-cv-36, 2025 WL 3465516, at *4-5 (D. Guam Dec. 3, 2025), the court dismissed the pro se plaintiff's amended complaint with prejudice, finding that the claims were barred by the statute of limitations. Additionally, the court noted that any further amendment to the complaint would be futile. Id. at *5. Finally, the court addressed potential Rule 11 violations by the plaintiff, who included misquoted and possibly AI-fabricated case law in his filings. Id. While the court did not impose sanctions, it cautioned the plaintiff to ensure the accuracy of future pleadings. Id. at *6. In Harris v. Pinnacle Bank, No. 25-cv-158, 2025 WL 3164067, at *1 (N.D. Miss. Nov. 12, 2025), the pro se plaintiff filed two separate actions against the defendant, alleging violations of the Fair Credit Reporting Act related to two different accounts he opened with the bank. The court granted the defendant's motion to consolidate the cases, finding that all relevant factors favored consolidation, including the presence of common questions of law and fact, as well as the potential for conserving judicial resources. Id. at *1-2. The court acknowledged the plaintiff's citation of fictitious legal authority, as alleged in the defendant's motion to strike, and issued a show cause order to address this issue. Id. at *2 n.2. The court declined to impose sanctions against the plaintiff but warned that any further violations may result in sanctions, including dismissal of this action. Harris, No. 25-cv-158, slip op. at 1 (N.D. Miss. Dec. 2, 2025), Dkt. No. 33. In a bankruptcy proceeding, the pro se debtor was a defendant in multiple civil actions related to real estate, as well as being indicted on 30 felony counts. In re Schwalb, No. 25-bk-12666, 2025 WL 3465948, at *1 (Bankr. D. Colo. Dec. 2, 2025). The bankruptcy filing aimed to centralize disputes and halt state court litigation. Id. However, the court granted relief from the stay for certain creditors, allowing them to continue state court litigation. Id. The debtor then moved to dismiss the Chapter 11 case, arguing it no longer served a purpose. Id. The court ultimately denied the debtor's motions for a stay pending appeal, finding that the debtor failed to demonstrate a strong likelihood of success on appeal, the threat of irreparable harm, the absence of harm to opposing parties, and that the public interest supported a stay. Id. at *3-5. In its ruling, the court noted that the debtor cited a non-existent case in a filing, but made no further comment. Id. at *3. In a pro se proceeding, the court addressed whether the plaintiff violated Rule 11 by including non-existent case law and fabricated quotations in his court filings. Mills v. City of St Louis, No. 25-cv-1219, 2025 WL 3470293, at *1 (E.D. Mo. Dec. 3, 2025). The court opined that the plaintiff's errors bore the hallmarks of AI hallucinations. Id. As a result, the court ordered the plaintiff to show cause why he should not be sanctioned for including non-existent case law and quotations. Id. at *2. Subsequently, the court denied the plaintiff's request to appoint counsel, noting that the plaintiff should not be rewarded for misconduct (referencing the plaintiff's previous misrepresentation of case law). Mills, No. 25-cv-1219, 2025 WL 3539832, at *1, *1 n.1 (E.D. Mo. Dec. 10, 2025). In a pro se action, the plaintiff appealed the district court's dismissal of her employment discrimination claims against the defendant. Moore v. City of Del City, No. 25-6002, 2025 WL 3471341, at *1 (10th Cir. Dec. 3, 2025). The district court dismissed her claims because she failed to file a timely charge of discrimination with the Equal Employment Opportunity Commission as required under Title VII and the Age Discrimination Act. Id. The appellate court affirmed the district court's decision. Id. Additionally, the appellate court dismissed the appeal as a sanction for the plaintiff's misuse of GAI in her filings. Id. at *3. In her appellate brief, the plaintiff cited eleven cases that the appellate court could not locate and two others that did not reasonably support the propositions for which they were cited. Id. at *2. The appellate court suspected that the eleven case citations were entirely created by a GAI tool. Id. In Button v. McCawley, No. 24-cv-60911, 2025 WL 3682758, at *1 (S.D. Fla. Dec. 2, 2025), the defendant sought to recover attorney's fees under Florida's Anti-SLAPP statute, which protects against lawsuits filed without merit primarily to suppress free speech on public issues. The case stemmed from statements made by the defendant in connection with litigation against the plaintiffs in Nevada. Id. The magistrate judge recommended granting in part and denying in part the defendant's motion for attorney's fees, concluding that the plaintiffs' lawsuit was without merit and primarily filed because the defendant exercised her right to free speech. Id. The magistrate judge also found that the plaintiffs' defamation claims were either time-barred or based on statements that were pure opinion or related to ongoing legal proceedings, rendering the lawsuit without merit. Id. at *2. Additionally, the magistrate judge noted that the plaintiffs' response contained numerous AI-generated hallucinated citations, which falsely attributed quotes to cases or cited non-existent cases. Id. While the magistrate judge did not recommend sanctions for these AI-related issues, the plaintiffs were warned to ensure the accuracy of their future submissions. Id. at *3. In a complex crypto case, the court addressed whether LGBCoin qualifies as a security under Section 12(a)(1) of the Securities Act. De Ford v. Koutoulas, No. 22-cv-652, slip op. at 1-2 (M.D. Fla. Dec. 2, 2025), Dkt. No. 531. Ultimately, the court denied the defendants' motion for summary judgment, finding that the plaintiffs' payment for LGBCoin constituted an "investment of money" and that the sale and purchase of LGBCoin constituted a "common enterprise" under existing law. Id. at 27-28. However, the court found a genuine dispute of material fact regarding whether there was an expectation of profits derived solely from the efforts of others, thus not granting full summary judgment on whether LGBCoin is a security. Id. at 26-27. In reaching a conclusion, the court observed that the defendants cited several cases that appeared to be AI hallucinations. Id. at 25-26 n.9. The court warned the defendants that citing non-existent cases violated Rule 11 and could give rise to sanctions. Id. In Jarrus v. Governor of Michigan, No. 25-cv-11168, 2025 WL 3461540, at *1 (E.D. Mich. Dec. 2, 2025), the district judge addressed whether the pro se plaintiffs' use of AI in drafting their objections to an order issued by the magistrate judge. The plaintiffs used AI-generated content without verifying its accuracy, resulting in false citations and misrepresented case holdings. Id. The district judge found that this conduct violated Rule 11, requiring a reasonable inquiry into the law and facts. Id. at *1-2. The court overruled the plaintiffs' objections due to noncompliance with the court's order and violations of Rule 11. Id. at *3. The district judge adopted the magistrate's recommendation, imposing a fine of $300 per plaintiff for three misrepresented AI-generated citations, totaling $600. Id. The district judge warned that future violations involving AI-generated content could result in dismissal of the case or revocation of the plaintiffs' in forma pauperis status. Id. In a pro se action involving an assortment of claims, the plaintiff filed a fourth amended complaint. Brick v. Gallatin Cnty., No. 24-cv-174, 2025 WL 3443200, at *1 (D. Mont. Dec. 1, 2025). The plaintiff's claims arose from civil disputes regarding her divorce and parenting plan with her former spouse, as well as from criminal proceedings against her in state courts and subsequent decisions made by the Montana Supreme Court concerning those cases. Id. at *2. Preliminarily, the court found that the fourth amended complaint failed to state a claim for relief under Rules 8 and 12. Id. at *3. Significantly, the court lacked jurisdiction to adjudicate the plaintiff's claims under the Rooker-Feldman Doctrine, as the allegations in the fourth amended complaint arise from the same set of facts as those presented in the previously dismissed third amended complaint. Id. at *6. Additionally, as in previous filings, the plaintiff continued to misrepresent citations and court findings to the court. Id. at *4. The court opined that many cases cited by the plaintiff in the fourth amended complaint either did not support the claims made, were fabricated, or were no longer considered valid. Id. The court did not elaborate further on the plaintiff's deficient case citations. In an insurance proceeding, the plaintiff alleged that the defendants failed to pay the full amount due under a flood insurance policy for water damage caused by a severe rainstorm. Tagliaferri v. Palomar Specialty Ins. Co., No. 25-cv-2148, 2025 WL 3440682, at *1 (N.D. Cal. Dec. 1, 2025). The defendants moved to dismiss the plaintiff's first amended complaint and to strike the plaintiff's request for punitive damages. Id. The court dismissed many of the claims with prejudice. Id. at *3-8. The court allowed the intentional misrepresentation claim to be amended. Id. at *7. The request for punitive damages was struck with prejudice (the plaintiff did not respond to the defendants' motion). Id. at *3. Claims against the defendant insurance company for breach of contract and breach of the covenant of good faith and fair dealing were not dismissed (apparently, these claims were not addressed in the motion to dismiss). Id. at *8. Additionally, the plaintiff's counsel admitted to using AI, which resulted in the inclusion of fictitious case citations and quotes in the legal filings. Id. at *3. While the court did not impose sanctions, it warned that such behavior would be subject to sanctions in the future. Id. In a complex case, the plaintiff alleged that the defendant's pop-up events offering free medical marijuana certifications violated Florida law by using dispensary funding to subsidize physician fees. The Doc App, Inc. v. Leafwell, Inc., No. 25-cv-838, 2025 WL 3288251, at *1 (M.D. Fla. Nov. 26, 2025). The plaintiff initiated the claim in state court, which was removed to federal court. Id. The issue before the court was whether to impose sanctions on the plaintiff's counsel for numerous misrepresentations of legal authority in a motion for a temporary restraining order (TRO). Id. at *2. The court found that counsel violated Rule 11(b) by including fabricated citations, misquoting cases, and citing irrelevant cases. Id. at *5-6. Notably, the court deemed that counsel's actions were not mere clerical errors but rather serious misrepresentations. Id. at *5. The court imposed sanctions on the attorney, requiring him to pay the defendant's attorney fees and costs incurred in responding to the TRO. Id. Additionally, the attorney was directed to attend a legal ethics course focused on AI, send a copy of the court's order to the plaintiff, and was referred to the state bar for appropriate disciplinary action. Id. at *6. The court denied the defendant's motions for additional sanctions as moot following the plaintiff's voluntary dismissal of the case. Id. In an employment discrimination case, the pro se plaintiff alleged that the defendant unlawfully terminated her employment based on race and disability. Boyd v. Protestant Mem'l Med. Ctr., No. 23-cv-3961, 2025 WL 3290642 (S.D. Ill. Nov. 26, 2025). The issue before the court was the plaintiff's motion for a protective order and request for scheduling relief, which she filed in response to the scheduling of her deposition one day before an independent neuropsychological exam. Id. at *1. The plaintiff claimed this scheduling was oppressive and placed an undue burden on her, and she also argued that she could not prepare for her deposition without outstanding discovery from the defendant. Id. The court denied the motion, stating that the plaintiff's workers' compensation case was a separate matter and that she presented no evidence of a coordinated legal effort among defense counsel. Id. The court noted that there were no outstanding discovery requests from the defendant prior to the plaintiff's deposition, as the defendant had already responded to all necessary interrogatories and requests for production. Id. Additionally, the court deemed the plaintiff's arguments concerning surveillance and expert disclosures as either inapplicable or irrelevant to the case. Id. at *1-2. The court ordered the plaintiff to attend her next scheduled deposition and warned her that failure to do so could result in the dismissal of her case. Id. at *2. As a final note, the Court admonished the plaintiff "for citing to cases that do not exist or do not stand for the proposition she claim[ed]." Id. at *2. The court opined that the plaintiff's "current motion [was] not the first example of her use of inappropriate case citations, but the Court [had] been lenient in the past due to her pro se status." Id. In a pro se action stemming from a foreclosure proceeding, the plaintiff filed a lawsuit against the defendant in state court, which was subsequently removed to federal court. Smith v. Wells Fargo Bank N.A., No. 25-cv-60, 2025 WL 3286668, at *1 (N.D. Miss. Nov. 25, 2025). The court granted the defendant's motion to dismiss with prejudice, labeling the lawsuit as frivolous. Id. at *4. Additionally, the court noted that the plaintiff cited fictitious cases in his filings. Id. at *3-4. While declining to impose sanctions, the court specifically warned the plaintiff:
Id. at *4 (emphasis is original). In Doe v. Taro Pharms. U.S.A., Inc., No. 25-cv-7815, 2025 WL 3284558, at *1 (N.D. Cal. Nov. 25, 2025), the court addressed the pro se plaintiff's motion to strike, which contained cases that the court could not locate. The court noted that pro se litigants were required to conduct a reasonable inquiry under the circumstances before submitting a motion under Rule 11(b). Id. The court ordered the plaintiff to explain how these non-existent cases were cited in her brief, but she will not face sanctions for these citations. Id. In a pro se action, the plaintiff filed a lawsuit against his former employer, the defendant, alleging retaliatory and discriminatory conduct in violation of the Americans with Disabilities Act and the Family and Medical Leave Act. Maturin v. T-Mobile USA, Inc., 24-cv-1125, 2025 WL 3281782, at *1 (D.N.M. Nov. 25, 2025). The issue before the magistrate judge was the cross motions for sanctions filed by both parties. Id. The plaintiff sought terminating sanctions against the defendant for alleged discovery violations, while the defendant sought sanctions against the plaintiff for bad faith conduct, including the use of fabricated legal citations and failure to comply with discovery obligations. Id. The magistrate judge recommended denying both parties' requests for terminating sanctions but suggested imposing lesser sanctions on the plaintiff. Id. In reviewing whether the defendant's request for dismissal as a sanction, the magistrate judge considered the following factors: the degree of actual prejudice to the defendant; the amount of interference with the judicial process; the culpability of the litigant; the court's previous warning about non-compliance with court rules; and the efficacy of lesser sanctions. Id. at *5-6. The magistrate judge recommended several sanctions against the plaintiff, including requiring him to reimburse the defendant for reasonable expenses related to false citations in his filings, as well as costs incurred from a motion for sanctions. Id. at *6. Significantly, the plaintiff must also cover expenses from his failure to appear at a scheduled deposition. Id. Additionally, the plaintiff was mandated to disclose the use of AI in future court filings and certify the accuracy of the information provided by AI under Rule 11. Id. at *7. The magistrate judge warned that non-compliance with these recommendations could result in the dismissal of his case. Id. In a pro se action, the plaintiff alleged four causes of action against the defendants: retaliation under the False Claims Act, retaliation under the state labor code, civil conspiracy to retaliate and facilitate wire fraud, and wrongful termination in violation of public policy. Rako v. VMware L.L.C., No. 25-cv-5142, 2025 WL 3277352, at *1 (N.D. Cal. Nov. 25, 2025). The court addressed three motions to dismiss the complaint filed by the defendants. Id. The court granted the defendants' motion with respect to the plaintiff's first, third, and fourth counts with prejudice. Id. at *7. The court did not reach the merits on the second count. Id. Additionally, the court expressed concern over the plaintiff's use of AI in preparing his opposition briefs, which contained non-existent legal citations. Id. at *2. The court ordered that in future filings, the plaintiff must verify the existence and accuracy of any AI-located citations and include a footnote confirming this verification. Id. In a habeas proceeding, the pro se plaintiff moved for relief from judgment under Rule 60(b) after his habeas corpus petition was denied. Andre v. Fed. Corr. Inst., No. 24-cv-1295, 2025 WL 3281732, at *1 (D. Conn. Nov. 25, 2025). The court addressed whether the plaintiff's motion was improperly prepared with undisclosed third-party assistance, including the use of GAI, which resulted in fabricated legal citations and arguments. Id. at *7. The court found that the plaintiff received substantial third-party assistance in drafting his submissions, which included the use of AI, leading to multiple inaccuracies and fabrications in his motion. Id. The plaintiff also misled the court by characterizing this assistance as merely clerical or typographical, and he did not personally sign or file the motion. Id. at *8. The court concluded that the plaintiff's actions violated Rule 11, requiring filings to be personally signed and factually and legally well-founded. Id. at *8-9. The court admonished the plaintiff for having a third party draft and file the motion, which contained multiple fabricated arguments generated by AI, and for his subsequent misrepresentations about the filing. Id. at *10. The court struck the motion with prejudice. Id. In the latest string of sovereign citizen-based filings by the pro se debtor, the court addressed the debtor's most recent attempt to halt foreclosure proceedings on her property. In re Kilpatrick, No. 25-bk-30619, 2025 WL 3295748, at *1 (S.D. Ohio Nov. 24, 2025). The court denied the motion, stating that there was no pending bankruptcy case to withdraw, and the only remaining issue was the imposition of sanctions against the debtor for her frivolous filings. Id. at *2. Ultimately, the court found the plaintiff's filings, including a verified notice of interest, to be without merit or legal basis. Id. Additionally, the court noted that the debtor likely used AI to generate her filings, which included citations to non-existent case law. Id. at *1. The debtor's misuse of AI to create and support frivolous legal arguments concerned the court, potentially warranting sanctions under Bankruptcy Rule 9011. Id. at *13. The court emphasized that her filings were frivolous and wasteful of judicial resources, and it planned to address the issue of sanctions in due course. Id. at *16. The court opined:
Id. The court will schedule a hearing to discuss the debtor's continuing and past violations of Bankruptcy Rule 9011(b) "to give her one last opportunity to purge herself of the [] ongoing violations under this Court's prior orders and to show cause why sanctions should not be issued by this Court under Bankruptcy Rule 9011(c)." Id. at *17. In a separate ruling, the bankruptcy court recommended that the district court deny the debtor's motion to withdraw the reference as moot, untimely, and meritless, emphasizing that there is no case or proceeding to withdraw since the bankruptcy case has been dismissed. In re Kilpatrick, No. 25-bk-30619, 2025 WL 3296216, at *1, *4 (S.D. Ohio Nov. 24, 2025). The bankruptcy court also referenced the debtor's repeated misuse of AI in preparing her frivolous filings. Id. at *4, *17. In a contract action, the plaintiff claimed that the defendant wrongfully denied a credit application for a $250,000 credit accommodation. Zero Point Mgmt. v. JPMorgan Chase Bank, N.A., No. 25-cv-8413, 2025 WL 3268885, at *1 (S.D.N.Y. Nov. 24, 2025). The primary issue before the court was whether a non-attorney trustee could represent the plaintiff, an "artificial entity," in federal court without legal counsel. Id. The court concluded that the non-attorney did not establish a basis for proceeding pro se and that the plaintiff must retain counsel to pursue the action. Id. In reaching a conclusion, the court observed that policy reasons strongly support the principle that non-attorneys should not represent the interests of others. Id. at *5. The court observed that the "concern has manifested itself" in this case, where the non-attorney's "submissions have contained citations to non-existent cases and misrepresented the holdings of cases." Id. The court opined that this "conduct highlight[ed] the importance of applying the rule barring non-lawyer representation of others in the absence of a satisfactory showing that the interests of others are not implicated." Id. In a pro se action, the plaintiff moved for a TRO to access life-saving medication, which he claimed was being delayed by the court's inaction. Izquierdo v. Wipro Ltd., No. 25-cv-2362, 2025 WL 3257089, at *1 (N.D. Ohio Nov. 21, 2025). The plaintiff argued that without court-mandated health insurance from the defendant, he would suffer irreparable harm. Id. The court denied the TRO, finding that the plaintiff misunderstood the nature of injunctive relief and the requirements of the preceding order to show cause. Id. The court noted that the plaintiff had other options to obtain healthcare, such as finding another job, seeking insurance on the open market, or maintaining his COBRA plan. Id. Additionally, the court warned the plaintiff against filing frivolous motions and indicated potential sanctions for continued misconduct. Id. In reaching its decision, the court observed that the plaintiff's filing contained an incorrect case citation. Id. at *1 n.5. In a complex civil rights case with bankruptcy implications, the court dismissed the pro se plaintiff's claims against the defendant, a former bankruptcy trustee, for procedural shortcomings. Oliver v. Dribusch, No. 25-cv-724, 2025 WL 3251000 *1, *3-6 (N.D.N.Y. Nov. 21, 2025). In reaching a conclusion, the court noted a dispute over the potential use of an AI tool by the plaintiff to generate an inaccurate legal citation. Id. at *7 n.4. The court "decline[d] to wade into this dispute," cautioning both parties "that the use of 'hallucinated' or fake case citations in legal submissions to a federal court is sanctionable conduct." Id. In Dubinin v. Papazian, No. 25-cv-23877, 2025 WL 3248187, at *1 (S.D. Fla. Nov. 21, 2025), the plaintiff's counsel filed a complaint and subsequent legal documents that contained numerous inaccuracies, including citations to non-existent cases and quotes. The inaccuracies were allegedly due to the use of AI in drafting the documents. Id. The court found that counsel's conduct, including reliance on AI-generated content without proper verification, constituted misconduct. Id. at *2. The court decided to strike the plaintiff's complaint, dismiss the case without prejudice, and impose sanctions on counsel, including the payment of attorney fees to the defendant. Id. at *3. Additionally, the court referred counsel to the state bar and the grievance committee for further investigation and potential disciplinary action. Id. Finally, the court ordered counsel to pay attorney fees "in the amount agreed upon by the parties at the Hearing—$4,030.90 for an estimated 26.5 hours spent on the case at a rate of $152.11 per hour." Id. In Evans v. Robertson, No. 24-cv-13435, 2025 WL 2737446, at *1 (E.D. Mich. Sep. 25, 2025), a pro se plaintiff sued the defendants for copyright infringement, defamation, fraud, and harassment. The primary issues before the court included motions related to anonymity and procedural matters. Id. The court granted the plaintiff's motions to compel one pro se defendant's (Robertson) identity disclosure, requiring Robertson to file a notice with her legal name and postal address. Id. at *3. In ruling, the court noted that both the plaintiff and Robertson provided inaccurate citations, likely due to reliance on AI tools, and emphasized the obligation of pro se litigants to ensure the accuracy of their legal documents. Id. at *5. The court warned that future filings must include a written representation confirming the accuracy of legal citations; failing to do so could lead to sanctions. Id. Subsequently, the court returned to the issue of sanctions against both parties for repeated failures to follow court orders and for dishonesty to the court, specifically regarding the use of factitious citations in their legal filings. Evans, No. 24-cv-13435, 2025 WL 3243458, at *1 (E.D. Mich. Nov. 20, 2025). The court found that both parties included incorrect citations in their filings, which were not made in bad faith but were still considered "tantamount to bad faith" or "wanton." Id. The court decided to revoke the parties' pro se electronic document upload privileges, requiring them to file documents by mail or hand delivery, as a sanction. Id. at *3. The court warned that future violations would result in additional sanctions, including potential monetary penalties. Id. In a discrimination case, the plaintiff alleged that the defendants failed to provide adequate accommodations for his disabilities. Goldman v. Ariz. Bd. of Regents, No. 25-cv-1420, 2025 WL 3018812, at *1-2 (D. Ariz. Oct. 29, 2025). The court addressed the defendants' motion to dismiss the plaintiff's amended complaint under Rule 12(b)(6). Id. The court granted the motion in part and denied it in part (permitting four claims against the Arizona Board of Regents to proceed). Id. at *3-4, *8. In ruling, the court found unusual language formulations in the plaintiff's response, surmising the use of GAI without sufficient attorney review. Id. at *9. The court identified issues with the response, including citations to non-existent cases and misrepresentations of legal standards, and ordered the plaintiff's counsel to explain these issues and show cause why they should not be sanctioned under Rule 11. Id. at *10. In a minute entry, the court noted the issues identified by the defendants and the court, and considered the response from the plaintiff's counsel; the court ordered that this matter would proceed. Goldman, No. 25-cv-1420, (D. Ariz. Nov. 20, 2025), Dkt. No. 54. In a bankruptcy action, the court addressed whether sanctions should be imposed on the debtors' counsel for filing pleadings with inaccurate, misleading, and fabricated citations and legal authorities. In re Jackson Hosp. & Clinic, Inc., No. 25-bk-30256, 2025 WL 3251167, at *1, *5 (Bankr. M.D. Ala. Nov. 20, 2025). The court found that counsel's filings contained numerous mis-citations and misstatements of existing case law, and that she had used GAI without verifying the accuracy of the citations. Id. at *14. The court determined that sanctions were not necessary for the firm, provided it implemented firm-wide training on AI use. Id. at *1. The court found that counsel's conduct violated several state ethics rules. Id. at *11-12. Counsel was sanctioned with a formal reprimand, revocation of her pro hac vice admission, and was required to circulate the court's opinion to relevant parties. Id. at *1, *11-12. In a class action, the court ordered the plaintiff's attorney to show cause to explain the fabricated quotations and caselaw within the plaintiff's motion. Buchanan v. Vuori, Inc., No. 23-cv-1121, 2025 WL 3089517, at *1 (N.D. Cal. Nov. 5, 2025). Specifically, the court identified eight instances of false quotations and reliance on a non-existent case, "Reed v. ZipRecruiter." Id. The court ordered the attorney to file a written response explaining the false citations and to show cause why the court should not impose sanctions and refer the matter to the Standing Committee on Professional Conduct. Id. at *2. Subsequently, the court found that the attorney violated Rule 11(b) and Civil Local Rule 11-4 by failing to conduct a reasonable inquiry into the legal authorities cited in his motion. Buchanan, No. 23-cv-1121, slip op. at 4 (N.D. Cal. Nov. 20, 2025), Dkt. No. 96. The court imposed sanctions, including striking the plaintiff's motions for preliminary approval of a class action settlement, ordering the attorney to pay $250 to the court clerk, and referring him to the court's committee on professional conduct. Id. at 6. The court also determined that the attorney was not adequate class counsel and would not allow him to file an amended motion. Id. at 7-8. In a pro se action, the plaintiff transferred approximately $100,000 in digital currency to various operators who allegedly blocked the plaintiff's withdrawal requests and absconded with the remaining funds. Y.S. v. Doe, No. 25-cv-3129, 2025 WL 3228214, at *1 (D. Colo. Nov. 19, 2025). The issue before the court was the plaintiff's request for expedited discovery to issue subpoenas to 13 third parties in order to identify the unknown Doe defendants. Id. at *2. The plaintiff also sought a nondisclosure order to prevent the subpoenaed parties from revealing the existence or contents of the subpoenas and requested permission to serve the subpoenas via email. Id. at *2, *4, *6. The court denied the plaintiff's motion for expedited discovery due to its excessive scope, allowing a single, amended motion focused on identifying Doe defendants and limiting subpoenas to three third parties, while also rejecting the requests for a nondisclosure order and email subpoenas. Id. at *3, *5-6. In ruling, the court observed the potential use of AI by the plaintiff in drafting or conducting legal research, which may have led to the inclusion of non-existent or improperly attributed legal citations. Id. at *5. The court warned the plaintiff of the obligation to comply with Rule 11 and the potential for sanctions if non-existent or misleading legal authority continues to be cited. Id. In Ekeocha v. U.S Dep't of State, No. 25-cv-454, 2025 WL 3228063, at *1 (D.D.C. Nov. 19, 2025), the plaintiff, a Nigerian citizen, invested $500,000 in an American company to qualify for the EB-5 immigrant investor visa program. Despite his investment and the approval of his visa petition, the defendants failed to schedule his required interview at the U.S. Embassy in Lagos, Nigeria, resulting in a delay in the processing of his visa application. Id. The plaintiff filed a lawsuit against the defendants, claiming that the delay violated the Administrative Procedure Act and his Fifth Amendment right to due process. Id. He sought declaratory and injunctive relief to compel the processing of his visa application. Id. The court granted the defendants' motion to dismiss the case. Id. at *8. In reaching a conclusion, the court noted that the plaintiff's counsel may have relied on AI to draft the opposition, as it contained citations to non-existent cases and quotations. Id. The court refrained from taking disciplinary action against the counsel at this time but warned of potential sanctions if the issue were to arise again. Id. In a dispute over the purchase of a vehicle through a retail installment contract, the pro se plaintiff alleged that the defendant unlawfully repossessed the vehicle without proper notice, misrepresented the vehicle's auction status, and engaged in deceptive business practices, among other claims. Nellum v. Credit Acceptance Corp., No. 25-cv-1579, 2025 WL 3222813, at *1-2 (S.D. Ind. Nov. 18, 2025). The court granted the defendant's motion to compel arbitration, finding that the arbitration clause was valid and encompassed all of the plaintiff's claims; consequently, the court stayed the proceedings pending arbitration. Id. at *7. The plaintiff's filings contained fabricated case citations and misrepresented legal authority. Id. at *3 n.3. The plaintiff claimed that she did not fabricate citations, but she conceded that some references may be imperfect due to limited access and the complexity of legal databases. Id. The court cautioned the plaintiff about the importance of complying with the procedural rules and that submitting hallucinated citations was unacceptable. Id. The court stressed that such conduct can result in sanctions. Id. In Moorehead v. Goodwill Indus. of Ne. Tex., No. 25-cv-563, 2025 WL 3217836, at *1 (E.D. Tex. Nov. 18, 2025), the pro se plaintiff filed a lawsuit against the defendant under the Fair Labor Standards Act and the Americans with Disabilities Act. The defendant moved to dismiss under Rule 12(b)(6) and also moved to stay proceedings or discovery pending the court's resolution of its motion to dismiss. Id. The court denied the defendant's motion to stay discovery, stating that the defendant had not demonstrated exceptional circumstances warranting such a stay. Id. The court noted that the number of discovery requests made by the plaintiff was within reasonable bounds and that the defendant had already answered or agreed to answer these requests. Id. The court also found that the defendant had not shown significant prejudice that would justify a stay of discovery. Id. at *2. Additionally, the court addressed concerns about the plaintiff's use of GAI, which resulted in her citing non-existent cases in her legal documents. Id. The court warned the plaintiff that such false citations were unacceptable and undermined the integrity of the judiciary. Id. The court stated that if the plaintiff continued to file documents with hallucinated or non-existent citations, she would be subject to sanctions. Id. In Paredes v. A&P Rest. Corp., No. 24-cv-522, 2025 WL 3215606, at *1 (S.D.N.Y. Nov. 18, 2025), the plaintiff initiated an action against the defendants, alleging interference, retaliation, and discrimination under the Family and Medical Leave Act and New York Labor Law § 215. The court granted the defendants' motion to dismiss, concluding that the plaintiff failed to establish a "serious health condition" under the FMLA and did not allege that he complained to the defendants about a potential state labor law violation. Id. at *4. The court dismissed the plaintiff's claims with prejudice, finding that permitting leave to amend would be futile. Id. at *4-5. Additionally, the court addressed the issue of potential sanctions against the plaintiff's counsel for citing non-existent cases and misquoting legal authorities, warning that such conduct could be subject to future sanctions. Id. In a pro se action (with two plaintiffs) against several electric cooperatives, the court addressed whether the plaintiffs' claims could withstand the defendants' motion to dismiss. Mattson v. Rosebud Elec. Coop., No. 25-cv-3008, 2025 WL 3208889, at *1 (D.S.D. Nov. 17, 2025). Of the plaintiffs' eleven counts, the court dismissed eight without prejudice and three with prejudice. Id. at *24. In its lengthy ruling, the court also addressed fictitious case citations in the plaintiffs’ response. Id. at *23. The court observed that the formatting of the brief appeared to indicate the use of GAI. Id. at *24. Additionally, the brief contained incorrect case citations and quotations, which the defendants pointed out in their reply. Id. The plaintiffs later corrected these errors in their notice. Id. The court declined to impose sanctions, but warned the plaintiffs to "review and abide by Federal Rule of Civil Procedure 11(b) for future filings." Id. In a motion to reconsider the court's grant of summary judgment in favor of the defendant, the pro se plaintiff argued that the court misapplied the discretionary function exception, improperly resolved a factual dispute, and applied procedural rules that resulted in manifest injustice. Cotto v. United States, No. 22-cv-1102, 2025 WL 3207118, at *1 (D. Colo. Nov. 17, 2025). The court denied the motion for reconsideration, finding that the plaintiff's arguments did not demonstrate a need to correct clear error or prevent manifest injustice. Id. at *1-3. In its ruling, the court observed that the plaintiff's filings contained citations to non-existent authorities and miscited other legal authority. Id. at *3. In a civil rights action, the court granted summary judgment to the defendants, concluding that the detention was justified as a Terry stop, the force used was not excessive, an individual defendant was entitled to qualified immunity for not violating clearly established rights, and thus the claims against the defendant city failed under the respondeat superior theory. Neal v. Frayer, No. 24-cv-778, 2025 WL 3204710, *5, *11, *13 (D. Md. Nov. 17, 2025). Additionally, the court considered Rule 11 sanctions, finding several troubling citations in the plaintiffs’ summary judgment opposition. Id. at *13. The court also noted that the plaintiffs' counsel included inaccurate citations in other cases. Id. at *14. The court declined to issue a show cause order despite recognizing errors in the plaintiffs' opposition due to prior practices, as counsel has since implemented new protocols to adhere to Rule 11’s standards. Id. In a pro se action, the plaintiff appealed the dismissal of her claims against the defendant, arising from the defendant's alleged failure to respond to a letter the plaintiff sent concerning an outstanding debt on a car loan. Miller v. Stuart, No. 25-30190, 2025 WL 3175977, at *1 (5th Cir. Nov. 13, 2025). The trial court dismissed the plaintiff's claims under Rule 12(b)(6) for failure to state a claim. Id. The appellate court affirmed the dismissal, agreeing with the trial court's determination that the defendant was exempt as a "buyer of chattel paper" and that the plaintiff's letter did not constitute a valid request for accounting. Id. at *2. Additionally, the appellate court noted some problematic filings by the plaintiff in the trial court and on appeal. Id. at *3. The plaintiff's lower court filings contained bold and alarming inaccuracies and misrepresentations. Id. On appeal, the plaintiff's appellate brief referenced numerous cases that do not match the citations provided. Id. Moreover, many of the cases she cited fail to support the propositions she attributes to them. Id. The appellate court declined to consider the arguments the plaintiff supported with nonexistent cases. Id. In Green Bldg. Initiative, Inc. v. Peacock, 350 F.R.D. 289, 291 (D. Or. 2025), the plaintiff sued the defendants for trademark infringement, unfair competition, breach of contract, and deceptive trade practices under Oregon law. The issue before the court was the plaintiff's motion for attorney fees, following the court's grant of the plaintiff's motion to strike two of the defendants' counterclaims under the state anti-SLAPP statute. Id. The court denied the motion without prejudice, finding that the motion was premature. Id. at 293. The court also found that the plaintiff's citations included fictitious cases, which appeared to have been generated by a GAI tool. Id. at 291-92. The court highlighted the ethical obligations of attorneys utilizing AI, emphasizing the importance of accuracy and verification to prevent violations of professional conduct rules. Id. The court ordered the plaintiff to show cause why sanctions should not be imposed for using fake citations. Id. at 293. After reviewing the plaintiff's response and accompanying declarations, the court decided not to impose any formal sanctions, being satisfied with the remedial actions already taken and those proposed by the plaintiff's counsel. Green Bldg. Initiative, No. 24-cv-298, 2025 WL 3198411, at *1 (D. Or. Nov. 12, 2025). In a pro se employment discrimination case, the plaintiff sued his former employer and the union. Montgomery v. Int'l Bhd. of Elec. Workers, No. 23-cv-1262, 2025 WL 3188737, at *1 (M.D. Tenn. Nov. 14, 2025). The court granted summary judgment in favor of both defendants, finding that the plaintiff failed to show that the union acted with discriminatory animus and that the former employer's reasons for his termination were pretextual. Id. In reviewing the filings, the court found that several of the plaintiff's citations were incorrect, and it was unclear whether the plaintiff relied on AI for drafting assistance. Id. at *5 n.2. In a pro se action, the plaintiffs alleged that the defendants acted unlawfully and negligently in servicing their mortgage loan. Swincher v. Fay Servicing, L.L.C., No. 25-cv-15, 2025 WL 3143458, at *1 (W.D. Ky. Nov. 10, 2025). The plaintiffs filed their action in state court, but after the defendants removed the case to federal court, the plaintiffs sought remand. Id. at *1-2. The court denied the plaintiffs' motion to remand, concluding that the defendants met the requirements for removal under 28 U.S.C. § 1446. Id. at *3. In ruling, the court noted that the plaintiffs indicated that "their motion to remand was 'PREPARED BY ONLINE ATTORNEY' and that their reply was 'PREPARED WITH THE ASSISTANCE OF AN ONLINE ATTORNEY.'" Id. at *1 n.1. The defendants suggested that "ghostwriting by an attorney is generally disfavored by federal courts and may be sanctionable." Id. The court found that the plaintiffs cited non-existent authority in their filings, and any further citation to non-existent legal authority would result in sanctions. Id. In this criminal case, the charges against the defendants (state police troopers) stemmed from four separate use-of-force incidents and an alleged cover-up. United States v. Czartorski, No. 25-cr-30, 2025 WL 3143800, at *1 (W.D. Ky. Nov. 10, 2025). Two of the defendants moved to sever their cases. Id. at *2. The court ordered a hearing to address the motions, as well as ordered a hearing for one of the defendant's counsel to show cause why they should not be sanctioned for citing fictitious decisions and misrepresenting case holdings, potentially due to reliance on AI-generated content. Id. at *3-4. The court noted that the motion contained citations to fabricated opinions, and "more concerning," the motion cited real Sixth Circuit cases but misrepresented the holdings. Id. at *4. In an employment discrimination case, the court addressed whether the plaintiff's attorney should be sanctioned for filing a brief that contained inaccurate legal citations. Shelton v. Parkland Health, No. 24-cv-2190, 2025 WL 3141108, at *1-2 (N.D. Tex. Nov. 10, 2025). The defendant's counsel spotted the problematic citations and informed opposing counsel of the errors. Id. at *1. The defendant's counsel gave the plaintiff's attorney three days to provide an explanation before notifying the court; the plaintiff's attorney did not respond. Id. In responding to a show cause order, the plaintiff's attorney attributed the use of GAI to a newly licensed associate attorney who formerly worked remotely for her law firm. Id. at *2. The plaintiff's attorney stated that she unintentionally filed a brief prepared using GAI without proper disclosure, as per court rules, and acted in good faith to correct the errors once she became aware of them. Id. After reviewing the attorney's conduct, the court determined that an admonition was a suitable sanction. Id. at *5. In crafting the sanction, the court noted that the attorney's action did not appear malicious. Id. Additionally, the court noted that the case reached a settlement, and the defendant's counsel did not establish a precise cost incurred as a direct result of opposing counsel's errors. Id. In a bankruptcy, a pro se debtor sought the turnover of a repossessed vehicle. In re Hines, No. 25-bk-32055, 2025 WL 3137723, at *1 (Bankr. S.D. Ohio Nov. 7, 2025). The court granted the turnover, ordering the repossessor to return the vehicle, as it was deemed essential for the debtor's transportation needs and potential financial rehabilitation under Chapter 13. Id. at *10. At the outset of the proceedings, the court inquired how the debtor prepared her filings. Id. at *3. The debtor "readily admitted that she utilized Chat GPT to make her filings look 'more professional,' but also testified that she had done some research on her own"; "she essentially 'cut and paste' from what Chat GPT provided in response to her prompts." Id. The court advised that AI-assisted filing documents often contain made-up, hallucinated case citations or other inaccuracies. Id. In a complex copyright infringement action, the court addressed multiple motions to dismiss. David v. George Chiala Farms, Inc., No. 24-cv-4040, 2025 WL 3124339, at *1-2 (N.D. Cal. Nov. 7, 2025). In addressing the motions, the court noted several instances of citations to non-existent cases in the plaintiffs' filings. Id. at *12. The court did not credit the plaintiff's arguments, relying upon the non-existent citations. Id. The court admonished the plaintiffs for failing to comply with local rules and the court's standing order. Id. at *4. In a criminal case, the court denied the defendant's motion to compel discovery, ruling that reliance on Brady v. Maryland, 373 U.S. 83 (1963), in a revocation proceeding was misplaced. United States v. Brewer, No. 19-cr-22, 2025 WL 2636404, at *1 (M.D. Fla. Sep. 11, 2025). The court expressed significant concerns with the motion filed by the defendant's attorney, noting that nearly every case citation in the twelve-page filing was incomplete, inaccurate, or fabricated. Id. The motion contained references to non-existent cases, misquoted cases, and cases that did not support the propositions for which they were cited. Id. at *1-2. The court deduced that these inaccuracies appeared to be typical AI hallucinations. Id. at *2. Accordingly, the court ordered the attorney to show cause why sanctions should not be imposed for these violations. Id. at *2-3. In considering sanctions for the defendant's attorney, the court found that his reliance on AI tools, specifically Westlaw CoCounsel, did not excuse his failure to personally verify the citations, which demonstrated recklessness and bad faith. Brewer, No. 19-cr-22, slip op. at 2 (M.D. Fla. Nov. 7, 2025), Dkt. 427. Consequently, the court referred the matter to the district court's grievance committee and the state bar. Id. at 3. The court directed the attorney to provide copies of the recent sanction orders to each judge and opposing counsel in his cases to mitigate any potential harm from his misuse of AI. Id. The court discharged the show cause order, pending further evaluation of sanctions after receiving the grievance committee's recommendation. Id. In a pro se action, the plaintiff alleged that the defendant breached a contract and violated several federal statutes. Grimmer v. Citibank, N.A., No. 25-cv-2758, 2025 WL 3124051, at *1 (D. Minn. Nov. 7, 2025). The defendant moved to dismiss under Rule 12(b)(6), arguing that the plaintiff's claims were not plausible. Id. The court found that the plaintiff's claims were not plausible for several reasons, including the lack of a bona fide dispute regarding the debt, the inapplicability of the UCC provisions cited, and the absence of a private right of action under the statutes he invoked. Id. at *2-4. Additionally, the court noted that Grimmer failed to allege facts showing Citibank was a debt collector under the FDCPA. Id. at *5. The court granted the defendant's motion, dismissing the complaint with prejudice. Id. at *8. Additionally, in its reply brief, the defendant pointed out that the plaintiff's opposition brief included numerous citations to non-existent cases, and suggested that sanctions would be appropriate; however, the defendant failed to file a motion for sanctions. Id. at *7. In a subsequent clarification notice, the plaintiff acknowledged that several citations in his opposition brief could not be found in official reporters or databases due to reliance on non-conventional research methods and an AI drafting tool, combined with his documented cognitive-processing disorders affecting short-term memory, and he subsequently apologized in a related document for the errors, denying any intent to mislead the court or opposing counsel. Id. After reviewing the plaintiff's filings, the court "conclude[d] the better answer is just to drop the issue," rather than order a show cause hearing or consider sanctions. Id. The court decided not to require the plaintiff to explain his citation errors due to his plausible excuses, sincere apology, existing harm to his credibility, and the belief that further sanctions would be disproportionately burdensome without a significant deterrent effect. Id. In an employment discrimination and FLSA action, the court addressed its jurisdiction, given that the defendant was a Nebraska corporation with limited business contacts in Tennessee. Warfield v. W.N. Morehouse Truck Line, Inc., No. 25-cv-37, 2025 WL 3102069, at *1 (E.D. Tenn. Nov. 6, 2025). The court concluded that jurisdiction did not lie, and it dismissed the plaintiff's claim without prejudice. Id. at *5. The court noted that the defendants indicated that the plaintiff's reply brief contained incorrect and non-existent case citations. Id. at *2. The court declined to address the errors in the plaintiff's brief. In a pro se action, the court denied the plaintiff's motions for leave to appeal in forma pauperis. Sifuentes v. Christian Bros. Auto., No. 23-cv-904, 2025 WL 3100998, at *1 (W.D. Mich. Nov. 6, 2025). Throughout the proceedings, the plaintiff relied on a non-existent, prompting the court to opine that "[t]his is the third time that the Court must reject the same argument in this case alone." Id. The court noted that the plaintiff had been previously warned about citing that non-existent case. Id. at *1 n.1. In a pro se action, the plaintiff alleged that the defendants improperly withdrew his employment offer, breached the contract, committed corporate negligence, and caused reputational harm. Miah v. Morgan Stanley & Co. Int'l PLC, No. 25-cv-1208, 2025 WL 3097414, at *1 (S.D.N.Y. Nov. 6, 2025). The district judge addressed the defendants' motion to dismiss the complaint for lack of subject matter jurisdiction, as both the plaintiff and the corporate defendant were aliens, defeating diversity jurisdiction. Id. The district judge adopted the magistrate judge's recommendation to grant the motion to dismiss and denied the plaintiff's motion for leave to amend the complaint. Id. The dismissal was without prejudice, allowing the plaintiff to pursue his claims in a court of competent jurisdiction. Id. at *2. Additionally, the plaintiff apparently used AI in his filings, which included citations to non-existent cases and quotations not found in the cited authorities. Id. at *2 n.1. The district judge noted that the "Complaint included apparent commentary from an AI platform in response to [the plaintiff's] prompts." Id. The district judge declined to address the AI misuse further. In Pete v. U.S. Dept. of Just., No. 25-cv-386, 2025 WL 2917098 (E.D. Tex. Oct. 10, 2025), the court denied the plaintiff's motion to proceed in forma pauperis, acknowledging that the plaintiff's reliance on fake caselaw was an abuse of the adversarial system. Subsequently, the plaintiff filed an objection to the court's previous order, adopting the magistrate judge's report and recommendation. Pete, No. 25-cv-386, 2025 WL 3091695, at *1 (E.D. Tex. Nov. 6, 2025). First, the court noted that "litigants cannot file 'objections' to the orders of district judges"; although the court construed the motion as one for reconsideration. Id. Ultimately, the court denied the plaintiff's motion for "reconsideration" due to his false statements, including his failure to provide certified copies of AI-hallucinated cases he previously cited, while also faulting the court for not referencing those cases in its order denying his in forma pauperis motion. Id. at *2. The court ordered that the plaintiff's ongoing objections or motions concerning the court's order on the filing fee will not postpone the case, and failure to pay the filing fee will result in dismissal of the action. Id. In a pro se action, the court addressed several motions, including a motion to strike, motions to dismiss for insufficient process and service of process, motions to set aside a default certificate, and a motion for default judgment. Logan v. LVNV Funding L.L.C., No. 25-cv-848, 2025 WL 3089130, at *1 (D. Utah Nov. 5, 2025). In sum, the court afforded the plaintiff to effect service on the defendants and permitted the defendants to file motions to dismiss. Id. at *3-4. Additionally, the court expressed grave concerns about allegations that the plaintiff's opposition contained AI-generated case quotations. Id. at *2. The court warned the plaintiff against improper use of AI in the litigation and indicated that sanctions could be considered under a Rule 11 motion for sanctions if the defendant pursued it. Id. In a pro se discrimination case, the plaintiff challenged the defendants' removal of the case to federal court. Lowrey v. City of Rio Rancho, No. 25-cv-849, 2025 WL 3089580, at *1 (D.N.M. Nov. 5, 2025). The court denied the motion to remand, finding that the removal was procedurally proper and that the federal court had original jurisdiction over the federal claims. Id. The court also found that the Plaintiff's arguments regarding the complexity of state law issues and pending state court motions did not warrant remand. Id. at *6-7. In reaching a conclusion, the court issued a warning to the plaintiff about the use of AI in drafting legal filings. Id. at *10-11. The court discussed (at length) the 11 non-existent cases or misleading authorities within the plaintiff's filings. Id. at *7-10. Ultimately, the court emphasized that even pro se litigants must comply with Rule 11, which requires that legal filings be objectively reasonable and well-supported. Id. at *10-11. The court cautioned against the use of AI-generated content that includes fictitious or misleading legal citations. Id. at *11. Subsequently, the plaintiff moved to disqualify an attorney from representing individual defendants in their personal capacities, arguing that joint representation creates an impermissible conflict of interest. Lowrey, No. 25-cv-840, 2025 WL 3171284, at *2 (D.N.M. Nov. 13, 2025). The court denied the motion, finding that the plaintiff did not demonstrate an actual conflict of interest requiring separate counsel and lacked standing to bring the motion. Id. at *4. The court noted that the plaintiff's allegations were speculative and lacked specific factual support, and also warned the plaintiff against citing nonexistent case law and misrepresenting legal support in future filings. Id. at *4-5. A pro se plaintiff filed an employment lawsuit against her former employer, the defendant, alleging retaliation, wrongful termination, race discrimination, defamation, and fraudulent manipulation. Smart v. Pro. Grp., No. 25-cv-11833, 2025 WL 3091139, at *1 (E.D. Mich. Nov. 5, 2025). The court addressed several motions filed by the plaintiff, including motions for reconsideration and various procedural requests, as well as a pending motion by the defendant for partial dismissal of some of the plaintiff's claims. Id. The court denied the plaintiff's motions, including her motion for reconsideration and other procedural motions, due to non-compliance with local rules and other deficiencies. Id. at *3-5. In ruling, the court expressed concern about the potential use of GAI in the preparation of the plaintiff's motions and notices, warning that AI cannot provide legal advice and its use in legal research can lead to significant errors. Id. at *5. The court warned against relying on AI-generated content, as it could lead to sanctions under Rule 11 for submitting inaccurate or false legal citations. Id. In Kheir v. Titan Team, No. 25-bk-3033, slip op. at 1 (Bankr. S.D. Tex. Nov. 4, 2025), Dkt. No. 35, the court addressed whether the plaintiff's counsel violated a court's order and Bankruptcy Rule 9011 by using GAI to manufacture legal authority without verifying the content or existence of such authorities. The court documented 32 hallucinations. Id. at 7-16. Incredibly, at the show cause hearing, counsel tried to pass the blame onto the plaintiff (not an attorney) for providing some of the citations. Id. at 17-18. Even though the plaintiff admitted to finding the cases, the court ruled that counsel failed to ensure that the cases were real and that the case quotations were accurate before signing the document and filing it with the court. Id. at 19. In finding that counsel violated the court order and pertinent rule, the court ordered counsel to reimburse the defendant for its reasonable attorney fees and costs, register for six hours of CLE on the use of GAI in courts, provide a copy of the court's order to his client, and file a certificate of compliance. Id. Additionally, the court referred counsel to the chief district judge and the state bar for possible disciplinary action. Id. In reaching a decision, the court opined:
Id. at 5-6 (footnotes omitted). In a pro se legal malpractice action, the defendant moved to dismiss the case under Rule 12(b)(1), arguing that both parties were citizens of Minnesota, thus negating diversity jurisdiction. Glass v. Foley & Lardner LLP, No. 24-cv-769, 2025 WL 3079280, at *1 (W.D. Wis. Nov. 4, 2025). The defendant claimed that one of its partners was a Minnesota citizen, which would destroy diversity jurisdiction. Id. at *2. The plaintiff disputed the claim, suggesting that the individual was a partner in name only, hired to manipulate jurisdiction. Id. at *3. Initially, the plaintiff sought leave to conduct limited discovery to confirm the defendant's citizenship; the plaintiff then supplemented his motion for jurisdictional discovery to include a list of proposed requests for production. Id. at *1-2. The court "largely" denied the plaintiff's motion, but permitted some limited jurisdictional discovery to go forward. Id. at *2. Additionally, the court observed that the plaintiff's initial motion for discovery contained incorrect or non-existent case citations, possibly due to reliance on GAI tools. Id. at *1 n.1. The court cautioned that providing non-existent authority may lead to sanctions. Id. In a dispute between the plaintiff insurance company and the defendants regarding a construction project, the plaintiff moved to strike the defendants' affirmative defenses. Arch Ins. Co. v. A3 Dev., L.L.C., No. 23-cv-23524, 2025 WL 3091075, at *1 (S.D. Fla. Oct. 21, 2025). The court granted the motion to strike in part and denied it in part. Id. at *5. While the case did not explicitly discuss AI, it highlighted the inclusion of non-existent case citations in the defendants' court filings. Id. at *3 n.1. The court ordered defense counsel to show cause why Rule 11 sanctions should not be imposed for these inaccuracies. Id. at *5. After reviewing counsel's show cause response, the court was satisfied with the remedial measures proposed to ensure proper training and responsible use of AI in the future. Arch Ins., No. 23-cv-23524, slip op. at 1 (S.D. Fla. Oct. 31, 2025), Dkt. No. 120. The court required counsel to file a status update on the implementation of new AI safeguards. Id. at 2. Additionally, all attorneys from the firm involved in the case must complete formal training on the proper use of AI, with a notice to be filed upon completion. Id. In a bankruptcy action, the debtor filed a motion to reconsider a previous court order denying her motion to strike unauthorized pleadings and disregard improper appearances. In re Williams, No. 24-bk-62693, 2025 WL 3039332, at *1 (Bankr. N.D. Ga. Oct. 30, 2025). The court denied the motion to reconsider, as the debtor failed to provide a basis for reconsideration. Id. at *2. Additionally, the court denied the debtor's request for a declaration to void a foreclosure sale due to a violation of the automatic stay; the court lacked jurisdiction to reconsider the stay denial order due to a pending appeal. Id. Finally, the court implicitly warned the debtor about AI misuse, noting that the debtor cited a case that could not be located and appeared to be a product of an AI hallucination. Id. at *1 n.2. In Safe Choice, LLC v. City of Cleveland, No. 24-cv-2033, 2025 WL 2958211, at *1 (N.D. Ohio Oct. 17, 2025), the court addressed whether the plaintiff and its attorney should be held in contempt for failing to comply with a court order requiring the plaintiff to provide copies of certain case citations that the court could not locate. While the court declined to hold the plaintiff or attorney in contempt, the court found that the attorney violated Rule 11 by citing non-existent cases and misrepresenting the legal significance of other cases in her filings. Id. at *3, *5-6. The court noted that the attorney's use of an AI platform called "Casemine" with an AI program named "Amicus" was identified as a contributing factor to the Rule 11 violations. Id. at *3-4. The court ordered the attorney to show cause why her conduct was not a violation of Rule 11(b) and why she should not be sanctioned for this conduct. Id. at *6. The court found that the plaintiff's counsel made repeated citations to non-existent legal authority and misrepresentations of legal authority in legal filings. Safe Choice, No. 24-cv-2033, 2025 WL 3029553, at *2-3 (N.D. Ohio Oct. 30, 2025). The court rejected the attorney's claim that deterrence was achieved by the previous warnings, noting that the attorney subsequently failed to adhere to the requisite standards for verifying the accuracy of AI-drafted material. Id. at *4. The court commented that the attorney "offered a brief and perfunctory apology at the Contempt Hearing," but the court found "that her demeanor did not reflect either true remorse or an understanding of how wrong her conduct was." Id. at *5. The court also found that the attorney's "attempt to shift the blame on her law clerk" was "inexcusable." Id. The court imposed monetary sanctions on the attorney in the amount of $7,500, required her to send copies of the court's orders and her response to the Cleveland Metropolitan Bar Association's Certified Grievance Committee, the plaintiff, and the state court upon remand. Id. at *6. In Sauls v. Pierce Cnty., No. 25-cv-5957, 2025 WL 3033958, at *1 (W.D. Wash. Oct. 30, 2025), the pro se plaintiff filed an ex parte emergency motion for a TRO against the defendants. The court denied the motion, finding that the plaintiff failed to demonstrate a likelihood of success on the merits or irreparable harm that could not be addressed through other legal means. Id. at *2-3. The court observed that the plaintiff's complaint lacked essential details to comprehend her allegations and failed to provide specific facts demonstrating immediate and irreparable injury, which diminished her chances of succeeding on the merits and was necessary for obtaining a TRO without notice. Id. Finally, the court reminded the plaintiff that there is no formal rule against using GAI to write pleadings and briefs, but she remains bound by Rule 11. Id. at *3 n.1. The court warned that using AI-generated content that included non-existent legal authority could lead to sanctions. Id. In Berg v. United Airlines, Inc., No. 23-cv-1766, 2025 WL 3033488, at *1 (D. Colo. Oct. 30, 2025), the district judge addressed the magistrate judge's order and recommendation to deny the pro se plaintiff's motions to amend the complaint and grant the defendant's motion to strike the plaintiff's responses to a motion for summary judgment. The district judge overruled the plaintiff's objection due to its lack of specificity and failure to identify any specific errors in the magistrate judge's recommendation. Id. at *2. Accordingly, the district judge adopted the recommendation and denied the plaintiff's motions to amend. Id. at *3. The district judge noted that the plaintiff's filings violated Rule 11 due to her continued misuse of GAI, resulting in citations for misstated or non-existent legal authority. Id. at *2-3. The court warned that continued misuse could result in severe sanctions, including filing restrictions, monetary sanctions, or dismissal of the action. Id. at *3. In Wilson v. Kipp Texas, Inc., No. 24-cv-2578, 2025 WL 3030444, at *2 (N.D. Tex. Oct. 29, 2025), the plaintiff's attorney failed to disclose AI use as required by the court's local rule. Specifically, the attorney utilized GAI to prepare portions of the summary judgment response and response appendix; however, it appears that ChatGPT was used to generate content that was inaccurately presented as verbatim quotations from job descriptions. Id. at *1. While not a fake case citation situation, the court found that this situation constituted a violation of Rule 11, as the AI-generated content lacked evidentiary support. Id. at *3. The court sanctioned the attorney for these violations, requiring him to reimburse the defendant for attorney fees related to the summary judgment reply and to attend CLE courses on AI. Id. The court ordered the attorney to confer with opposing counsel regarding attorney fees and costs, indicating either an agreed-upon amount and payment deadline or stating that no agreement was reached, after which the Court will intervene if necessary. Id. Subsequently, the parties filed a notice indicating that an agreement had been reached on sanctions. Wilson, No. 24-cv-2578, slip op. at 1 (N.D. Tex. Nov. 5, 2025). In a pro se action regarding an insurance coverage dispute, the court granted the defendant's motion to dismiss the claims for bad faith and IIED. Nelson v. State Farm Fire & Cas. Co., No. 25-cv-99, 2025 WL 3015797, at *1, *4 (S.D. Ga. Oct. 28, 2025). The court did not reference AI misuse in the ruling, but indicated that the plaintiff's filings included multiple citations to non-existent cases. Id. at *1. The plaintiff acknowledged that he did file briefs containing citations to non-existent cases. Id. at *4 n.3. In a pro se action, the plaintiff sought declaratory relief, injunctive relief, and monetary damages, claiming that the defendant unlawfully sold the contents from the plaintiff's rental storage units through an online auction. Waheed v. SM 1 MMS, L.L.C., No. 24-cv-6476, 2025 WL 3239422, at *1 (S.D.N.Y. Oct. 28, 2025). The magistrate judge recommended denying the plaintiff's motions for preliminary injunctive relief. Id. at *2. The court noted that the plaintiff cited a non-existent case and misstated holdings of other cases. Id. at *7 n.3. The court surmised that the plaintiff's filings contained hallucinations generated by AI. Id. The magistrate judge declined to take action. In a bankruptcy action, the debtor initiated a pro se adversary action against the bankruptcy trustee, the trustee's counsel, and the trustee's bonding company. In re McGann, No. 24-bk-18118, 2025 WL 3028987, at *1 (Bankr. D. Colo. Oct. 27, 2025). The trustee and the trustee's counsel moved to dismiss, and the court granted the motion because the debtor failed to timely respond. Id. While the order was not directed at the bonding company, the debtor failed to timely prosecute her remaining claims against the bonding company. Id. The court ordered the debtor to show cause why those claims should not be dismissed. Id. The debtor claimed proper service on the bonding company and moved for default and entry of default judgment. Id. The court denied the debtor's motion, finding that the debtor failed to establish proper service of legal process on the bonding company. Id. at *11. Accordingly, the court lacked personal jurisdiction over the bonding company, precluding the entry of default judgment. Id. The court also indicated that it might dismiss the bonding company without prejudice due to the failure to effect proper service within the required timeframe. Id. at *12. In ruling, the court noted that the debtor repeatedly cited a fake case throughout the proceedings. Id. at *4 n.21. In an insurance case, the pro se plaintiff filed the action in state court, and the defendant removed it to federal court. Jayroe v. Progressive Cas. Ins. Co., No. 25-cv-2408, 2025 WL 3144976, at *1 (N.D. Tex. Oct. 27, 2025). The plaintiff then moved to remand the case to state court, asserting that he was entitled to a default judgment in state court and that the removal was untimely. Id. The court found that the plaintiff was not entitled to a default judgment because the defendant filed its answer before the state court entered a default judgment. Id. Additionally, the court determined that the defendant's notice of removal was timely filed and that the plaintiff's motion to remand be denied. Id. at *2-3. Additionally, the court found that the plaintiff's filings cited non-existent, AI-generated authority. Id. at *2. The court noted that local civil rules require litigants to disclose the use of GAI. Id. the court opined that the plaintiff's filings were "built on AI-generated cases that stand for legal propositions in direct contravention of actual case law," and amounted to “the epitome of baseless.” Id. at *3 (internal quotation omitted). The court admonished the plaintiff and cautioned that failure to comply with the notice requirements set out in the local rules or filing pleadings with citations to non-existent case citations may result in sanctions, "including the striking of filings, the imposition of filing restrictions, monetary penalties, or dismissal of this action." Id. In Jones v. District of Columbia Off. of Unified Commc’ns., 25-cv-1420, 2025 WL 3018812, at *1 (D. Ariz. Oct. 29, 2025), the plaintiff brought an action against her former employer, the defendant, alleging discrimination, retaliation, and hostile work environment under the Americans with Disabilities Act, the Age Discrimination in Employment Act, and Title VII, as well as interference with the Family and Medical Leave Act. The issue before the court was whether the plaintiff's claims of age discrimination, Title VII retaliation, and hostile work environment were sufficiently supported by factual allegations to survive a motion to dismiss. Id. at *2. The court granted the defendant's partial motion to dismiss, finding that the age discrimination claim for lack of evidence showing significantly younger selected candidates, the Title VII retaliation claim for failing to allege retaliation based on a protected characteristic, and the hostile work environment claim due to insufficient severity or pervasiveness of the alleged conduct. Id. at *3-6. Further, the court observed that the plaintiff's counsel cited non-existent quotations in the opposition brief, which bore the hallmarks of AI. Id. at *7. The court emphasized that reliance on misquoted or non-existent authorities in court filings is unacceptable and contravenes an attorney's duty to exercise professional judgment and responsibility. Id. The court warned that further violations could result in sanctions or referral to a disciplinary committee. Id. In Support Cmty., Inc. v. MPH Int'l LLC, No. 23-cv-4911, slip op. at 1 (N.D. Cal. Sep. 11, 2025), Dkt. No. 86, the court addressed the defendant's administrative motion to withdraw its motion for summary judgment. A subsequent hearing was initially converted to a show cause hearing to determine whether the defendant's counsel had violated Rule 11 by failing to verify the accuracy of legal citations in a brief that was partially drafted using GAI. Id. at 2. The court was tentatively inclined to require counsel to report to the state bar and complete continuing legal education on the GAI use in the legal context. Id. at 4. After reviewing the defendant's motion for summary judgment, which included citations generated by AI without verification, the court examined whether the use of AI without verifying the accuracy of the citations constituted a breach of the attorney's duty to ensure that legal contentions are supported by existing law. Support Cmty., No. 23-cv-4911, slip op. at 1-2 (N.D. Cal. Oct. 6, 2025), Dkt. No. 97. The court granted the defendant's motion to withdraw the summary judgment motion in part and imposed sanctions for the improper use of AI-generated citations. Id. at 2-3. The court directed the defendant to re-file the motion with the hallucinated cases and citations excised. Id. at 3. As a sanction, the court awarded the plaintiff reasonable attorney fees and costs. Id. The court also ordered the defendant to submit a copy of this order to the state bar. Id. The plaintiff requested more than $25,000 in attorney fees. Declaration re Court-Ordered Sanctions at 5-8, Support Cmty., No. 23-cv-4911 (N.D. Cal. Oct. 27, 2025), Dkt. No. 98. In a pro se action, the plaintiff alleged violations of the Fair Debt Collections Practices Act due to misleading and deceptive attempts to collect a consumer debt. Youngers v. Scott & Assocs., P.C., No. 25-cv-2573, 2025 WL 3488668, at *1 (S.D. Tex. Oct. 24, 2025). The plaintiff sought statutory damages under the FDCPA and actual damages for emotional distress. Id. The defendants responded with separate answers and affirmative defenses, which the plaintiff moved to strike, arguing that they were both legally insufficient and factually unsupported. Id. The magistrate judge addressed whether to grant the defendant's motions to strike the defendants' affirmative defenses under Rule 12(f). Id. The court recommended denying the motions, noting that in the Fifth Circuit, affirmative defenses only need to meet the "fair notice" standard, not the heightened pleading standards of Twombly and Iqbal. Id. at *2. Ultimately, the court found that the defendants' affirmative defenses provided sufficient information to give the plaintiff fair notice. Id. at *3. Additionally, the magistrate judge addressed AI implications, finding that the plaintiff cited non-existent cases and legal propositions. Id. at *2. In suspecting AI misuse, the magistrate judge admonished the plaintiff for this misconduct, warning that future similar conduct could result in sanctions. Id. The plaintiffs sued the defendant, alleging violations of contractual obligations under the Business Solutions Agreement. N-BAR Trade, Inc. v. Amazon.com Servs. LLC, No. 25-cv-918, 2025 WL 2986447, at *1 (D.D.C. Oct. 22, 2025). The court dismissed the action without prejudice after granting the defendant's motion to compel arbitration, finding that the parties had established an agreement to arbitrate that delegated arbitrability questions to the arbitrator and determined that Amazon had not waived its right to compel arbitration. Id. at *6. Additionally, the court noted that the plaintiff's counsel likely relied on AI to draft court filings. Id. at *7. The court refrained from taking disciplinary action due to the case being referred to arbitration, but warned that future violations could result in sanctions. Id. In Pete v. Facebook Meta Platforms, No. 25-cv-00245, 2025 WL 2979701, at *1-2 (E.D. Tex. Oct. 22, 2025), the pro se plaintiff objected to the court's transfer of the case to another federal court. The court reviewed these objections under the "clearly erroneous" standard and overruled them, directing the clerk to transfer the case immediately. Id. at *2-3. In reaching a decision, the court noted that if the plaintiff's objections were based on AI-generated content, he could be subject to sanctions under Local Rule CV-11(g) for any errors. Id. at *3 n.5. In Univ. Mall v. Okorie, No. 24-cv-91, slip op. at 1, 5, 13 (S.D. Miss. Oct. 22, 2025), the plaintiff moved for contempt against the pro se defendant for failing to comply with court orders to vacate the property, as well as moving for a pre-filing injunction to prevent the defendant from filing further vexatious lawsuits. The court granted both motions. Id. at 21. Additionally, the court noted that the defendant used AI to generate his pleadings, which included hallucinated citations and non-existent case references. Id. at 17. The defendant's misuse of AI contributed to the court's decision to impose a pre-filing injunction. Id. In an appeal from a Chapter 11 bankruptcy proceeding, the pro se creditors sought review of the bankruptcy court's orders sustaining the debtors' objections to their claims. In re Bittrex, No. 23-cv-10598, 2025 WL 2977719, at *1 (D. Del. Oct. 22, 2025). After the court denied the appeal, the creditors moved for enlargement of time to file a motion for rehearing. Id. The court denied the motion, finding that the creditors failed to demonstrate excusable neglect. Id. at *4. Additionally, the court expressed concern about the creditors' misleading citations to non-existent cases, which weighed against a finding of good faith. Id. The court surmised that the misleading citations might be attributable to AI fallacies, although this was not a basis for excusing their conduct. Id. In an employment discrimination case, the plaintiff alleged claims of discrimination, retaliation, and hostile work environment under the ADEA, Title VII, and the Pennsylvania Human Relations Act. Weaver v. Shasta Servs., No. 25-cv-910, 2025 WL 2977874, at *1 (W.D. Pa. Oct. 22, 2025). The court granted in part and denied in part the defendant's motion to dismiss. Id. at *4. While the plaintiff refiled his opposition brief, citing two erroneous case citations, the court reflected that the original brief in opposition contained apparent hallucinations created by AI. Id. at *1 n.1. In a pro se action, the plaintiff, a former police officer, filed a lawsuit against the defendant police officers’ federation, alleging discriminatory treatment based on race and sex in violation of Title VII, among other claims. Kasso v. Police Officers’ Fed'n of Minneapolis, 23-cv-2777, 2025 WL 2963375, at *1 (D. Minn. Oct. 21, 2025). Following the filing of the plaintiff's second amended complaint, the defendant moved to dismiss the Second Amended Complaint, and the court dismissed all claims except for the Title VII claim for race and sex discrimination. Id. The issue before the court was the plaintiff's second motion to compel a Rule 45 subpoena, seeking documents and electronically stored information from the non-party City of Minneapolis. Id. The court granted in part and denied in part the plaintiff's motion. Id. at *3-7. Additionally, the court addressed the plaintiff's use of inaccurate and non-existent caselaw, which appeared to be generated by AI. Id. at *8. The court found that the plaintiff violated Rule 11, as it represented an abdication of the duty of truthfulness and an abuse of the legal system. Id. The court warned the plaintiff against further use of fictitious and inaccurate authorities, highlighting the potential consequences of such actions. Id. In Goddard v. Sares-Regis Grp., Inc., No. 25-cv-5882, 2025 WL 2969295, at *1 (N.D. Cal. Oct. 21, 2025), the pro se plaintiff filed a lawsuit against the defendants, stemming from the denial of a request for a rent reduction. The defendants moved to dismiss ten causes of action in the plaintiff's first amended complaint. Id. The plaintiff failed to file a timely response to the motion to dismiss, and the court granted the motion as unopposed. Id. at *2. The court also found that the complaint did not comply with Rule 8's requirement for a "short and plain" statement of the claim, and the claims were deemed legally meritless. Id. at *2-3. Importantly, the court granted the motion to dismiss with prejudice, considering factors such as bad faith, undue delay, and futility of amendment, concluding that further amendments would be futile. Id. at *3-4. In reaching a conclusion, the court noted that the plaintiff's filings contained repeated misrepresentations and were likely generated in whole or in part through GAI. Id. at *3. Ultimately, the court declined to issue a show cause order to consider the plaintiff's alleged AI misuse. Id. In Cowden v. U.S. Dep't of Treasury, No. 24-cv-602, 2025 WL 2958766, at *1 (E.D. Mo. Oct. 20, 2025), the pro se plaintiff filed a lawsuit to challenge a federal tax lien and sought declaratory and injunctive relief, claiming a violation of the Administrative Procedures Act. The court granted the defendants' motion to dismiss the case with prejudice, concluding that the Anti-Injunction Act and the Declaratory Judgment Act barred judicial review of the plaintiff's claims. Id. Additionally, the court noted that the plaintiff had alternative legal remedies available, which further precluded review under the APA. Id. at *3. Finally, the court suspected that portions of the plaintiff's filings might have been generated by AI, as it was unable to locate some of her case citations and quotations. Id. at *2 n.3. In lieu of the case dismissal, the court declined to address the AI implications. In a case involving an allegation of Medicaid fraud, the pro se plaintiff sought injunctive relief to prevent the defendant from withholding Medicaid payments. Leach v. Minn. Dep't Hum. Servs., No. 25-cv-3220, 2025 WL 2962486, at *1 (D. Minn. Oct. 17, 2025). The court denied the plaintiff's motion, ruling that the plaintiff lacked standing to bring a case against the defendants. Id. at *2. Further, even if the plaintiff had established standing, they failed to show a likelihood of success on the merits of the case, suffered irreparable harm, or demonstrated that the balance of harms and the public interest favored granting the injunction. Id. at *3-4. The court also dismissed the claims against the defendants due to lack of subject-matter jurisdiction. Id. at *2, *5. Additionally, the court expressed concern over the plaintiff's use of legal citations, noting that a quotation provided in the plaintiff's supplementary memorandum was not found in the cited case or elsewhere. Id. at *3. The court cautioned against using AI tools that might provide inaccurate information, indicating leniency due to the plaintiff's pro se status, but warned of potential future actions if such issues persist. Id. In Button v. Jimison, No. 25-cv-5622, 2025 WL 2958545, at *1 (W.D. Wash. Oct. 17, 2025), the plaintiffs moved to strike the pro so defendant's answer, asserting that the answer contained non-responsive and legally insufficient denials and affirmative defenses. The plaintiffs requested the court to strike these responses and to require a more definite statement. Id. The court granted the plaintiffs' motion to strike the defendant's answer, allowing the defendant to file an amended answer with the benefit of counsel. Id. at *2. Additionally, the court observed issues with the plaintiffs' citations, which included references to non-existent cases and misquoted statements. Id. The court advised the plaintiffs to verify all information and citations, warning against relying on AI programs for legal research or drafting legal arguments. Id. To ensure accuracy, the court required the plaintiffs to include a signed certification in future filings, confirming the validity and accuracy of cited decisions and quoted language. Id. In a pro se proceeding, the plaintiff filed a motion to "proceed toward default judgment without U.S. Marshal service." Sargsyan v. Amazon.com Inc., 25-cv-1257, 2025 WL 2958482, at *1 (W.D. Wash. Oct. 17, 2025). Thus, the issue before the court was to determine whether the plaintiff could proceed with a default judgment against the defendant without having properly served them. Id. After analyzing the standards under Federal Rule of Civil Procedure 4(d), the court found no legal basis to proceed without serving the defendant and denied the plaintiff's motion. Id. Additionally, the court noted that the plaintiff cited non-existent case law and warned that any future citations to fake law would subject the plaintiff to sanctions under Rule 11. Id. In Hanson v. Nest Home Lending, LLC, No. 25-cv-2599, 2025 WL 2959293, at *1 (D. Colo. Oct. 17, 2025), the court addressed several motions filed by the pro se plaintiffs. The court thoroughly reviewed the filings and was concerned by the numerous defects, including inaccurate citations, misattributions of legal concepts, and references to non-existent cases. Id. The court surmised that the plaintiffs may have used GAI to prepare their filings in this matter, and the filings were "rife with citations to nonexistent cases, misstatements of legal principles based on these cases, and improperly quoted material from legitimate cases." Id. at *2. The court issued an order for the plaintiffs to show cause why their conduct has not violated Rule 11(b). Id. at *4. The court ordered the plaintiffs to explain how they located the legal authority cited in their pleadings and what efforts they made to confirm its accuracy. Id. The court opined that failure to respond may result in sanctions. Id. In Tristan v. Rubio, No. 25-cv-255, 2025 WL 2939131, at *1 (E.D. Mo. Oct. 16, 2025), the pro se plaintiffs sought a declaration that they are U.S. citizens pursuant to federal immigration law. The defendants moved to dismiss for lack of subject matter jurisdiction and for failure to state a claim. Id. at *2. First, the plaintiffs acknowledged that certain defendants should be dismissed as improper defendants under the APA. Id. at *3. Accordingly, the court dismissed the claims against those defendants without prejudice. Id. The court dismissed another claim for lack of standing without prejudice. Id. at *8-9. The court declined to dismiss another claim (on improper venue), because the defendants failed to address a key issue. Id. at *4-7. In ruling, the court observed that the plaintiffs relied on a non-existent case in their brief. Id. at *10. The court issued a warning that the plaintiffs "shall be sure to cite to specific (actual) case authority and evidence supporting their position on venue." Id. In a lawsuit related to the failed January 6, 2021, insurrection, the court ordered the attorney for one of the defendants (a leader of one of the Florida chapters of the Oath Keepers) to show cause how fabricated local civil rule citations and quotations were included in the defendant's opposition brief and why she failed to take immediate steps to withdraw or fully correct the brief. Smith v. Trump, No. 21-cv-2265, 2025 WL 2943723, at *1 (D.D.C. Oct. 16, 2025). In Polinski v. United States, No. 25-cv-783, 2025 WL 2935059, at *1 (Fed. Cl. Oct. 15, 2025), the pro se plaintiff filed a lawsuit against the United States, alleging a "failure to redeem" a negotiable instrument, amounting to a taking under the Fifth Amendment, as well as other claims. The court found jurisdiction to be lacking and the plaintiff's pleadings to be implausible and insufficient. Id. at *3, *6. The court also noted that the claims were frivolous, as they were based on theories similar to those of the sovereign citizen movement, which have been universally rejected by courts. Id. at *8. Finally, the court observed that the plaintiff's filings appeared to have been drafted with the assistance of AI, which included references to non-existent cases. Id. at *11. The court issued a warning to the plaintiff about the risks associated with using AI-generated legal authority, indicating that future filings with fictional AI-generated citations could result in sanctions. Id. Ultimately, the court dismissed the case and ordered the clerk to close it. Id. In Ghadimi v. Arizona Bank & Tr., No. 25-cv-3106, 2025 WL 2928933, at *1 (D. Ariz. Oct. 15, 2025), the pro se plaintiff alleged that the defendant engaged in a coordinated scheme to destroy his healthcare businesses. In denying the plaintiff's request for injunctive relief, the court noted that the plaintiff's filings contained incorrect citations. Id. at *2-4. The court did not expressly address whether the plaintiff used AI "or simply imagined the cases himself," but cautioned that filing documents containing such cases will result in sanctions under Rule 11. Id. at 4. In Force v. Capital One, N.A., No. 25-cv-633, 2025 WL 2930308, at *1-4 (M.D. Fla. Oct. 15, 2025), the court identified several deficiencies in the pro se plaintiff's filings, including the use of non-existent or misleading case citations and improper filings that do not comply with procedural rules. The court ordered the plaintiff to show cause why the action should not be dismissed as a sanction for the repeated violations (the hearing was set for November 4, 2025). Id. at *4. In two separate cases initiated by the plaintiffs arising from the provision of medical care services, the court consolidated the actions. Reed v. Cmty. Health Care, No. 25-cv-5228, 2025 WL 1645210, at *1-2 (W.D. Wash. June 10, 2025). The plaintiffs opposed consolidation, but the court ordered the consolidation of the two cases to avoid duplicative arguments, conflicting rulings, and to preserve judicial economy and resources. Id. at *2-3. During the proceedings, the plaintiffs identified fictitious quotes and citations in their briefings. Id. at *2 n.4. The court acknowledged that the plaintiffs appeared to accept responsibility for the fictitious citations. Id. The court advised that providing fictitious cases and quotes will lead to sanctions. Id. Subsequently, the court addressed the defendants' motion to dismiss the plaintiffs' second amended complaint. Reed, No. 25-cv-5228, 2025 WL 2917464, at *1 (W.D. Wash. Oct. 14, 2025). The court again observed that the plaintiffs continued to use fictitious case law in their filings. Id. at *10. The court ordered that the plaintiffs shall include a signed certification on any subsequent filings, indicating that "each decision cited is a valid decision that does exist.” Id. The court warned that any pleading filed by the plaintiffs that does not include this certification will be stricken. Id. In a pro se case, the plaintiff alleges unlawful arrest, excessive force, and inhumane jail conditions against the defendants. Pyle v. Glenn Cnty. Sheriff's Dep't, No. 24-2940, 2025 WL 2912644, at *1 (E.D. Cal. Oct. 14, 2025). The magistrate judge recommended dismissal of the plaintiff's § 1983 claims, but permitted the plaintiff to amend the pleadings. Id. at *4-5. In reaching a decision, the magistrate noted that the plaintiff's sur-reply appeared to use GAI, which included prompts and responses to prompts. Id. at *3. The court warned that filings containing AI hallucinations, such as made-up facts or legal authority, could violate Rule 11 and result in sanctions. Id. In a pro se action, the plaintiff alleged claims of negligence, invasion of privacy, and breach of contract, asserting that the defendant's employee made an unauthorized disclosure of his sensitive personal information to a third party. Anderson v. JPMorgan Chase Bank, N.A., No. 25-cv-2214, 2025 WL 3313734 (N.D. Tex. Oct. 13, 2025). The plaintiff later amended his pleading to include a claim that the defendant's duty of care arose from federal law, specifically the Gramm-Leach-Bliley Act, as well as the bank's internal policies. Id. The defendant removed the case to federal court based on diversity jurisdiction. Id. The plaintiff moved to remand, arguing that the defendant failed to establish the amount in controversy, that a state court was the proper venue, that the plaintiff did not assert any federal claims, and that the defendant should not be allowed to remove the action a second time after it had been remanded once. Id. at *2. The magistrate judge recommended that the plaintiff's motion to remand should be denied. Id. at *1-3. The magistrate judge observed that the plaintiff's briefing contained serious errors, including citations to non-existent cases, which raised questions about whether he used AI to prepare his briefs without verifying the accuracy of legal citations or the substance of arguments. Id. at *4. The magistrate judge underscored the importance of verifying the accuracy of legal citations and adhering to court rules, warning that failure to do so could result in sanctions. Id. at *4-5. In Oneto v. Watson, No. 22-cv-5206, 2025 WL 2901666, at *1 (N.D. Cal. Oct. 10, 2025), the court ordered the plaintiff's attorney to show cause why sanctions should not be imposed for including non-existent and erroneous case citations in a brief. The court found that the attorney violated Rule 11 by failing to conduct a reasonable inquiry into the validity of the legal authorities cited, as well as violating the state rules of professional conduct, requiring attorneys to present claims warranted by existing law and to maintain candor with the tribunal. Id. at *1-2. The court imposed sanctions on the attorney, including a $1,000 monetary penalty, a requirement to serve a copy of the sanction order on his client, participation in a CLE course on the ethical use of AI in legal practice, and notification to the state bar. Id. at *4. In United States v. McGee, No. 24-cr-113, slip op. at 1 (S.D. Ala. July 10, 2025), Dkt. No. 258, the court addressed the defendant's motion to continue the trial; the prosecution opposed and alleged that the defendant's filing contained fabricated legal citations. According to the prosecution, the inability to locate the purportedly fake citations "bear the hallmarks" of AI hallucinations. Id. The court conducted an independent search and found similar issues; consequently, defense counsel was ordered to show cause why sanctions should not be imposed for making false statements of fact or law. Id. at 2. The court subsequently granted the defendant's motion to remove counsel and to appoint new counsel. Oral Order, McGee, No. 24-cr-113 (S.D. Ala. Jul. 16, 2025), Dkt. No. 268. Subsequently, the court determined that counsel's conduct was tantamount to bad faith, as he failed to verify the citations generated by the AI program before submitting them to the court. McGee, No. 24-cr-112, 2025 WL 2888065, at *7 (S.D. Ala. Oct. 10, 2025). The court found that counsel's "misconduct [was] tantamount to bad faith and sanctionable under the Court's inherent authority." Id. at *8. The court decided to reprimand counsel for the misconduct. Id. at *9. The reprimand included the following. Id.
In a legal malpractice claim, resulting in liability against the defendant and an award of damages to the plaintiff, the pro se defendant moved for sanctions against the plaintiff and her attorney for alleged misconduct throughout the litigation, including citing cases that do not exist or misrepresenting case law. Rhee-Karn v. Lask, No. 15-cv-9946, 2025 WL 3287148, at *1-2 (S.D.N.Y. Oct. 9, 2025). The court denied the motion, noting that much of the defendant's motion focused on events that should have been addressed during the post-trial motions period, which already passed. Id. at *2. The court found no basis for sanctions against the plaintiff for her post-trial arguments, which were not made in bad faith. Id. While the court acknowledged that the plaintiff misstated some case holdings and cited a non-existent case, it declined to impose sanctions due to the defendant's own misrepresentations and fabrications, which also protracted the litigation. Id. at *2-3. Subsequently, the plaintiff and her attorney moved to request a conference to reconsider the court's previous order; the court denied the motion. Rhee-Karn, No. 15-cv-9946, 2025 WL 3287146, at *1 (S.D.N.Y. Oct. 20, 2025). Ultimately, the court found no basis for reconsideration or relief, noting that the plaintiff's motion was untimely and did not meet the strict standard for reconsideration. Id. at *2-3. In ruling, the court noted that the plaintiff's filing contained misstatements that could be the result of using AI without verification or some other failure. Id. at *1. However, the court did not impose sanctions or make a finding that the plaintiff's attorney acted in bad faith, nor did it assume that his errors were the product of AI. Id. The court opined that the "incorrect citations and descriptions of holdings could be the result of use of artificial intelligence 'or some other failure.'" Id. (emphasis in original). In Queen v. Kansas City, No. 25-cv-2292, 2025 WL 2845025, at *1 (D. Kan. Oct. 7, 2025), a pro se plaintiff filed a lawsuit against several defendants, alleging false arrest and excessive force under 42 U.S.C. § 1983, civil theft and property deprivation, deliberate indifference to medical needs, ADA violation and disability discrimination, negligent medical discharge, and false arrest and defamation. The issues before the court included motions to dismiss the plaintiff's claims of ADA violation, disability discrimination, and negligent medical discharge, as well as the plaintiff's motions for default judgment against certain defendants. Id. The court granted the motions to dismiss filed by two of the defendants, finding that the factual allegations were insufficient to support the ADA and negligent medical discharge claims. Id. at *2-3. The court also denied the plaintiff's motions for default judgment as premature because the defendants had not been properly served at the time the motions were filed. Id. at *4. Additionally, the court expressed concern that the plaintiff might be relying on AI to assist with his legal filings, given the nonresponsive nature of his responses to the motions to dismiss. Id. The court admonished the plaintiff against using AI for drafting legal documents or citing cases without confirming their accuracy and directed him to review Rule 11, which applied to both attorneys and unrepresented parties. Id. In Villavicencio v. Mingo, No. 25-cv-993, 2025 WL 2837645, at *1 (S.D. Ohio Oct. 7, 2025), the magistrate judge conducted an initial screening of the pro se plaintiff's complaint under 28 U.S.C. § 1915 to identify any cognizable claims and recommend dismissal of any frivolous or non-meritorious claims. The case involved a writ of mandamus to compel a state environmental court to make a determination regarding an environmental penalty. Id. at *2-3. The magistrate determined that the court lacked subject-matter jurisdiction because the writ of mandamus was abolished under Federal Rule of Civil Procedure 81(b), and the relief sought does not fall under the jurisdiction of 28 U.S.C. § 1361. Id. at *3. The magistrate recommended dismissing the complaint without prejudice for lack of subject-matter jurisdiction. Id. Additionally, the magistrate noted that the plaintiff cited a U.S. Supreme Court case that was "patently false," as well as citing several other state-law citations that were incorrect or did not exist. Id. The magistrate warned the plaintiff that future citation of false legal authority would lead to sanctions. Id. In this case, the court found that the defendant’s motion to dismiss included briefs containing erroneous quotations and misrepresented case law, including inaccurate quotes attributed to the court’s own prior opinion. Jakes v. Youngblood, No. 24-cv-1608, 2025 WL 2371007, at *1-2 (W.D. Pa. June 26, 2025) (emphasis added). While the plaintiff identified these issues in a response brief, the defendant did not offer an explanation. Id. The court noted that the defendant's counsel "brazenly attempted to mount a tu quoque defense, asserting that 'a LexisNexis Document Analysis of Plaintiff's own opposition brief reveals a pattern of misquotation, superficial citation, and invocation of authorities that are either inapposite or do not support the propositions for which they are cited.'" Id. The court independently reviewed each party's filings, finding no issues with the plaintiff and that the defendant's "brief [was] replete with non-existent quotations and repeated misrepresentations of actual case law." Id. The court opined, "when accused of a serious ethical violation, [the defendant's counsel] chose to double down." Id. The court viewed this conduct "as a clear ethical violation of the highest order." Id. The court identified eight specific fabrications and numerous additional fabricated quotations. Id. at *2-4. The court graciously presumed that the defendant's briefs were constructed by GAI rather than an effort by the defendant's counsel to personally construct false and misleading briefs." Id. at *4. The court concluded that counsel could not "outsource his obligations to the court and his client to a third party--including artificial so-called 'intelligence.'" Id. The court struck the defendant's motion to dismiss and reply brief from the record and ordered the defendant to answer the complaint by a specified time. Id. While counsel filed a withdrawal of his appearance, the court ordered counsel to show cause as to why sanctions should not be imposed. Id. at *1, *5. At a subsequent show cause hearing, the court requested the plaintiff to submit a petition for attorney fees. Plaintiff's Petition for Fees at 11, Jakes, No. 24-cv-1608, (W.D. Pa. Aug. 1, 2025), Dkt. No. 61. The plaintiff requested $76,197.63 in attorney fees. Id. at 11. To support the award of attorney fees, the plaintiff argued that the defendant's AI-infected 20-page motion to dismiss raised eight separate issues—far more substantial than typical AI-related cases (usually involving lower-stakes filings like discovery disputes). Id. The defendant further complicated the matter by employing the same strategy in his reply brief, inaccurately accusing opposing counsel of similar misconduct. Id. The plaintiff asserted that this situation necessitated the filing of a sur-reply. Id. In the subsequent memorandum Order, the court found that the attorney's explanation regarding the AI misuse was not credible. Jakes, No. 24-1608, slip op. at 2 (W.D. Pa. Oct. 6, 2025), Dkt. No. 71. Notably, the court specifically opined that an attorney "with a cosmopolitan, multi-state, practice—cannot plead ignorance to justify their use or misuse of AI in drafting legal documents filed with the courts." Id. The court noted that the defendant's brief in support of the motion to dismiss and the reply contained fabrications, but the attorney refused to accept responsibility and instead wrongly accused opposing counsel of AI misuse. Id. While the court directed opposing counsel to submit a petition for fees, the court determined that the requested amount ($76,197.63) was not "a reasonable measure of a sanction in this case." Id. at 4-5. In determining a reasonable amount, the court considered the nature of the attorney's practice and ability to pay. Id. at 5. The court "believe[d] that monetary sanctions [were] necessary to deter [the attorney] from future misconduct—especially due to his decision to double-down on his misuse of AI after it was brought to the attention of the Court." Id. Ultimately, the court found that a fee award to opposing counsel in the amount of $5,000 was appropriate. Id. In Davis v. Faubion, No. 25-cv-336, 2025 WL 2795301, at *1 (W.D. Tex. Oct. 1, 2025), the magistrate judge recommended that the pro se plaintiff's claims should be dismissed as frivolous and for failure to state a claim upon which relief can be granted. The district judge accepted the recommendation and dismissed the action with prejudice under 28 U.S.C. § 1915(e), finding that allowing an amendment would be futile. Id. at *3. The district judge noted that the plaintiff's reliance on AI research was insufficient without verifying the accuracy of AI-generated information, as required by the Fifth Circuit. Id. at *2. The district judge also emphasized that the dissenting opinions, on which the plaintiff relied, do not provide binding legal authority. Id. Finally, the district judge denied the plaintiff's request to amend his complaint, concluding that he had not presented a plausible claim that warranted leave to amend. Id. at *3. The district judge provided no further commentary on the Plaintiff's AI misuse. In Smith v. Athena Constr. Grp., Inc., 18-cv-2080, slip op at 1 (D.D.C. July 26, 2025), Dkt. No. 190, the court issued a show cause order for the plaintiff's attorney to explain why sanctions should not be imposed for making false statements of law to the tribunal. In responding to a motion to continue the trial, the plaintiff's brief contained nine case citations, four of which cited false propositions of law, four were accompanied by fabricated quotations, and one case citation was entirely fabricated. Id. at 2-3. In a subsequent minute order, the court expressed dissatisfaction with the attorney's filed response to the show cause order, finding it "wholly inadequate." Smith, No. 18-cv-2080 (D.D.C. July 30, 2025). According to the blistering and lengthy minute order, the attorney failed to clarify the process by which he incorporated the cited authorities and accompanying text into the brief, as directed by the court's show cause order. Id. While the attorney identified three software tools used to draft the brief (Pages with Grammarly, ProWriting Aid, and Lexis' cite-checking tool), he did not explain how he utilized these tools to produce the cited cases and fabricated quotations. Id. As a result, the court remained unclear about how a non-existent case citation and fabricated quotes appeared in the brief. Id. Additionally, the attorney explained that he cited only one case, Morris v. Slappy, 461 U.S. 1 (1983), for a false proposition of law. Id. However, he did not address the other three cases in this same category. Id. Furthermore, the attorney did not indicate whether he actually read those cases before citing them in the brief. Id. Ultimately, the court imposed an award of attorney fees in the amount of $8,151. Smith, No. 18-cv-2080 (D.D.C. Oct. 10, 2025), Dkt. 203. In Lafontant v. Coolidge-CLK St. Germaine, No. 24-cv-2536, 2025 WL 2817583, at *1 (E.D. La. Oct. 3, 2025), the plaintiff's attorney filed a memorandum in opposition to a motion for partial summary judgment without verifying the accuracy of the citations contained in the memorandum. The court found that the attorney violated Rule 11(b)(2) by failing to verify the accuracy of the citations in the memorandum. Id. at *3. The court sanctioned the attorney with a $1,000 fine, required the attorney to attend one hour of CLE GAI, and referred the matter to the disciplinary committee for the Eastern District of Louisiana. Id. The plaintiff's attorney admitted responsibility for the citation errors, attributing them to the use of an AI legal research tool. Smith, No. 18-cv-2080, slip op. at 1 (D.D.C. Oct. 3, 2025), Dkt. No. 201. He stated that the AI tool was used to identify legal authorities, but he failed to verify the accuracy of the citations and quotations before filing the brief. Id. at 1-2. The court found the attorney's conduct reckless and egregious, as he relied solely on the AI tool without checking the accuracy of the information. Id. at 2. The court decided that the attorney should pay the attorney fees and costs associated with the defendant's motion for a continuance and the reply brief. Id. at 3. The court noted that the attorney self-reported to the state bar and required him to submit the court's order to supplement the record before the bar. Id. In a bankruptcy adversary proceeding, the court addressed whether the debtors could obtain relief to avoid the sheriff's sale and related judgments, which were allegedly invalid due to various procedural and substantive errors. In re Koger, No. 20-bk-23340, 2025 WL 2807695, at *1-2 (Bankr. W.D. Pa. Sep. 30, 2025). The debtors also claimed that the sale was a fraudulent transfer and that they were victims of a conspiracy due to racial discrimination and political activities. Id. at *8. The court dismissed the adversary proceeding and other bankruptcy matters. Id. at *1. The court found that the debtors lacked standing to assert their claims, that the state court judgments were final and binding, and that their arguments were precluded by prior rulings. Id. at *8-11. The court also noted that the debtors' filings were disjointed, incoherent, and often mischaracterized prior proceedings. Id. at *7. Finally, the court speculated that the debtors might have used AI to draft their pleadings, as some citations referred to non-existent cases. Id. at *7 n.70. While the court made no further comment on the debtors' purported AI misuse, it imposed a one-year filing ban "due to the abusive nature of these proceedings." Id. at *17. In a pro se action, the plaintiff filed a lawsuit against the defendants, alleging various tort claims. Button v. Doherty, No. 24-cv-5026, 2025 WL 2776069, at *1 (S.D.N.Y. Sep. 30, 2025). The magistrate judge recommended dismissing the plaintiffs' claims against one defendant for lack of personal jurisdiction and against the other two defendants for failure to state a claim. Id. The district judge adopted the report and recommendation in its entirety. Id. at *5. Additionally, the district judge noted that the plaintiffs' objections appeared to rely on an AI and contained numerous errors, including mischaracterizing findings and quoting non-existent cases. Id. at *5 n.7. The district judge reminded the pro se litigants of their responsibility to verify the accuracy of AI-generated outputs. Id. Future filings using AI tools must include a signed certification verifying the accuracy of legal authorities and factual assertions. Id. The defendant was convicted by a jury for crimes related to gang activity, drug possession, and two murders; he received a sentence of life imprisonment. United States v. Luciano, No. 24-1251, slip op. at 1 (7th Cir. Sep. 30, 2025), Dkt. No. 30. The defendant filed an appeal, but his appointed counsel moved to withdraw, asserting that the appeal was frivolous. Id. The court reviewed the potential issues raised by counsel, including pretrial motions, juror issues, sufficiency of evidence, credibility of witnesses, jury instructions, and sentencing. Id. at 2-3. The court found no merit in these issues and dismissed the appeal. Id. at 2, 6. Additionally, the court noted that some of the cases cited by the defendant in his Rule 51(b) response could not be found, suggesting that the errors might have been due to mistaken transcription or the use of GAI. Id. at 6. The court encouraged litigants to carefully review their submissions before filing. Id. A False Claims Act case was dismissed for "good cause" in light of motions to dismiss the expert, as the expert had confessed to using ChatGPT. Khoury v. Intermountain Health Care Inc., No. 20-cv-372 (D. Utah Sep. 30, 2025), Dkt. No. 307. In Tomlin v. New Mexico, No. 24-cv-1163, 2025 WL 2784906, at *1 (D.N.M. Sep. 30, 2025), the pro se plaintiff filed a civil rights action against multiple defendants, including the State of New Mexico. The court dismissed the plaintiff's claims, finding that they were barred by the statute of limitations and that her allegations did not meet the necessary legal standards to proceed. Id. The court also addressed concerns about the use of AI tools by the plaintiff in her filings. Id. at *14. The court suspected that the plaintiff may have used AI to generate citations to non-existent cases, which violated Rule 11. Id. The court warned the plaintiff that continued issues with fabricated or misleading authorities may result in sanctions. Id. at *15. In Kertesz v. Colony Tire Corp., 20-cv-12364, 2025 WL 2779094, at *1-2 (D.N.J. Sep. 30, 2025), the plaintiff alleged invasion of privacy and failure to accommodate under the state law against discrimination, among other claims, following the disclosure of his medical conditions and his termination shortly after returning from FMLA leave. The court denied the plaintiff's motion for summary judgment and granted, in part, and denied, in part, the defendants' motion for summary judgment. Id. at *13-14. Additionally, the court noted that the plaintiff's attorney used AI tools, which resulted in erroneous citations and quotations in the briefs. Id. at *5-6. The court declined to impose sanctions but cautioned the attorney about the professional conduct implications of submitting inaccurate information due to AI use. Id. at *6 n.12. In a Fair Labor Standards Act claim, the plaintiff alleged that he was misclassified as a geologist, his work hours were improperly recorded, and he was terminated in retaliation for inquiring about FLSA violations. Herr v. Elos Env't, LLC, No. 25-cv-387, 2025 WL 2319926, at *1 (E.D. La. Aug. 11, 2025). The lawsuit includes a motion to compel and for sanctions against the defendants for allegedly fabricating evidence and acting in bad faith during discovery. Id. At the outset, the court questioned certain authorities cited by the plaintiff in his filings. Id. at *2. The court opined that due to the relative novelty of AI technology, the plaintiff may not be aware that AI programs can produce fake case citations and other inaccuracies in legal documents. Id. The court declined to impose sanctions on the pro se litigant at this time and elected to issue a written warning. Id. The court warned: "Now that the Plaintiff is informed about the risks of using AI-generated legal filings, he understands that he may face sanctions if he cites false, AI-generated legal authority in the future." Id. Ultimately, the court denied the plaintiff's motions to compel and for sanctions, as well as granted the plaintiff's motion to file a supplemental Rule 37 certificate. Id. at *8. Later, the plaintiff moved the court to reconsider a previous order that partially granted and partially denied his motion to compel discovery from the defendants. Herr, No. 25-cv-387, 2025 WL 2754750, at *1 (E.D. La. Sep. 29, 2025). The plaintiff argued that his location data proved the defendants' responses were false and that the court improperly shifted the burden to him. Id. The court denied the motion, finding that the plaintiff's evidence did not prove fraud or clearly demonstrate that the defendants' responses were false. Id. at *2. The court emphasized that factual disputes should be resolved by a trier of fact during the trial, rather than through discovery motions. Id. Additionally, the court addressed concerns related to pretext and the relevance of certain discovery requests, ultimately concluding that Herr's objections were unfounded. Id. at *3. In a previous ruling, the court noted that the plaintiff filed a motion to compel and for sanctions, which the court denied without prejudice after the plaintiff failed to hold a proper Rule 37 conference and improperly cited non-existent cases. Id. at *1. In that ruling, the court first noted that the plaintiff's challenge to the factual accuracy of the defendants’ responses was a matter for resolution by the trier of fact, not via a discovery motion. Id. In Jackson v. BOK Fin. Corp., No. 25-cv-297, 2025 WL 2755868, at *1 (N.D. Okla. Sep. 29, 2025), the pro se plaintiff filed a lawsuit against several defendants, seeking to compel arbitration for 84 separate claims. The plaintiff filed motions to disqualify the defendants' counsel, strike his entry of appearance, and strike his filings, alleging a conflict of interest. Id. The court denied these motions, finding no evidence of a conflict. Id. In reaching a conclusion, the court noted that the plaintiff cited the Federal Arbitration Act, the Fifth Amendment, and various cases (real and unreal), but none of these authorities supported the proposition that an attorney cannot represent his law firm or that an attorney cannot represent both his law firm and that firm's client. Id. at *3. Additionally, the court noted the plaintiff's other problematic filings. In a previous motion filed by the plaintiff to disqualify counsel, the court struck the motion without prejudice after finding many "fake case quotations." Id. Four days later, the plaintiff submitted an amended motion to disqualify, which was substantively similar to the previously stricken filing. Id. The plaintiff removed the parentheses and quotation marks from the four fabricated quotations identified by the court but failed to correct her claim regarding their support for her stated principles or check her other citations for accuracy. Id. The court ordered the plaintiff to show cause as to why sanctions should not be imposed under Rule 11. Id. at *4. The court opined that the combined errors indicate that the plaintiff did not conduct a reasonable inquiry under the circumstances and made legal contentions unsupported by existing law. Id. at *6. The court ordered the plaintiff to respond by October 14, 2025. Id. In the previous order, the court addressed the plaintiff’s motion to disqualify counsel, which contained several quotations that were purportedly from legal cases but were found to be fabricated and not present in the cited cases. Jackson, No. 24-cv-297, 2025 WL 2294916, at *1 (N.D. Okla. Aug. 8, 2025). The court noted that the "fake quotations are just those located in the first two paragraphs of substantive argument [and it] is not the duty of this Court or other parties to waste time poring through cases vainly attempting to find non-existent language." Id. The court struck the motion to disqualify without prejudice to refiling, but warned the plaintiff "that continued fabricated citations to non-existent case quotations or other frivolous filings may result in sanctions including, without limitation, dismissal of his claims." Id. In Burch v. HCA Healthcare, Inc., No. 25-cv-1408, 2025 WL 2772572, at *1 (D. Nev. Sep. 26, 2025), the pro se plaintiff filed suit against the defendants, alleging violations of the federal emergency medical treatment law, disability discrimination statutes, and civil rights protections. The plaintiff filed a motion for expedited discovery, seeking various communications and records related to medical care, corporate policies, and billing matters. Id. The defendants opposed this request. Id. Generally, discovery does not commence until after the Rule 26(f) conference, but the court may permit expedited discovery upon a showing of good cause. Id. the court denied the motion, finding that the plaintiff failed to show good cause for expedited discovery. Id. at *2. Additionally, the court warned the plaintiff about using artificial intelligence for case law verification. Id. at *3. The plaintiff cited non-existent or misleading case law, which the court attributed to potential AI errors. Id. The court emphasized the importance of verifying case law citations and noted that AI can sometimes generate or hallucinate incorrect legal references. Id. at *4. The court cautioned that future citations of nonexistent or misleading case law, whether generated by AI or not, could result in sanctions. Id. In Shaporov v. Levine, No. 22-cv-1150, 2025 WL 2731460, at *1 (D.N.J. Sep. 25, 2025), the plaintiff initiated a civil rights action against five specific police officers and other unidentified officers. The court granted the defendants' motion for summary judgment and dismissed the claims against the unidentified defendants with prejudice. Id. at *15. In ruling, the court expressed concerns with the plaintiff's opposition brief, which contained multiple inaccurate quotations and citations. Id. at *13-15. The court ordered the plaintiff's counsel to show cause why their conduct did not violate these Rule 11 and the state rules of professional conduct. Id. at *15. Pro hac vice and local counsel submitted separate letters to the court in response to the show cause order. Igbokwe Letter, Shaporov, No. 22-cv-1150 (D.N.J. Oct. 8, 2025), Dkt. No. 112; Maglione Letter, Shaporov, No. 22-cv-1150 (D.N.J. Oct. 8, 2025), Dkt. No. 111. The court has not issued a ruling on sanctions. In Perez v. Evans, No. 24-cv-356, 2025 WL 2726792, at *1 (S.D.N.Y. Sep. 25, 2025), the pro se plaintiff filed objections to the magistrate judge's report and recommendation, which suggested dismissing his amended complaint with prejudice. The district judge overruled the objections, adopted the report and recommendation, and dismissed the complaint with prejudice, citing procedural and substantive deficiencies in the plaintiff's claims. Id. at *7. The plaintiff acknowledged using ChatGPT in his initial filing. Id. at *3. The district judge noted that the plaintiff included 17 footnote citations to ChatGPT throughout his objections, including a citation to a copy of a conversation in which the plaintiff made specific prompts to prepare a legal memorandum. Id. While the district judge declined to impose sanctions, partly due to the plaintiff's admission of using ChatGPT. Id. at *4. Additionally, the district judge "would overrule Plaintiff's objections without the identified AI issues." Id. The plaintiff filed a lawsuit against the defendants, alleging sex discrimination and retaliation under Title VII. Black v. Miss. Dep't of Rehab. Servs., No. 23-cv-426, 2025 WL 2723429, at *1 (D. Miss. Sep. 24, 2025). The court granted summary judgment in favor of the defendants, concluding that even if the defendants failed to follow the correct policy, it did not imply intent to discriminate by sex. Id. The plaintiff moved for reconsideration, focusing on whether the defendant executive director lied about his knowledge of the statutory requirement during his testimony. Id. The court denied the motion, finding that the plaintiff's arguments were speculative and did not demonstrate a manifest error of law or fact. Id. at *2. AI implications arose when the plaintiff's counsel admitted that her initial briefs contained false AI-generated content. Id. at *1. Counsel corrected these errors by submitting amended memoranda, which mostly deleted references to the AI-generated inaccuracies. Id. The court acknowledged the correction but denied the motion for leave to file amended memoranda as moot, noting that the corrected briefs remained in the record. Id. at *2-3. The plaintiff filed a lawsuit against the defendants, including breach of an equipment financing agreement and two counts of breach of personal guaranties. BFG Corp. v. Pierce RE Holdings LLC, No. 25-cv-2142, slip op. at 1 (N.D. Ill. Sep. 24, 2025), Dkt. No. 41. The court granted a default judgment against the corporate defendant for failing to retain an attorney, while the claims against the individual defendants remained. Id. The court then denied the defendants' motion to dismiss, finding that the plaintiff's complaint contained a short and plain statement of the claim, giving the plaintiff standing to pursue its claims. Id. at 3. In ruling, the court noted that the defendants cited numerous inapplicable cases, some of which could not be found or did not support the defendants' arguments. Id. at 4. The court suggested that this might be due to the improper use of AI in preparing the defendants' briefings, warning that such use is unacceptable and could lead to sanctions. Id. In Thackston v. Driscoll, No. 24-cv-276, slip op. at 1 (W.D. Tex. Aug. 28, 2025), Dkt. No. 45, the plaintiff filed a lawsuit against the defendant, alleging discrimination, retaliation, and a hostile work environment under the Rehabilitation Act. The defendant filed a motion for judgment on the pleadings, arguing that the plaintiff lacked standing. Id. at 2. In a report and recommendation, the magistrate recommended granting the defendant's motion and dismissing the plaintiff's case. Id. at 15. In the plaintiff's filings, counsel included non-existent legal citations and mischaracterized case law. Id. at 3-4. The magistrate judge identified an "extreme pattern of hallucinated legal citations." Id. at 4-7 (chronicling thirteen problematic case citations). The magistrate judge noted that monetary sanctions, continuing legal education courses, and referral to the state bar would be considered. Id. at 8. Accordingly, the magistrate recommended that the district judge impose sanctions under Rule 11. at 15. The district judge adopted the magistrate's recommendation regarding the grant of the defendant's motion for judgment on the pleadings. The court denied the remaining motions pending as moot and closed the case. Thackston, No. 24-cv-276, 2025 WL 2714123 (W.D. Tex. Sep. 23, 2025). The district judge made no reference to the sanctions recommendation. In a contract dispute, the plaintiffs alleged negligence, breach of contract, and unjust enrichment against the defendant. Vision Mgmt. Grp., LLC v. Constant Aviation, LLC, No. 25-cv-725, 2025 WL 2718525, at *1 (D. Nev. Sep. 24, 2025). In addressing the defendant's motion to dismiss, the court observed that the plaintiffs' brief contained citations to non-existent cases. Id. at *14 nn.11-12. While the court disregarded the citations, it reminded counsel of her responsibilities under Rule 11. Id. at *14 n.12. The court granted the defendant's motion to dismiss and also denied the plaintiff's motions for a preliminary injunction and for leave to file a sur-reply. Johnson v. Mini of Las Vegas, No. 25-cv-725, 2025 WL 2718525, at *1 (D. Nev. Sep. 24, 2025). The court also granted the plaintiff's leave to amend her complaint. Id. In reviewing the plaintiff's motion for leave to file a sur-reply, the court observed that the document appeared to have been prepared using GAI software, as it cited a non-existent case. Id. at *3. Rather than imposing sanctions, the court reminded the parties of their duty under Federal Rule 11 to ensure that legal contentions are warranted by existing law and warned against citing fake cases generated by AI. Id. In Lipe v. Albuquerque Pub. Schs., No. 23-cv-899, 2025 WL 1581155, at *1 (D.N.M. June 4, 2025), the court addressed a discovery dispute involving the plaintiff's motion to compel discovery responses, request for sanctions, and request for an expedited ruling. The court sua sponte struck both the defendant’s supplemental response and the plaintiff’s reply for failing to comply with a court order requiring them to specify which discovery disputes remained unresolved. Id. at *2. The court ordered the parties to file amended briefs that met specific requirements addressing the outstanding discovery issues. Id. While not expressly referencing AI usage, it addressed potentially sanctionable conduct by the plaintiff’s counsel, who included unsupported allegations and misrepresented case law in her briefing. Id. The court voiced concern over the plaintiff’s counsel’s use of spurious citations and cautioned that continued misconduct may result in sanctions or referral to the state bar. Id. The magistrate judge set a show cause hearing where the district judge would consider whether plaintiff's counsel should be sanctioned. Id. at *3. The issue before the court arose from a discovery dispute where the plaintiff's counsel submitted filings containing citations to non-existent cases and misrepresented existing cases. Lipe, No. 23-cv-899, 2025 WL 2695244, at *1 (D.N.M. Sep. 22, 2025). Following the show-cause proceeding, the district judge found that the plaintiff's counsel violated Rule 11 by submitting filings without verifying their accuracy, which included citing authorities that did not exist. Id. at *2-3. While counsel completed a CLE course on the use of AI in legal practice, the district judge was unpersuaded that a CLE course was a sufficient sanction to deter this conduct. Id. at *4. Counsel repeatedly exhibited egregious misconduct by failing to verify the accuracy of filings, responding inaccurately to the court, and submitting additional documents with the same citation errors, indicating a lack of necessary review on multiple occasions. Id. The court ordered counsel to pay a fine of $3,000 and to self-report to the New Mexico and Arizona state bar disciplinary boards. Id. In another order, the court noted another instance of GAI usage without proper review. Lipe, No. 23-cv-899, 2025 WL 2855760, at *2 (D.N.M. Oct. 8, 2025). This time, the court observed that the plaintiff's "briefing no longer contains fabricated citations, it does contain several 'legal contentions' that are simply not 'warranted by existing law.'" Id. at *3. The court emphasized the importance of attorneys diligently reviewing AI-generated content to ensure accuracy and compliance with legal standards. Id. In a pro se bankruptcy adversary proceeding, the debtor moved to reopen the adversary proceeding and vacate the court's order approving a settlement agreement and judgment. In re Molina, No. 21-bk-8139, 2025 WL 2697623, at *1 (Bankr. E.D.N.Y. Sep. 22, 2025). The court denied the debtor's motion, finding that he failed to meet the burden of proof to demonstrate that the settlement agreement was entered into under duress. Id. at *6-7. Additionally, the court addressed motions for sanctions filed by both parties, ultimately denying them. Id. at *22. In reviewing the record, the court found that the debtor included fake case citations in his filings. Id. at *21. The court declined to impose sanctions. Id. For future filings, the court ordered the debtor to include a statement, sworn under penalty of perjury, in which the debtor certifies that he has verified the accuracy of each legal authority he cites or quotes. Id. at *22. This requirement shall remain in effect until the proceedings are concluded. Id. In a post-sentencing matter, the defendant moved for early termination of his supervised release, claiming full compliance with the terms of his release and an inability to get re-licensed as a doctor while on supervised release. United States v. Malik, No. 16-cr-324, 2025 WL 2687413, at *1 (D. Md. Sep. 19, 2025). The court denied the defendant's motion, stating that compliance with supervised release terms alone was insufficient for early termination, emphasizing the seriousness of the defendant's offenses. Id. at *2. Additionally, the court noted that the defendant's addendum contained inaccurate information, including non-existent quotations and citations, which may have resulted from the use of GAI. Id. at 1 n.2. The court warned against the use of AI-generated content that can hallucinate, leading to fake legal citations and misrepresentations. Id. In Gibralter, LLC v. DMS Flowers, LLC, No. 24-cv-174, 2025 WL 2689350, at *1 (E.D. Cal. Sep. 19, 2025), the court ordered the plaintiffs to show cause as to why sanctions should not be imposed after discovering that the plaintiffs cited a fictitious case in their opposition to the motion to dismiss. The court identified the fictitious as a hallucination likely generated from the improper AI usage in legal research. Id. The court admonished the plaintiffs' counsel for carelessness and emphasized the importance of exercising due care when using AI tools in legal filings. Id. at *2. Despite the error, the court discharged the order to show cause without imposing sanctions, acknowledging the counsel's candor and commitment to implementing precautions to prevent future errors. Id. The pro se plaintiff initiated an action against the defendant, alleging default by non-response, violation of UCC § 9-201, trespass, and violation of constitutional rights. Martin v. Redstone Fed. Credit Union, No. 25-cv-548, 2025 WL 2690449, at *1 (N.D. Ala. Sep. 19, 2025). The defendant moved to dismiss, whereby the court found that several of the plaintiff's claims were based on "sovereign citizen" theories. Id. at *4. While the plaintiff "disavow[ed] the characterization of his claims as based upon “sovereign citizen” ideology," the court dismissed counts II, III, and IV "because each is based upon frivolous, sovereign citizen theories, as opposed to cognizable legal claims." Id. at *5. The court also dismissed the plaintiff's other claims. Id. at *7-9. Finally, the court addressed the plaintiff's use of non-existent case citations in his complaint and amended complaint, noting that eight case citations in the complaint and five case citations in the amended complaint did not exist. Id. at *8. The court declined to impose sanctions, but strongly cautioned that any future filings submitted to any federal courts must comply with Rule 11. Id. at *9. A pro se plaintiff brought several claims against the defendants, including constitutional claims under § 1983 for violations of her Establishment Clause, equal protection, and due process rights; a claim under the Rehabilitation Act; statutory perjury claims under federal and state law; and state claims for defamation, intentional infliction of emotional distress, and false light. Bryant v. Pottsgrove Sch. Dist., No. 25-cv-3140, 2025 WL 2691044, at *1 (E.D. Pa. Sep. 19, 2025). The defendants filed a motion to dismiss, which the court granted in part and denied in part. Id. With respect to AI implications, the court observed that the plaintiff filed her response to the defendants' motion within two days. Id. at *1 n.3. The court opined: "To respond so quickly would be a remarkable feat if done by a lawyer. When done by a pro se litigant, it strains credulity." Id. The court noted the potential influence of AI tools on the legal profession, particularly for pro se litigants. Id. The court expressed concern about AI's tendency to generate fake cases and its inability to grasp legal principles and nuances, which could mislead litigants without legal training. Id. Despite these concerns, the court emphasized that pro se litigants must still comply with court rules and ensure their legal contentions are warranted by existing law. Id. After several preliminary filings by the pro se plaintiff (many of the 14 filings were procedurally defective), the district judge referred the matter to the magistrate to address a docket that was spiraling out of control. Ali v. IT People Corp., 25-cv-10815, 2025 WL 2682622, at *1 (E.D. Mich. Sep. 19, 2025). The magistrate judge addressed the defendant's motion for sanctions and the plaintiff's motion for leave to file a second amended complaint. Id. The magistrate denied the defendant's motion for sanctions, citing a lack of compliance with Rule 11's "safe harbor provision" and the resolution of issues by a prior court order. Id. at *2. However, the magistrate imposed sanctions on the plaintiff under its inherent authority due to misrepresentations in his filings, including false legal citations and a non-existent regulatory code. Id. The magistrate admonished the plaintiff that any misrepresentations to the tribunal, whether in fact or in law, will not be tolerated." Id. (emphasis in original). Importantly, the magistrate opined that excessive reliance on AI-generated documents, without confirmation and verification of the citations, did not excuse false statements of law. Id. The magistrate sanctioned the plaintiff $200 for each misrepresentation for a total of $600. Id. at *3. "A United States Magistrate Judge has authority to decide a Rule 11 sanction motion without the added step of a report and recommendation." Id. at *2 n.1. Further, the magistrate ordered the plaintiff to read the pertinent rules and ensure that all subsequent filings complied with the rules. Id. Also, the magistrate granted the plaintiff's motion for leave to file an amended complaint in part. Id. at *6. However, the court ruled that "THIS WILL BE PLAINTIFF'S FINAL PLEADING AND NO FURTHER AMENDMENTS SHALL BE ALLOWED." Id. at *5 (emphasis in original). In Mitchel v. Stellantis Fin. Servs., Inc., No. 24-cv-882, 2025 WL 2676569, at *1 (E.D. Va. Sep. 18, 2025), the pro se plaintiff brought an unlawful repossession action against the defendants. The court addressed whether the defendants had unlawfully repossessed the plaintiff's vehicle, thereby violating the Fair Debt Collection Practices Act and other applicable state laws. Id. at *3. The court granted the defendants' motion to dismiss, finding that the plaintiff failed to state a claim under the FDCPA because a defendant had a present right to repossess the vehicle due to the plaintiff's default. Id. at *9. The court also declined to exercise supplemental jurisdiction over the remaining state law claims, dismissing them without prejudice. Id. Additionally, the court noted that many of the plaintiff's legal citations were inaccurate, suggesting the use of AI drafting tools. Id. at *3 n.6. The court proposed that an exception to the liberal-construction rule for pro se pleadings might be necessary when AI is used to draft them. Id. the court opined "where a pro se individual relies on AI to draft pleadings and thus blurs the line between what is a good faith pro se assertion of an actionable claim and what is a computer-generated morass that only serves to waste court time and resources." Id. In a breach of contract and unjust enrichment action, the plaintiff sought $20 million from the defendant. OTG New York, Inc. v. Ottogi America, Inc., No. 24-cv-7209, 2025 WL 2671460, at *1 (D.N.J. Sep. 18, 2025). The court issued a show cause order to the plaintiff as to why sanctions should not be imposed on its counsel for using GAI in a court filing, resulting in the citation of non-existent cases and fabricated legal propositions. Id. The court found that counsel admitted "admittedly—failed to make a diligent inquiry into the veracity of the cases submitted to the Court within the Reply and still inexplicably signed and certified the submission." Id. at *3. Accordingly, the court imposed a monetary sanction of $3,000 on counsel, emphasizing the need for attorneys to verify AI-generated content to avoid similar violations of Rule 11. Id. In Hill v. Auto Club Fam. Ins. Co., No. 24-cv-107, 2025 WL 2663676, at *1 (S.D. Miss. Sep. 17, 2025), the court addressed whether the pro se plaintiff's late discovery motions should be granted. The court found that the plaintiff did not meet the necessary procedural requirements and failed to demonstrate excusable neglect or good cause for the delay. Consequently, the court denied all of Hill's discovery motions. Id. at *2-8. Additionally, the court expressed concern about the plaintiff's use of fabricated legal citations, which it suspected might be the result of GAI output. Id. at *6-7. The court warned the plaintiff "that submitting documents containing AI hallucinations [was] sanctionable conduct." Id. at *7. In Fagan v. Barnhiser, No. 24-cv-6012, 2025 WL 2654994. at *1 (D.N.J. Sep. 17, 2025), the pro se plaintiff moved for reconsideration after his complaint against the defendants was dismissed. The complaint alleged breach of fiduciary duty, misrepresentation, and gross mismanagement. Id. The court dismissed the complaint without prejudice, stating that the plaintiff asserted a derivative action and lacked standing. Id. The court denied the motion for reconsideration because the plaintiff failed to demonstrate any intervening change in controlling law, new evidence, or a clear error of law. Id. In ruling, the court observed that the plaintiff cited two cases that did not exist. Id. at *2. The defendants moved for sanctions. Id. After the defendants informed the plaintiff about the nonexistent cases, the plaintiff retracted his reliance on them and issued an apology. Id. As a result, the court determined that imposing monetary sanctions would be excessive. Id. Instead, the court reprimanded the plaintiff for his improper conduct and warned him that he could face sanctions, including monetary penalties, if he engaged in similar behavior in the future. Id. Furthermore, the court granted the plaintiff one more chance to revise and resubmit his complaint. Id. In Brown v. Fat Dough Inc., No. 22-cv-761, 2025 WL 2663170, at *1 (N.D.N.Y. Sep. 17, 2025), the pro se plaintiff brought an action against the defendant, alleging employment discrimination. After an initial ruling on a motion to dismiss, the following claims remained retaliation in violation of the ADA, sexual harassment in violation of Title VII, and retaliation in violation of Title VII. Id. The court then addressed the plaintiff's motions for summary judgment and sanctions and the defendant's cross-motion for summary judgment. Id. In reviewing the plaintiff's filings, the court noted that the plaintiff used ChatGPT to draft his filings, which resulted in the inclusion of at least one fictitious legal citation. Id. at *4. The court declined to impose sanctions but cautioned the plaintiff about the substantial risk of sanctions if AI is used without careful verification of all citations. Id. at *5. Ultimately, the court denied the plaintiff's motions and granted the defendant's motion. Id. at *8. The court ordered the clerk to enter judgment and close the action. Id. In a pro se action, the plaintiff alleged breach of contract, breach of good faith and fair dealing, improper repossession, and other damages related to a floor-plan line of credit agreement between the plaintiff's car dealership and the defendant. Tsupko v. Kinetic Advantage, LLC, No. 24-cv-1210, 2025 WL 2677157, at *1 (S.D. Ind. Sep. 17, 2025). A parallel case was also underway in state court. Id. The defendant moved to dismiss (and alternately to stay the proceedings), and the plaintiff's subsequent filings included a motion for sanctions regarding non-existent case law. Id. First, the court concluded that the federal and state cases were parallel suits, and the pertinent case law "weigh[ed] in favor of abstaining from jurisdiction and staying the proceedings pending the outcome of the state litigation." Id. at *4. The court declined to address the merits of the motion to dismiss. Id. In ruling on the defendant's motion, the court noted: [The plaintiff] does not provide a responsive argument other than merely stating that the proceedings are not parallel (Filing No. 58 at 7). As the Court will discuss later, his brief appears to have been created using some form of artificial intelligence ("AI") because the stated reason for his conclusion that the proceedings are not parallel is as follows: "the federal and state cases (if any) are not truly parallel [Plaintiff can insert distinguishing facts here, e.g. the parties or claims differ]." Id. Under these circumstances, the Court determines that the two lawsuits are parallel. Id. at *3. Turning to the AI implications, the defendant filed a notice alerting the court that the plaintiff provided multiple non-existent case citations in his response to the defendant's motion to dismiss. Id. at *4. The plaintiff subsequently filed a motion to strike the defendant's notice, arguing that his citations were correct, and moved for sanctions against the defendant for falsely claiming that his citations were incorrect. Id. Shortly thereafter, in another filing, the plaintiff acknowledged that his citations were incorrect. Id. Accordingly, the court denied the plaintiff's motion to strike and request for sanctions. Id. The court then chronicled the plaintiff's AI-related transgressions, finding that his filings included non-existent case citations and the filings expressly created by AI, with the inclusion of placeholders with prompts from the AI model for the plaintiff to include pertinent facts. Id. at *4. The court previously admonished he plaintiff for his filing practices, and did so again "one final time," instructing that he was not excused from complying with procedural rules, "and any further non-compliance with all applicable Federal Rules of Civil Procedure and the Local Rules of this Court will result in sanctions against him which may include dismissal of this case." Id. at *5. In Mooney v. Nationstar Mortgage LLC, No. 25-cv-114, 2025 WL 3725705, at *1 (S.D. Miss. Sep. 16, 2025), the pro se plaintiff filed a motion to strike, claiming he did not receive any of the defendants' filings by U.S. Mail and had not consented to electronic service. The court found that the plaintiff completed a pro se registration for electronic receipt of court filings, consenting to receive all documents electronically. Id. The court denied the motion. Id. at *2. Additionally, the court observed that the plaintiff's filings contained citations to non-existent cases and incorrect legal propositions. Id. The court reminded the plaintiff of his obligations under Rule 11, which requires that legal contentions be supported by existing law, and warned that future violations could result in sanctions. Id. at *2-3. On
September 16, 2025, the appellate court held that the trial court's denial of
the defendants' motion to vacate was not an abuse of discretion. BKA
Holdings, LLC v. Sam, 2025 IL App (2d) 250160-U, ¶ 1. As part of the review
process, the appellate court addressed the plaintiff's motion for sanctions,
alleging that the defendants' reply brief contained hallucinated authority. Id.
at ¶ 21. The appellate court observed that the Illinois Supreme Court's policy
permitted the use of AI by attorneys, who were advised to responsibly review
all AI-generated content for accuracy and compliance with legal and ethical
standards before submission in court proceedings. Id. the appellate
court found that the defendants’ status as pro se litigants did not excuse
their careless reliance on AI. Id. at ¶ 23. Additionally, the trial
court previously admonished the defendants for their use of AI in this case. Id.
The appellate court granted the plaintiff’s motion for sanctions and struck the
defendants’ reply brief. Id. The appellate court also granted the
plaintiff’s motion for attorney fees and directed the plaintiff to file a
statement of reasonable expenses and attorney fees. Id. In Ebem v. Bondi, No. 24-cv-148, 2025 WL 2642207, at *1 (N.D. Tex. Sep. 15, 2025), the pro se plaintiff, a Nigerian citizen, filed a lawsuit against various defendants, seeking to compel the adjudication of his I-485 application for adjustment of immigration status. The court addressed whether it had subject-matter jurisdiction over the plaintiff's claims under the Administrative Procedure Act and the Mandamus Act, and whether the plaintiff adequately pleaded a Fifth Amendment Due Process claim. Id. at *1-2. The court found that it lacked subject-matter jurisdiction over the APA and Mandamus Act claims and that the plaintiff failed to identify a cognizable liberty or property interest to support his Due Process claim; consequently, the court granted the defendants' motion to dismiss. Id. at *3-6. Finally, the court noted that the plaintiff's motions and objections appeared to be generated via AI, as evidenced by the formatting and style consistent with AI output. Id. at *4 n.2. The court construed any misrepresentations of the record as likely resulting from AI misapplication rather than deliberate attempts to mislead. Id. However, the court emphasized that the use of AI must be accompanied by "actual intelligence" in its execution and warned the plaintiff that false statements in his pleadings could result in sanctions, including dismissal or prosecution for perjury. Id. In Fang v. Hechalou US LLC, No. 25-cv-1180, slip op. at 1 (C.D. Cal. Sep. 12, 2025), Dkt. No. 49, the defendants filed an opposition to a motion for preliminary injunction, containing several erroneous legal citations. In the defendants' subsequent notice of errata, counsel pointed to “inadvertent errors" in the opposition brief. Id. In total, there were six citation errors, four of which involved quotations that did not exist in the cited cases, and two that involved changing the case citations for the proffered proposition. Id. Counsel admitted that AI use resulted in inaccurate legal citations, and counsel failed to verify and confirm the accuracy of the citations. Id. at 2. The court recognized the defense counsel’s honesty in admitting the unverified use of AI, but deemed the resultant errors—particularly in light of recent cases where AI misled attorneys into citing non-existent or fabricated authorities—highly problematic and unacceptable. Id. at 4. The court ruled that reimbursement of 50 percent of the attorney fees generated as a result of the AI-generated citations was a reasonable sanction and that the sanction should be imposed on the law firm that filed the brief, as opposed to the individual attorney or attorneys responsible. Id. at 5. The court also ordered the attorneys to notify the state bar of the sanction. Id. In a pro se action, the plaintiff alleged that the defendant made unlawful decisions regarding a trust. Turnage v. Associated Bank, N.A., No. 25-cv-3004, 2025 WL 3052638, at *1 (D. Minn. Sep. 12, 2025). Additionally, the plaintiff applied for in forma pauperis status, asserting he had no personal assets. Id. Under 28 U.S.C. § 1915(e)(2)(B), the court considered whether the plaintiff's complaint was frivolous or failed to state a claim upon which relief could be granted, as required for in forma pauperis status. Id. at *1-2. The court dismissed the plaintiff's claims against the defendant regarding its refusal to make purchases as frivolous due to the absence of a supporting federal statute and the defendant's status as a non-state actor, while also rejecting his allegations of technical violations of federal law, including misuse of his social security number, for being imprecise and insufficient to establish a claim. Id. A significant issue was the plaintiff's use of non-existent case law citations, likely generated by an AI application. Id. at *2-3. The plaintiff's AI misuse amounted to a Rule 11(b) violation, requiring that filings in federal court be truthful and accurate. Id. at *3. The court imposed filing restrictions on the plaintiff, preventing him from initiating new litigation in the District of Minnesota without representation or prior judicial approval, as a deterrent against future misuse of AI in legal filings. Id. at *3-4. On September 12, 2025, in a pro se action to obtain unemployment benefits, the appellate court affirmed the trial court's order dismissing the plaintiff's untimely claim. DiCristina v. Dep't of Emp. Sec., 2025 IL App (1st) 241462-U, ¶¶ 1-3. In deciding the appeal, the appellate court noted that the plaintiff's opening brief cites non-existent cases and was clearly generated by an AI LLM, as it included repetitive “refined” drafts, suggestions for improvement directed at the plaintiff, and the statement, “Generative AI is experimental.” Id. ¶ 10. While noting that the appellate court was entitled to briefs that clearly defined the issues, cited to authority, and presented cohesive arguments, it declined to strike the plaintiff's brief. Id. ¶ 11. Moreover, the plaintiff's untimely complaint justified the trial court's ruling. Id. ¶¶ 18-19. In SEC v. Hist. Asset Placement Servs. Global, LLC, No. 24-cv-10745, 2025 WL 2674259, at *1 (C.D. Cal. Sep. 12, 2025), the SEC alleged that several defendants engaged in a fraudulent scheme concerning historical bonds. The SEC accused two of the defendants of selling these bonds and preparing purchase agreements with false statements about the bonds' values. Id. These defendants moved to dismiss the claims against them; the court denied the motion, finding that the SEC's complaint sufficiently alleged securities fraud under various sections of the Securities Act and the Exchange Act. Id. at *5-6. In reaching a ruling, the court observed that the defendants' legal briefing was riddled with inaccurate and false citations, suggesting the use of an AI tool that hallucinated legal authority. Id. at *6. This court considered imposing sanctions because the briefing was "so rife with these questionable citations." Id. While the court declined to impose sanctions, it noted cases imposing up to $10,000 in monetary sanctions against pro se parties for citing non-existent legal authority. Id. In Pulido v. Goodleap LLC, No. 24-cv-267, 2025 WL 2807033, at *1 (W.D. Tex. Sep. 11, 2025), the pro se plaintiffs filed a lawsuit against the defendants, alleging violations of the Truth in Lending Act, breach of contract, and wrongful foreclosure. The issue before the magistrate judge was the consideration of the plaintiffs' combined motions to strike, dismiss, and impose sanctions. Id. The magistrate recommended denying these motions, as they were untimely and lacked merit. Id. at *3-4. In reaching a decision, the magistrate noted that the plaintiffs relied upon two non-existent cases in their briefing. Id. at *5. The magistrate resolved the motions without further reference to the non-existent cases. Id. at *6. In Mid-America Apartment Communities, Inc. v. Philipson, No. 23-cv-2186, 2025 WL 2625359, at *1 (W.D. Tenn. Sep. 11, 2025), the pro se defendant requested a post-judgment accounting, claiming it was necessary to exercise his rights and obligations accurately. The court found that the record already contained the necessary documents, rendering his request moot. Id. at *2. A significant aspect of the case involved the defendant's use of AI to generate content in his filings. Id. The court observed that the defendant cited a non-existent case and fabricated a quotation, likely created by a GAI tool. Id. The court warned that future filings containing fictitious citations or quotations could result in sanctions, including monetary penalties. Id. The court opined: The increased use by lawyers and non-lawyers of artificial intelligence to draft legal documents has resulted in a scourge of fictitious case citations in court documents in recent years. Many harms flow from deceptively citing to nonexistent case law and fabricated quotations, “including wasting the opposing party's time and money, the Court's time and resources, and reputational harms to the legal system (to name a few).” Id. (quoting Buckner v. Hilton Glob., No. 3:24-CV-375-RGJ, 2025 WL 1725426, at *7 (W.D. Ky. June 20, 2025) and Morgan v. Cmty. Against Violence, No. 23-CV-353-WPJ/JMR, 2023 WL 6976510, at *8 (D.N.M. Oct. 23, 2023)). The court warned that future filings containing fictitious citations or quotations could result in sanctions, including monetary penalties. Id. at *3. In a pro se § 1983 action, the defendants conducted a traffic stop of an Uber driver (with the plaintiff as a passenger), which involved a pat-down of the plaintiff. Bradley v. Eichhorn, No. 25-cv-959, 2025 WL 2625293, at *1 (S.D. Ohio Sep. 11, 2025). After attempting to flee the scene, the defendants apprehended the plaintiff and found illegal substances on him. Id. The plaintiff was subsequently charged in state court. Id. In the § 1983 proceeding, the court granted the plaintiff's request to proceed in forma pauperis and allowed him to proceed on certain claims against the officers in their individual capacities (but dismissed a long list of other claims). Id. at *1, *3. In ruling, the court suspected that the plaintiff's inaccurate case citations were the result of GAI and cautioned that future submissions relying on inaccurate or non-existent authorities may be grounds for sanctions. Id. at *4 n.3. In an action involving two pro se defendants, the court denied the defendants' motion to compel discovery due to procedural defects. Head v. Franklin, No. 24-cv-4741, 2025 WL 3190840, at *1 (N.D. Ga. Sep. 9, 2025). Additionally, the court addressed the defendants' use of fake case citations, which had been previously warned against. Id. The court emphasized that signing a pleading certified that the legal contentions are warranted by existing law, and using fictitious case citations was considered a form of lying to the court. Id. at *2. The court warned the defendants that future false citations would be treated as a Rule 11 violation and could result in severe sanctions. Id. A pro se plaintiff sued the defendants, alleging wrongful foreclosure among other violations of federal and state laws. Asker v. Bank of Am., N.A., No. 24-cv-5323, 2025 WL 2889173, at *1-2 (N.D. Ga. Sep. 9, 2025). The issue before the court was whether the plaintiff's fourth and fifth amended complaints should be dismissed due to being shotgun pleadings, barred by the statute of limitations, lacking standing, and failing to state a claim. Id. at *3-4. After an extensive review, the court dismissed the plaintiff's fourth and fifth amended complaints. Id. at *13. The court also noted that the plaintiff's filings appeared to use GAI, as evidenced by citations to non-existent case law. Id. at *8. The court opined that the citation of non-existent cases was sanctionable, but declined to address the matter as the defendants' arguments raised in their motions to dismiss were well-taken. Id. In Robinson v. Oglala Sioux Tribe, No. 25-cv-289, 2025 WL 2609573, at *1 (W.D. Okla. Sep. 9, 2025), the pro se plaintiff filed an "Emergency Motion for Protective Order, Sanctions, and Court Intervention" against the defendants. The court reflected that the case (at this point still "in its infancy") has already generated more than 100 filings, mostly by the plaintiff. Id. Previously, the court warned the plaintiff about adhering to litigation rules and the potential for sanctions, including dismissal with prejudice, if she failed to comply. Id. Now, the court addressed the plaintiff's conduct warranted sanctions for sending threatening correspondence, submitting fabricated evidence, and filing excessive and frivolous motions, warrants sanctions, specifically dismissal with prejudice. Id. at *2. The court found that the plaintiff's actions constituted sanctionable conduct, while also noting that the plaintiff's filings contained non-existent and misrepresented legal authority. Id. at *3-4. The plaintiff claimed that her use of AI to assist her with the litigation was not prohibited. Id. at *4. The court explained that Rule 11 obligations were not altered by the technology used in preparing court filings. Id. The court found that the submission of non-existent and misrepresented legal authority, regardless of the use of AI, constituted sanctionable conduct. Id. After reviewing the record, the court concluded that the dismissal of the plaintiff's claims with prejudice was the appropriate sanction. Id. at *2-7. In reaching a decision, the court opined:
Id. at *7. In Tercero v. Sacramento Logistics, LLC, No. 24-cv-953, 2025 WL 2605020, at *1 (E.D. Cal. Sep. 9, 2025), the court addressed the conduct of the plaintiff's counsel in submitting a motion for reconsideration filled with erroneous and non-existent citations. The court previously ordered arbitration for the plaintiff's claims, which counsel sought to challenge through a motion for reconsideration. Id. However, the motion contained numerous fabricated citations, including two cases that do not exist, and misrepresented other cases by citing them for propositions they did not support. Id. at *3. After reviewing the filing, the court found that counsel's conduct violated Rule 11 and the local rules, which required attorneys to ensure the accuracy and validity of legal contentions. Id. at *8. Counsel included non-existent cases, as well as falsely attributing language as direct quotations from cases and misrepresenting cases by citing them for propositions they do not support. Id. at *8-9. While counsel denied using AI, the court emphasized that citing non-existent case law or misrepresenting case holdings was a false statement to the court, regardless of whether AI was involved. Id. at *10. The court opined that counsel's conduct was akin to contempt of court due to the submission of fictitious case citations and her failure to provide credible explanations for the errors. Id. at *11. Ultimately, the court imposed sanctions on counsel, including a $1,500 monetary penalty, a requirement to serve a copy of the sanction order on her client, and a directive for the Court Clerk to notify the state bar. Id. at *13. Following a show cause hearing, the magistrate judge issued a report and recommendation that the plaintiff's attorney should be personally sanctioned for filing a brief that contained non-existent case citations. Davis v. Marion Cnty. Super. Ct. Juv. Det. Ctr., No. 24-cv-1918, 2025 WL 2502308, at *5 (S.D. Ind. Sep. 2, 2025). The attorney admitted responsibility for the errors, attributing them to a short deadline and his reliance on a paralegal to draft the brief. Id. at *1. The magistrate judge found that the attorney did not verify the citations using available legal research tools (the attorney represented that he subscribed to Lexis). Id. at *2. The magistrate judge opined: "It would have taken only a few minutes to check the validity of the citations in the brief using LEXIS before filing it." Id. The magistrate judge recommended sanctions against the attorney for failing to ensure the accuracy of the information provided in the relevant court filing, emphasizing that the use of AI tools in drafting legal documents was not inherently improper. Id. The magistrate judge explained that the responsibility lay with the attorney to verify the accuracy of the citations, regardless of whether AI was used. Id. at *3. The court noted that hallucinated cases created by GAI tools were widely discussed, but the attorney's paralegal claimed to have used Fastcase instead of AI. Id. at *2. The magistrate judge recommended a $7,500 sanction for the Rule 11 violations and referred the matter to the chief district judge for further consideration of any additional discipline. Id. at *5. In a miscellaneous action to address the referral, the chief district judge subsequently referred the matter to the state disciplinary commission. In re Sture, No. 25-mc-47 (S.D. Ind. Sep. 8, 2025), Dkt. No. 73. In objecting to the magistrate's recommendation, the attorney asserted that referral to the disciplinary commission was a sufficient deterrent and that monetary sanctions were not warranted. In re Sture, No. 25-mc-47, slip op. at 1 (S.D. Ind. Oct. 10, 2025), Dkt. 94. The chief district judge concluded that this miscellaneous case only addressed the disciplinary referral, and not any potential Rule 11 sanctions; the attorney's objections were denied. Id. at 2. The plaintiff sued the defendant, initially alleging state law claims for malicious prosecution, false imprisonment, false arrest, and battery. Poole v. Walmart, Inc., No. 25-cv-603, 2025 WL 2577025, at *1 (N.D. Ill. Sep. 5, 2025). The case was removed to federal court based on diversity jurisdiction. Id. The court previously dismissed the plaintiff's claims but allowed him to amend his complaint. Id. In the amended complaint, the plaintiff reasserted claims for malicious prosecution, battery, and false arrest, and added claims for respondeat superior and spoliation of evidence. Id. The defendant moved to dismiss under Rule 12(b)(6) for failure to state a claim. Id. The court granted the defendant's motion to dismiss in part; the plaintiff's malicious prosecution, battery, and § 1983 claims were dismissed with prejudice, and the defendant's motion was denied with respect to the false arrest and spoliation claims. Id. at *5. In ruling, the court noted that the plaintiff cited non-existent cases and referenced an outdated court district, which may have been the result of GAI usage. Id. The court reminded the plaintiff of his Rule 11 obligations to ensure the accuracy of his filings and warned of potential sanctions for non-compliance. Id. In an appeal of the denial of Social Security benefits, the court addressed three motions. Thompson v. Comm'r of Soc. Sec. Admin., No. 25-cv-365, 2025 WL 2555732, at *1 (D. Ariz. Sep. 5, 2025). Two of the motions related to non-existent quotations and mischaracterizations of cases in the plaintiff's brief. Id. The court opined that these issues were consistent with errors generated by AI. Id. Fundamentally, the court reviewed the ALJ's determination, and the plaintiff argued that the ALJ improperly dismissed his mental impairments, formulated a residual functional capacity unsupported by medical evidence, and conducted a flawed step-five analysis by identifying jobs that conflicted with his stooping limitation. Id. at *3. Returning to the AI implications, the court struck the identified portions of the plaintiff's brief. Id. at *1. Ultimately, the court found that the ALJ's decision was supported by substantial evidence and affirmed the denial of benefits. Id. at *8. In a pro se action, the plaintiff filed a lawsuit against multiple defendants, alleging RICO violations and various state-law claims. Stanford v. Vida, No. 25-cv-792, 2025 WL 3190676, at *2 (W.D. Tex. Sep. 4, 2025). The plaintiff had a history of filing frivolous lawsuits and was declared a vexatious litigant; thus, he was required to seek leave before filing new litigation in federal court. Id. Ultimately, the court granted the plaintiff's request to proceed in forma pauperis but recommended dismissing his RICO claims with prejudice as frivolous under 28 U.S.C. § 1915(e)(2)(B). Id. at *1, *4, *6. The court also recommended dismissing his state-law claims without prejudice due to a lack of jurisdiction, as the federal claims had been dismissed, and there was no diversity between the parties. Id. at *4. Additionally, the court warned the plaintiff that continued filing of frivolous or duplicative suits could result in sanctions or a pre-filing injunction. Id. at *5. Additionally, the court found two unidentifiable cases and several misrepresentations attributed to other cases in the plaintiff's filings. Id. The court warned the plaintiff that he could face sanctions, which may include monetary penalties or a pre-filing injunction that would prevent him from filing future lawsuits. Id. In Nelson v. Navient Solutions, LLC, No. 24-cv-25, 2025 WL 2633962, at *1 (S.D. Iowa Sep. 4, 2025), the pro se plaintiff moved to alter or amend the court's previous order, which dismissed her amended complaint with prejudice. The plaintiff argued that newly discovered evidence and manifest errors warranted reconsideration under Rule 59(e); however, the court found that the plaintiff failed to meet the requirements for newly discovered evidence and did not demonstrate manifest error. Id. In denying the motion, the court cited the plaintiff's lack of diligence in obtaining new evidence, the failure to establish manifest error, and improper attempts to amend the complaint without leave of court. Id. at *1-2. Additionally, the court noted the plaintiff's repeated citation of non-existent legal authorities, suggesting improper use of GAI in drafting court documents. Id. at *3. According to the court, this was the third brief in which the plaintiff cited non-existent cases, indicating a persistent misuse of GAI in court filings, which wasted judicial resources and misled the tribunal. Id. at *3. The court also noted that the plaintiff failed "to address her pattern of citing non-existent legal authorities, a troubling practice that has persisted throughout these proceedings." Id. at *2 n.1. A pro se plaintiff brought several claims against the defendants related to the financing of a vehicle he purchased. Nixon v. Ken Ganley Ford West, No. 25-cv-575, 2025 WL 2600359, at *1 (N.D. Ohio Sep. 3, 2025). The plaintiff's claims included violations of the Truth in Lending Act, the Equal Credit Opportunity Act, and state usury laws, as well as a deceptive act under the Ohio Consumer Sales Practices Act. Id. The defendants moved for judgment on the pleadings. Id. The court granted the defendants' motion due to the plaintiff's failure to oppose or request extensions. Id. The court found that the plaintiff's federal claims did not meet the basic pleading standards and also declined to exercise supplemental jurisdiction over the state-law claims. Id. at *3-4. In reaching a conclusion, the court noted that the plaintiff appeared to have used GAI in drafting some of his motions, which cited non-existent cases. Id. at *5. The court and the defendants could not locate numerous cases cited by the plaintiff in his filings. Id. The court declined to impose sanctions in this instance, but warned that relying on AI-generated content that included non-existent authorities could subject a litigant to sanctions under Rule 11. Id. In a Chapter 11 bankruptcy, the debtor requested court approval to pay pre-petition claims of critical creditors or vendors essential for ongoing operations and reorganization. In re Whitehall Pharmacy LLC, 672 B.R. 768, 769 (Bankr. E.D. Ark. 2025). On September 3, 2025, the court issued a show cause order to verify the accuracy of a citation in the debtor's motion. Id. The attorneys acknowledged using AI in preparing the motion, which led to the inclusion of a non-existent case citation. Id. at 771. The court recognized that while AI can assist in legal research, it did not absolve attorneys of their duty to ensure the accuracy of their filings. Id. at 774-75. The court ultimately opted not to impose sanctions, considering the attorneys' remedial actions and safeguards, including discontinuing the use of AI for preparing court documents and implementing additional oversight measures. Id. at 775. The court also noted that the order would be transmitted to the state professional conduct office to supplement the attorney's election to self-report. Id. In Hobbs v. Goncharko, No. 25-cv-3398, 2025 WL 2544001, at *1 (N.D. Ill. Sep. 3, 2025), a pro se plaintiff filed a lawsuit against the defendants, alleging racial discrimination, disability discrimination, and retaliation under the Fair Housing Act, as well as a discriminatory breach of contract claim under 42 U.S.C. § 1981. The court granted the defendants' motions to dismiss and allowed the plaintiff to amend the complaint for some of the claims. Id. at *8. In reviewing the plaintiff's brief, the court noted that the plaintiff twice cited a case (a "ghost citation") that neither the court nor defense counsel could locate. Id. at *5. The court reminded the plaintiff that Rule 11 applies to pro se litigants, indicating that sanctions could occur for referencing a non-existent case, especially if the citation was not merely an error, as submitting any pleading or motion acknowledges responsibility for its contents. Id. at *5 n.7. In Kholod v. Nationstar Mortgage LLC, No. 24-cv-1631, 2025 WL 2327933, at *1 (M.D. Pa. July 22, 2025), a pro se plaintiff alleged that the defendant was the recipient of unauthorized withdrawals from a business account without his consent. The plaintiff claimed violations of the Electronic Funds Transfer Act, Article 4A of the UCC, the state's unfair trade practices and consumer protection law, and breach of contract. Id. at *2. The defendants moved to dismiss. Id. at *1. The magistrate judge recommended that the defendants' motions to dismiss should be granted, and the plaintiff's complaint dismissed without prejudice and with leave to amend. Id. at *9. The magistrate instructed further that if the plaintiff did not file an amended complaint, the remaining state law claims should be remanded. Id. In reaching a conclusion, the magistrate addressed the eight cases the plaintiff included in his complaint as support for his claims for relief. Id. at *6. The magistrate observed that the citations were incomplete, but a search for each case on Westlaw and LexisNexis was "largely fruitless." Id. The magistrate cautioned the plaintiff about using fake case citations, warning that such use may lead to sanctions under Rule 11. Id. at *8. The district judge adopted the magistrate's report and recommendation. Kholod, No. 24-cv-1631, 2025 WL 2534036, at *1 (M.D. Pa. Sep. 3, 2025). Because the plaintiff failed to file an amended complaint or request an extension within the specified time, the district judge dismissed the federal claims with prejudice and remanded the state law claims. Id. at *1-3. In Pete v. Houston Methodist Hosp., No. 25-cv-273, 2025 WL 2544001, at *1 (E.D. Tex. Sep. 3, 2025), the pro se plaintiff filed a motion for default judgment, claiming that she served the defendant and that the defendant had not responded. However, at a hearing, the plaintiff admitted that she had not actually served the defendant and was not entitled to a default judgment. Id. The court found that no summons had been issued, no service had been perfected, and no entry of default had been made by the clerk; accordingly, the court denied the motion. Id. In reaching the decision, the court noted that the plaintiff claimed in her motion that she had effected service on the defendant, including an unsigned affidavit from an attorney (purportedly admitted to the Texas bar) to support the claim. Id. at *1, *1 n.1. Later, the plaintiff admitted that she never met the attorney and that the attorney did not represent her. Id. at *1. The court found that the State Bar of Texas had no record of the attorney. Id. The court cautioned the plaintiff about AI usage and warned that all filings must comply with Rule 11. Id. In Lothamer Tax Resol., Inc. v. Kimmel, No. 25-cv-579, 2025 WL 2490380, at *1 (W.D. Mich. Aug. 29, 2025), the plaintiffs filed a lawsuit against the pro se defendant (a former employee), alleging multiple violations. The plaintiffs also sought a preliminary injunction to prevent the defendant from using or sharing confidential information. Id. The court found that the plaintiffs did not establish a right to preliminary relief for some of the claims; however, the found that the plaintiffs were entitled to injunctive relief for the defendant's breach of the non-disparagement provision of his employment agreement. Id. at *4. As a result, the court decided to hold an evidentiary hearing to resolve disputed factual issues related to the defendant's alleged breach of the non-retention provision. Id. In reviewing the defendant's briefs, the court found "a substantial amount of the legal authority he purports to rely on is either mischaracterized or entirely fictitious." Id. at *14. The court surmised that the fictitious citations were the result of using GAI. Id. The court declined to impose sanctions because the defendant "may not have recognized the risks of using AI." Id. In a subsequent order, the court addressed the defendant's "pattern of submitting misleading filings." Lothamer Tax, No. 25-cv-579, slip op. at 1 (W.D. Mich. Dec. 1, 2025), Dkt. 184. After reviewing the defendant's sanctionable misconduct, the court imposed a penalty of $2,900. Id. at 15. In United States v. Sethi, No. 20-cr-77, 2025 WL 2483977, at *1 (E.D. Tex. Aug. 28, 2025), the defendant was initially indicted on multiple counts of wire fraud and money laundering in 2020. The defendant pleaded guilty to money laundering under a plea agreement but later attempted to withdraw his plea, claiming coercion by counsel. Id. The court denied his motion to withdraw the plea, and after rejecting the plea agreement, the defendant's case went to trial. Id. He was convicted by a jury on seven counts of wire fraud and one count of money laundering. Id. Throughout the proceedings, Sethi was represented by various attorneys, but eventually, he chose to represent himself. Id. Later, the defendant filed a motion to inform the court of newly discovered exculpatory evidence and his request for time to present a Rule 33 motion before sentencing. Id. The defendant also requested the appointment of standby counsel and a show cause hearing on alleged constitutional violations. Id. The court denied these requests, stating that the defendant failed to provide any new exculpatory evidence and that his claims were unsupported. Id. at *2-3. The court also explained that the defendant did not have a constitutional right to standby counsel and that his Faretta rights were not violated. Id. at *3-5. In reaching a decision, the court noted that the defendant "marshal[ed] numerous fabricated quotes, vague assertions, and nonexistent case law to support his claims that his constitutional rights are being violated." Id. at *5. The court explained further that "eighteen of the purported quotations from various cases are complete fabrications, and in some instances [the defendant] has cited cases that do not exist. Id. The court concluded by opining: "The common theme in [the defendant's submissions] is his unrelenting attempt to mislead and manipulate the Court, and to delay the proceedings in this case." Id. While the ruling did not expressly reference AI-generated fabrications, the hallmarks of non-existent cases and fabricated quotations suggested as such. In Allbaugh v. Univ. of Scranton, No. 24-cv-2237, 2025 WL 2484188, at *1 (M.D. Pa. Aug. 28, 2025), the pro se plaintiff filed a complaint against the defendant alleging sex-based discrimination. The plaintiff claimed that the hiring decision was discriminatory because his interview was conducted by women, the staff listed on the university's website were all women, and a woman was ultimately hired for the position. Id. The defendant moved to dismiss for failure to state a claim. Id. The court found that the plaintiff's allegations did not create a reasonable inference of discrimination and granted the defendant's motion to dismiss. Id. at *4, *7. The court dismissed the plaintiff's complaint without prejudice. Id. at *7. In reaching a conclusion, the court noted that the plaintiff relied on AI-generated content without verifying its accuracy in violation of the Federal Rules of Civil Procedure and the court's standing order on the use of GAI. Id. at *6. In lieu of the plaintiff's pro se status, the court found that "a fine on the lower end of the range of fines imposed by courts for similar offenses to be appropriate." Id. The court ordered the plaintiff to pay a fine of $1,000. Id. Subsequently, the court denied the plaintiff's motion for reconsideration. Allbaugh, No. 24-cv-2237, 2025 WL 3048971, at *3 (M.D. Pa. Oct. 31, 2025). Additionally, the court noted that the plaintiff cited to unreported cases in his motion for reconsideration but failed to provide those cases to the court in accordance with local rules. Id. at *3 n.2. The court implied imposition of sanctions, opining: "Even after being sanctioned, [the plaintiff] continues to ignore the local rules." Id. In a contract dispute, the plaintiff claimed damages of more than $11 million and brought several claims, including breach of contract, breach of the implied covenant of good faith and fair dealing, and violation of the Florida Deceptive and Unfair Trade Practices Act, among others. Multiphone Latin Am. v. Millicom Int'l Cellular S.A., No. 25-cv-23249, 2025 WL 2480412 (S.D. Fla. Aug. 28, 2025). The court granted the motion in part but allowed the breach of contract claim to proceed. Id. at *4-5. In the ruling, the court noted several deficiencies with the plaintiff's filings, including two non-existent cases. Id. at *10. The court referred the attorneys to the Ad Hoc Committee on Attorney Admissions, Peer Review, and Attorney Grievance, as well as the Florida Bar, for investigation. Id. at *11. In Lee v. R&R Home Care, Inc., No. 24-cv-836, 2025 WL 2481375, at *1 (Aug. 28, 2025), the court addressed whether the plaintiff's attorney should be sanctioned for violating Rule 11. The court found that the attorney signed and filed a memorandum in opposition to a motion to dismiss without verifying the accuracy of a citation and a quotation contained in the memorandum. Id. The citation and quotation were found to be fabricated, and the attorney admitted to using Google Gemini, a GAI platform, to draft the brief without verifying the sources. Id. The court determined that the attorney's conduct violated the rule because he failed to confirm the existence and validity of the legal authorities he cited. Id. at *3. While the court acknowledged the attorney's candor and efforts to educate himself on ethical AI use, these factors did not excuse the misconduct. Id. at *4. The court imposed a $1,000 sanction on the attorney and referred him to the disciplinary committee, underscoring the importance of verifying AI-generated content in legal practice. Id. In United States v. DeBaere, No. 19-cr-9, 2025 WL 2474926, at *1 (W.D. Va. Aug. 27, 2025), the pro se defendant filed a motion for early termination of supervised release and a motion to compel the production of the probation office's supervision report. The defendant was sentenced to 70 months of imprisonment and 15 years of supervised release after pleading guilty to accessing child pornography; he was currently in the sixth year of his supervised release (to end in 2034). Id. The court denied DeBaere's two motions for early termination of his release, citing the serious nature of his offense, the need for continued deterrence, and the importance of public safety. Id. at *1, *6, *8. In ruling, the court expressed concern over the defendant's reliance on fabricated legal authorities in his filings. Id. at *3 n.6. The court emphasized the responsibility of parties to verify the accuracy and validity of all cited authorities, warning that future reliance on fictitious sources could result in sanctions. Id. In a Chapter 13 bankruptcy case, the debtors filed an adversary complaint and a motion for a preliminary injunction against a creditor, alleging a violation of the automatic stay. In re Richburg, 671 B.R. 918, 919 (Bankr. D.S.C. 2025). At the outset, the court explained: The legal profession has entered a brave new world of technological advances. Generative artificial intelligence (“AI”) has become increasingly accessible in recent years, making it easier than ever to quickly distill information from a plethora of sources. Many lawyers have embraced this technology, seeing it as a valuable tool to help them serve their clients in more efficient and cost-effective ways. As with other new development in the practice of law, there are growing pains. Attorneys must reconcile the integration of new technology in their work with their existing ethical duties and professional responsibilities. Without proper knowledge of how AI works, lawyers may unjustifiably rely on the content it generates in ways that violate rules of professional responsibility. Id. The court then addressed the debtors' pleading that cited non-existent caselaw generated by AI. Id. The debtors' attorney, with 40 years of experience, admitted to using the AI-generated citations without verifying their accuracy. Id. Following this revelation, the court issued a show cause order and imposed non-monetary sanctions on the attorney. Id. The court emphasized the importance of verifying sources and aimed to highlight the potential consequences of relying on generative AI in legal practice as a cautionary lesson for the legal community. Id. The court determined that a nonmonetary sanction for the attorney to complete three hours of continuing legal education in addition to any annual requirements that may be imposed on the attorney by the state bar was appropriate in the circumstances. Id. at 925-26. The petitioner sought review of an order by the respondent, revoking his Certificate of Registration and denying any pending applications to modify or renew it. McCarthy v. U.S. Drug Enf't Agency, No. 24-2704, 2025 WL 2028399, at *1 (3d Cir. July 21, 2025). The respondent's action was based on the petitioner's issuance of prescriptions for controlled substances without being supervised by a physician, as required by state law. Id. After the administrative ruling in favor of the respondent, the issue on appeal was whether the respondent's revocation of the petitioner's certificate was justified and whether the administrative decision was unconstitutional. Id. at *1-2. The court found that the petitioner failed to demonstrate a causal link between the removal protections and his injury, and that the respondent's decision was supported by substantial evidence. Id. at *3. The court noted that the petitioner's counsel relied on summaries of the respondent's adjudications; these summaries were generated by AI. Id. Seven of these summaries were inaccurate, and the eighth decision did not exist. Id. Counsel admitted that he never confirmed the accuracy of the summaries or even that the decisions existed. Id. Later, counsel acknowledged that he knew about the erroneous summaries and non-existent case "long before the filing of his response." Id. at *3 n.5. The court disregarded the portion of the brief containing the problematic material. Id. at *3. Finally, the court issued an order for counsel "to show cause why he should not be sanctioned for his conduct, particularly for his lack of candor to the Court." Id. at *3 n.5. The court has not yet issued a written opinion or order regarding sanctions, as of August 27, 2025. In this case, the plaintiff initiated an action alleging violations of the Puerto Rico Civil Code and a tort claim. Mintvest Cap., Ltd. v. NYDIG Trust Co., No. 25-cv-1019, slip op. at 1 (D.P.R. June 23, 2025), Dkt. No. 100. During the proceedings, the magistrate judge addressed the defendant's motion to strike filings by the plaintiff, which allegedly contained "numerous non-existent cases, quotations that do not appear in the cited cases, and references to cases that do not support the legal propositions for which they are cited." Id. The plaintiff’s counsel admitted that many errors in the motions were due to the use of the AI platform Claude and insufficient verification of the AI-generated content. Id. at 4. The magistrate judge acknowledged that while AI may serve as a useful tool in litigation, attorneys remain responsible for ensuring the accuracy of their citations and are held to a heightened standard of care and diligence. Id. at 10. The magistrate judge found that "[g]iven the number of incorrect citations, faulty references, and non-existent cases cited by Plaintiff’s counsel, sanctions are appropriate under Rule 11." Id. at 11. The magistrate judge recommended that the plaintiff’s counsel pay the attorney fees incurred by the defendants in relation to the plaintiff’s submissions and filings. Id. The court has not yet issued a written opinion or order regarding sanctions, as of August 27, 2025. The pro se plaintiff initiated an action, alleging inadequate supervision, harmful restraint, and harassment by school personnel, as well as claims under federal law. Wilt v. Whitehouse Indep. Sch. Dist., No. 24-cv-375, 2025 WL 2633210, at *1-2 (E.D. Tex. July 22, 2025). The magistrate judge recommended partially granting the motion to dismiss by dismissing the IDEA claim for lack of administrative exhaustion and other claims for failure to state a claim, except for the ADA claim, which is exempt from the IDEA's exhaustion requirement. Id. at *4-5. In reaching a decision, the magistrate reflected that several case citations in the plaintiff's filings appeared to be fabricated, possibly using GAI in violation of court rules. Id. at *8-9. The court warned the plaintiff that further use of non-existent case citations may result in sanctions. Id. at *9. The district judge subsequently adopted the report and recommendation. Wilt v. Whitehouse Indep. Sch. Dist., No. 24-cv-375, 2025 WL 2438799, at *2 (E.D. Tex. Aug. 25, 2025). In an international business dispute, the plaintiff alleged that the defendants misappropriated the plaintiff's technology to build additional plants without compensation, leading to arbitration in Zurich, Switzerland, where the plaintiff was awarded damages. Chenco Eng'g & Consulting GmbH v. Do-Fluoride New Materials Co. Ltd., No. 24-cv-632, 2025 WL 2430556, at *1-2 (D. Idaho Aug. 22, 2025). The issue before the court was whether the case should be remanded to state court due to a lack of federal jurisdiction. Id. at *6-7. The court concluded that the action concerns a foreign judgment, not an arbitral award, and thus remanded the case to state court. Id. at *7. In reaching a decision, the court observed that the defendants' motion contained fictitious case quotations, suspecting the use of AI. Id. at *5. The court reminded counsel of their professional obligations to provide accurate legal representations. Id. In a creditor action against a debtor, the creditors initiated an adversary proceeding to deny the debtor's bankruptcy discharge and to declare the debt as non-dischargeable. In re Mascio, No. 25-bk-10631, 2025 WL 2434832, at *1 (Bankr. D. Colo. Aug. 22, 2025). The court denied the pro se debtor's motion to dismiss. Id. at *12. In reaching a conclusion, the court admonished the debtor about the use of AI for legal research. Id. at *15. The court cautioned that any use of AI must comply with Rule 11, and the failure to do so might result in sanctions. Id. On August 20, 2025, in an appeal of a trial court's termination of parental rights, the appellate court affirmed that the trial court's unfitness and best interest findings were not against the manifest weight of the evidence, and the termination proceedings were not fundamentally unfair. In re R.L., 2025 IL App (4th) 241211-U, ¶ 1. In reaching a conclusion, the appellate court noted that the appellant's attorney may have violated Illinois Supreme Court Rules and Illinois Rules of Professional Conduct for citing non-existent caselaw in other cases. Id. ¶¶ 116-17; see In re Boy, 2025 IL App (4th) 241427; In re A.S., 2025 IL App (4th) 250298-U; In re S.M., 2025 IL App (4th) 250277-U. The appellate court noted that the attorney cited non-existent caselaw in the instant appeal, too. In re R.L., 2025 IL App (4th) 241211-U, ¶¶ 118, 139, 152. The appellate court declined to impose sanctions because the attorney had been referred to the disciplinary committee and will be surrendering his law license. Id. ¶ 118. The pro se plaintiff brought an action against the defendants, alleging that they were responsible for her loss of approximately $275,000 in cryptocurrency. Lahti v. Consensys Software Inc., No. 24-cv-183, 2025 WL 2404454, at *1 (S.D. Ohio Aug. 20, 2025). The matters before the court included several motions filed by the parties. Id. In short, the court granted one defendant's motion to compel arbitration and the plaintiff's motion to amend the complaint against the other defendant. Id. at *9. In ruling, the court noted that the plaintiff included fictitious citations in filings throughout this case. Id. at *3. However, because the court struck the plaintiff's reply (as unnecessary in lieu of the defendant's motion to compel arbitration), the court did not consider the defendant's request to strike the filing as a sanction for the plaintiff's misleading the court with fictitious case citations. Id. The court warned that such conduct was sanctionable under Rule 11. Id. In Garces v. Hernandez, No. 25-50342, 2025 WL 2401001, at *1 (5th Cir. Aug. 19, 2025), the pro se plaintiff-appellant appealed the dismissal of his civil rights suit, where the federal trial court ruled that a final state court judgment precluded his claims. Initially, the plaintiff sued the defendants, alleging wrongful eviction from a hotel and seeking damages for violations of federal and state statutes. Id. The state trial court dismissed his claims, and the plaintiff did not appeal, making the judgment final. Id. The plaintiff then filed the same claims in federal court, which were dismissed on the grounds of claim preclusion. Id. On appeal, the plaintiff raised the same arguments that were found to be without merit, and the district court's judgment was affirmed. Id. In reaching a decision, the court noted that the plaintiff's litigation conduct included citing several non-existent legal authorities, which suggested the use of GAI. Id. at *2. The court admonished the plaintiff, emphasizing that pro se litigants must verify the accuracy of AI-generated information and that the plaintiff was on notice that future frivolous or abusive filings could result in sanctions. Id. In Clark v. JPMorgan Chase Bank, N.A., No. 25-cv-11195, 2025 WL 2408194, at *1 (E.D. Mich. Aug. 19, 2025), the pro se plaintiff initiated a consumer credit lawsuit concerning the purchase of a vehicle from one defendant (the auto dealer) with financing by another defendant and the subsequent repossession of the vehicle by yet another defendant. The issue before the court was the plaintiff's motion to strike the auto dealer's amended affirmative defenses. Id. The court denied the plaintiff's motion, deeming it frivolous, and highlighted several deficiencies in the plaintiff's submissions, including noncompliance with local rules, improper signatures, and erroneous case citations. Id. at *2-3. The court ordered the plaintiff to show cause for not appearing at a hearing and for not seeking concurrence with defense counsel before filing the motion. Id. at *3. The court suspected that the plaintiff used AI in his research. Id. at *3 n.4. The court acknowledged "a rash of cases" involving counsel and pro se litigants, citing "fake, hallucinated cases." Id. The court noted further that AI chatbots generate accurate responses by mimicking word patterns from their training data, rather than independently verifying facts like humans do. Id. Subsequently, the court found excusable neglect for the plaintiff's non-appearance, discharged that portion of the show cause order, and permitted the case to move forward without imposing sanctions. Clark, No. 25-cv-11195, slip op. at 1 (E.D. Mich. Sep. 2, 2025), Dkt. No. 52. The court admonished the plaintiff for missing deadlines and hearings, making unauthorized filings, and disregarding court rules; however, the court did not reference AI misuse. Id. at 1-3. The pro se plaintiff appealed the dismissal of his civil rights lawsuit against the defendant. Chambers v. Village of Oak Park, No. 25-1104, 2025 WL 1898369, at *1 (7th Cir. July 9, 2025). On appeal, the court found that the defendant's actions were rationally based, and the plaintiff's claim did not meet the necessary criteria. Id. The court affirmed the dismissal. Id. at *1-2. In so ruling, the court noted that the defendant moved for sanctions, asserting that the appeal was frivolous. Id. at *2. The defendant cited portions of the plaintiff's filings that included misquoted cases, misrepresented facts, or holdings, and appeared to cite non-existent cases. Id. Acknowledging the difficulty of litigating cases pro se, the court ordered the plaintiff to show cause as to why monetary sanctions or a filing restriction should not be imposed. Id. Ultimately, the court warned the plaintiff that future frivolous filings (including fictitious authority) may result in sanctions, including fines and a filing bar. Chambers, No. 25-1104, slip op. at 2 (7th Cir. Aug. 19, 2025), Dkt. No. 34. In a bankruptcy case, the court addressed whether the debtor’s actions constituted an abuse of the bankruptcy process. In re DeRosa-Grund, No. 25-bk-80235, 2025 WL 2395095, at *1 (Bankr. S.D. Tex. Aug. 18, 2025). In reviewing the case, the court found that the debtor repeatedly made arguments based on non-existent caselaw, non-existent cases, and by misquoting cases. Id. at *5. The court brought these troubling occurrences to the Debtor early in the case, but she nevertheless persisted in the practice. Id. In dismissing the case, the court concluded that the debtor violated Bankruptcy Rule 9011(b) in numerous ways. Id. The court decided to "include certain protective measures in its dismissal in order to ensure that these abuses do not occur in the future, especially given the pattern and practice by the Debtor of misquoting and making up cases." Id. Notably, the court dismissed the "case with prejudice to its refiling for one year after entry of the order." Id. In Clonan v. Centrastate Healthcare Sys., No. 24-cv-11399, 2025 WL 2374514, at *1, *3 (D.N.J. Aug. 15, 2025), the pro se plaintiff alleged federal and state claims against 34 defendants for a six-day involuntary medical commitment in March 2023. In the instant proceeding, the court addressed motions to dismiss by some of the defendants. Id. at *4. Of the plaintiff's eleven claims, the court dismissed seven with prejudice and dismissed four without prejudice for lack of subject matter jurisdiction. Id. at *15. In reviewing the case's procedural history, the court noted that the plaintiff filed a sur-reply without the court's permission. Id. at *3. The plaintiff filed the sur-reply to respond to the defendants' claims that the plaintiff's opposition briefs contained fabricated case citations. Id. at *3 n.7. In the sur-reply, the plaintiff acknowledged that he used legal research and drafting tools that may have had AI features. Id. The court admonished the plaintiff to use caution while citing cases and to ensure the case law's validity. Id. In a bankruptcy case, the plaintiffs filed an adversary complaint seeking to have certain debts declared non-dischargeable; the defendant debtor moved to dismiss. In re Nasser, No. 25-bk-44069, 2025 WL 2382055, at *1 (Bankr. E.D. Mich. Aug. 15, 2025). The court granted the defendant's motion in part, but denied it with respect to the plaintiff's fraud allegation. Id. at *9. In reaching a decision, the court noted that the plaintiffs filed a notice of errata to correct certain errors in the response. Id. at *2 n.3. The court opined that these errors raise questions about the veracity of the response. Id. The court pondered "how such errors could be made," and expressed concern that the plaintiffs used GAI to assist in drafting the response. Id. The court "discourage[d] such a practice for reasons that should now be well known by all attorneys [but] will not take any action at this time other than to warn counsel that future errors of this nature will not be tolerated." Id. In Monster Energy v. Owoc, No. 24-cv-60357, slip op. at 1 (S.D. Fla. Aug. 14, 2025), Dkt. No. 54, the court addressed the submission of incorrect legal citations in the pro se defendant's motion, which were suspected to be fake citations generated by AI. The defendant admitted that the citations were generated by AI and explained his financial hardship and reliance on free resources for legal research. Id. The court noted that the defendant’s use of AI led to the submission of fake legal citations, which violated Rule 11. Id. at 2. As a result, the court imposed sanctions, including requiring the defendant to complete community service and to certify the accuracy of legal citations in future filings if AI is used. Id. at 3. In Chapman v. Horace Mann Prop. & Cas. Ins. Co., No. 24-cv-10546, 2025 WL 3724904, at *1 (C.D. Cal. Aug. 14, 2025), the court addressed whether to grant the pro se plaintiff's motion to amend the complaint and whether the plaintiff's repeated use of fabricated case citations warranted sanctions. The court denied the motion to amend, citing the plaintiff's failure to demonstrate good cause for the amendment and the undue delay in seeking it. Id. at *5-6. The court also noted the plaintiff's repeated use of hallucinated case citations and issued a final warning before imposing sanctions for any further misconduct. Id. at *1-3. The court identified at least 22 instances where the plaintiff used fabricated case citations. Id. at *2. The court highlighted the harms of submitting fake opinions, including wasted time and resources, potential harm to the reputation of the legal profession, and the promotion of cynicism about the judicial system. Id. The court expressed displeasure with the plaintiff's "failure to take any sincere accountability for his repeated misrepresentations." Id. While the court found the plaintiff's conduct to be more egregious than other similar cases involving pro se litigants, the court extended "one final warning before the imposition of sanctions, which may include terminating sanctions." Id. at 3 (emphasis in original). In Nora v. M & A Transport, Inc., No. 25-cv-1015, 2025 WL 2337132, at *1 (E.D. La. Aug. 13, 2025), the court ordered the plaintiff's counsel to show cause for potential sanctions due to her failure to comply with Rule 11. In the plaintiff's motion to transfer venue, the defendants identified suspicious citations. Id. In a subsequent filing, counsel admitted to the inaccuracies in the cited authorities, noting that the verification was mistakenly conducted using Westlaw Precision, an AI-assisted research tool, instead of Westlaw’s standalone legal database. Id. Counsel further explained that she now understood Westlaw Precision used AI-assisted research, which can generate fictitious legal authority if not independently verified. Id. The court ordered counsel to produce the AI-assisted research history; however, counsel was unable to do so because her research history did not include the inaccurate citations at issue. Id. at *2. At a subsequent in camera review, counsel testified that "she was unable to provide the Court with this research history because the lawyer who produced the AI-generated citations is currently suspended from the practice of law in Louisiana." Id. In this case, there was uncertainty about whether Westlaw produced the fabricated citations. At a subsequent hearing, the ruling provided:
Id. The court ultimately determined that counsel violated Rule 11 for failing to verify that several of the legal contentions in the motion to transfer were warranted by existing law. Id. at *3. The court also took issue with counsel's misrepresentations regarding the origin of the AI-generated cases. Id. The court sanctioned counsel in the amount of $1,000, ordered her to attend one hour of continuing legal education on the topic of GAI, and referred counsel to the district court's disciplinary committee. Id. In Chavez-DeRemer v. NAB, LLC, No. 21-cv-984, 2025 WL 2308676, at *1 (D. Nev. Aug. 11, 2025), the plaintiff prevailed in a Fair Labor Standards Act action against pro se defendants. Two of the defendants moved to stay execution of that judgment, asserting financial hardship. Id. The court denied the motion and warned the parties that using GAI tools may result in sanctions. Id. at *2-3. The court observed that the plaintiff pointed to at least one case cited in a defendant's brief that did not exist. Id. at *3. The court noted that "[i]ncidents of fake authority cited in briefs have skyrocketed in recent months, and the culprit is usually the use of generative AI software like ChatGPT to conduct legal research and write briefs." Id. The court warned that parties are required to ensure that the authorities they cite are accurate and genuine, as reliance on inaccurate or fake authorities in legal briefs will result in consequences, including sanctions. Id. In United States v. Stephens, No. 23-cv-80043, 2025 WL 2840746, at *1 (S.D. Fla. Aug. 7, 2025), the pro se defendant moved for equitable relief to return 50 percent of the net sale proceeds from a property, which was sold to satisfy a criminal restitution judgment lien against him. The defendant utilized AI tools in his legal research and drafting, which resulted in the inclusion of non-existent case citations in his filings. Id. at *3. The court confirmed that the cited cases did not exist and noted the evolving challenge of AI in the legal profession, emphasizing the need for verification of AI-generated content. Id. As a result, the court imposed sanctions on the defendant, requiring him to apologize to opposing counsel, pay reasonable attorney fees, and disclose any future use of AI tools in his filings. Id. at *4-5. In a subsequent order closing the case and ordering the defendant to pay the U.S. Attorney's Office $532.39 in attorney fees as a sanction for AI misuse. Stephens, No. 23-cv-80043, slip op at 2 (S.D. Fla. Oct. 30, 2025). On August 7, 2025, the appellate court held that the trial court’s fitness and best-interest determinations were not against the manifest weight of the evidence. In re S.M., 2025 IL App (4th) 250277-U, ¶ 1. During the review of this appeal, the appellate court found that the respondent’s counsel referenced two non-existent cases in the appellant’s brief, as well as two valid cases that do not support the legal propositions for which they were cited. Id. ¶ 29. Counsel filed a response to a subsequent show cause order, but the appellate court found his responses to be "disingenuous and misleading." Id. ¶¶ 30-31. The appellate court highlighted that the four problematic citations were the only case citations included in the appellant’s brief. Id. The appellate court found that counsel "violated Rule 375 by willfully citing multiple cases that do not exist or do not stand for the propositions of law for which they were cited." Id. ¶ 32. The appellate court imposed monetary sanctions in the amount of $1,000 and referred the matter to the disciplinary commission. Id. ¶ 34. In Hall v. The Academy Charter Sch., No. 24-cv-8630, 2025 WL 2256653, at *1 (E.D.N.Y. Aug. 7, 2025), the plaintiff filed a lawsuit against the defendant, alleging discrimination based on sexual orientation and a hostile work environment. AI slop seeped into the proceedings when the plaintiff's attorney submitted a brief containing AI-generated fictitious legal citations. Id. Like others before, the court noted that there was nothing inherently wrong with using AI in legal practice, but attorneys must be aware of its limitations and ensure the accuracy of citations and legal arguments. Id. at *4. The court decided not to impose monetary sanctions on the attorney, considering the personal circumstances affecting her performance and the lack of bad faith in the submission of the AI-generated citations. Id. at *6. On August 4, 2025, the appellate court dismissed the appeals, concluding it lacked jurisdiction and the respondent did not pursue challenges to the other orders from which he appealed. In re A.S., 2025 IL App (4th) 250298-U, ¶ 1. In reaching a conclusion, the appellate court discovered that the respondent's appellate counsel cited one case that did not exist and seven cases that existed but did not stand for the propositions of law for which they were cited. Id. ¶ 14. In a response to the appellate court's show cause order, counsel claimed that the errors resulted from typos or were inadvertent. Id. ¶ 15. The appellate court opined: "Even accepting [counsel's] questionable claim he simply miscited a case rather than cited a case that did not exist, our review makes clear he has violated Rule 375 by willfully citing multiple cases that do not stand for the propositions of law for which they are cited." Id. ¶ 18. Additionally, the appellate court found "it particularly concerning this conduct occurred, at least as it relates to the reply brief, after he personally appeared before this court for similar conduct.” Id. While counsel did not admit to using AI to prepare the briefing, the appellate court reasonably deduced as much based upon the review of the briefing, the response to the rule to show cause, and counsel's past conduct. Id. at ¶ 19. Accordingly, the appellate court dismissed the appeals and ordered counsel to pay $1,000 as monetary sanctions; the clerk was ordered to send a copy of this decision to the disciplinary commission. Id. ¶ 22. In Tellez v. Proietti, No. 24-cv-408, 2025 WL 2208429, at *1 (E.D. Cal. Aug. 4, 2025), the court addressed whether the pro se plaintiff's complaint stated a cognizable claim. The magistrate judge recommended dismissing the case without leave to amend, citing the Rooker-Feldman doctrine. Id. The plaintiff objected, citing three cases (including one fictitious case) to support her argument that the court had jurisdiction to review constitutional questions regarding a state court's actions. Id. However, the court rejected the plaintiff's objections as unpersuasive and adopted the magistrate judge's findings and recommendations, dismissing the case without leave to amend. Id. at *1-2. While the court did not expressly find that the fictitious case was generated by AI, it can be inferred as the cited case "does not appear to be a real case by a search of its name or citation." Id. at *1 n.1. In the instant action, the pro se plaintiff asserted that the defendants violated her rights in a state court eviction case. Advani v. App. Term, 2d Jud. Dep't, No. 25-cv-1627, 2025 WL 2201065, at *1 (S.D.N.Y. Aug. 1, 2025). Two of the defendants moved to dismiss the action based on the Rooker-Feldman doctrine. Id. In reviewing the matter, the court concluded that all four Rooker-Feldman requirements were satisfied; thus, the court lacked subject-matter jurisdiction over the plaintiff's claims against all of the defendants. Id. at *3. The court accordingly entered judgment in favor of the defendants. Id. at *4. In reaching its decision, the court found "several troubling features" in the plaintiff's filings, including citations to non-existent cases, quotations that do not appear in cited cases, and citations to cases that do not support propositions for which they are cited. Id. The court surmised that these problems arose from the plaintiff's use of GAI tools. Id. In lieu of the case's dismissal and the plaintiff's pro se status, the court declined to pursue the matter and warned the plaintiff "that presentation of false citations, quotations, and holdings in the future may indeed result in the imposition of sanctions." Id. In pro se actions, the plaintiff filed three lawsuits against the defendant, alleging various claims related to his activities as a third-party seller on the defendant's platform. Ligeri v. Amazon.com Servs. LLC, No. 25-cv-764, 2025 WL 2161497, at *1 (W.D. Wash. July 30, 2025). The issues before the court included motions to vacate judicial reassignment, consolidate the cases, compel arbitration, and dismiss certain claims. Id. The court denied the plaintiff's motion to vacate judicial reassignment, granted the defendant's motion to consolidate the cases, and compelled arbitration based on a previous court ruling. Id. at *3-4, *6. The court also dismissed the plaintiff's intellectual property claims without prejudice. Id. at *10. In ruling, the court noted that the plaintiff's filings included citations to non-existent judicial opinions and fake quotes, suggesting that the plaintiff used AI to draft his documents. Id. at *2. The court warned the plaintiff that future filings containing such citations might result in sanctions. In Rollins v. Premier Motorcar Gallery Inc., No. 24-cv-413, 2025 WL 2161428, at *1 (S.D. Fla. July 30, 2025), the pro se plaintiff filed a complaint that included federal claims under the Truth in Lending Act (TILA), other federal statutes, and state law claims. The court agreed with the magistrate judge's report and recommendation, which suggested dismissing the federal claims and declining to exercise supplemental jurisdiction over the state law claims. Id. The court noted that the Eleventh Circuit encourages dismissal of state-law claims when all federal claims are dismissed before trial. Id. In this case, the plaintiff's proposed second amended complaint included a citation to a non-existent case, which she attributed to reliance on AI for legal research. Id. The court cautioned the plaintiff about the risks of relying on AI without independent verification and warned that continued citation to non-existent law could result in dismissal of future cases. Id. In Coronavirus Reporter Corp. v. Apple Inc., No. 24-cv-8660, 2025 WL 2162947 (N.D. Cal. July 30, 2025), the plaintiffs alleged the defendant monopolized the app distribution market on its devices by controlling the curation and approval process for its App Store, thereby suppressing or excluding competing apps. The court dismissed the plaintiffs' claims, citing that they were barred by res judicata. Id. at *2. The plaintiffs filed a number of post-trial motions, followed by a motion for sanctions filed by the defendants. Id. at *2-3. The court found that sanctions were warranted because the plaintiffs' complaint and ensuing motions were frivolous and lacked support. Id. at *3. Additionally, the court noted that the plaintiffs' counsel admitted to using ChatGPT to generate a document submitted to the court, which included hallucinated citations. Id. at *4. The court determined that the defendant was entitled to the fees and costs reasonably incurred in connection with the litigation, and that the defendant shall submit declarations from its attorneys detailing the fee request. Id. at *6-7. In a Chapter 7 bankruptcy, the court addressed the debtor's failure to comply with court orders. In re Ford, No. 24-bk-31129, at *5 (Bankr. W.D.N.C. July 29, 2025). The court expressed concern with the debtor's unauthorized practice of law by representing a company that she solely owned in the bankruptcy proceedings. Id. at *2. Additionally, the debtor was accused of transferring properties to the company in a potentially fraudulent manner, which the Chapter 7 Trustee contested. Id. The court also noted the debtor's failure to disclose certain financial accounts and transactions (potentially constituting perjury). Id. at *6. While the court expressed "concerns with the Debtor citing non-existent legal authorities and perhaps receiving misleading legal advice from the jurisprudence course that the Debtor recently took," there was no specific reference to AI-generated fabrications. Id. at *4. Ultimately, the court held the debtor in contempt (on grounds other than AI misuse). Id. at *7. In Robbins v. Martin Law Firm, P.L., No. 25-cv-409, slip op. at 1 (M.D. Fla. July 28, 2025), Dkt. No. 32, the plaintiff filed a complaint in state court against the defendants for legal malpractice, misrepresentation, and breach of fiduciary duty. The plaintiff alleged that the defendants converted her bankruptcy case from Chapter 13 to Chapter 7 without notice or consent, exposing her to asset liquidation. Id. at 2. The defendants removed the case to federal court, citing federal jurisdiction due to the bankruptcy context. Id. While the plaintiff initially sought remand, her motion to remand was withdrawn. Id. The defendants requested an award of reasonable attorney fees and expenses, as well as an order requiring an explanation concerning the misrepresentations about cases and citation to non-existent case law. Id. The defendants contended that certain aspects of the plaintiff’s support were unusual, arguing that sanctions were justified when direct quotations were fabricated to create support that did not exist. Id. at 7. The court did not expressly reference AI-generated content, but the defendants' allegations suggest the plaintiff's attorney used AI to draft the motion to remand. The court found that the plaintiff's attorney failed to make a reasonable inquiry regarding the validity of the citations before filing the motion; however, the defendants did not comply with the safe harbor provision of Rule 11 to permit opposing counsel to address the issue before seeking sanctions. Id. at 10. The court denied the defendants' motion, observing that the attorney’s citations were misleading, incorrect, and contained blatantly misquoted material; however, the plaintiff's motion to remand was immediately withdrawn. Id. at 11. Further, the court found that counsel did not act knowingly or recklessly, and the defendants failed to show objectively that the misconduct was in bad faith. Id. In a case involving two related lawsuits, the court addressed the use of AI in legal research, specifically concerning false citations in the plaintiffs' summary judgment response briefings. Seither & Cherry Quad Cities v. Oakland Automation, No. 23-cv-11310, 2025 WL 2105286, at *1 (E.D. Mich. July 28, 2025). The issue for the court was whether the plaintiffs' attorneys should be sanctioned for using AI-generated content that included fictitious quotations and misrepresented case holdings. Id. While the court found that the citations were not submitted in bad faith, sanctions could still be imposed regardless of good or bad faith. Id. Importantly, the court highlighted the risks associated with using AI tools, notably the problem with hallucinations and the necessity for attorneys to independently verify AI-generated citations. Id. at *1. The court imposed monetary sanctions on the plaintiffs' attorneys, requiring them to pay $1,485 to defense counsel to cover costs incurred due to the false citations. Id. at *2. Additionally, the court encouraged the attorneys to complete a continuing legal education course on the use of LLMs in legal research and legal ethics. Id. In Kessler v. City of Atwater, 25-cv-288, 2025 WL 1918003, at *1 (E.D. Cal. July 11,
2025), the plaintiff's attorney allegedly violated Rule 11 by citing
non-existent cases, misquoting cases, and citing cases for propositions not
supported by the case law. The court ordered the attorney to show cause why
sanctions should not be imposed for these violations. Id. In the show
cause order, the court painstakingly reviewed the specific AI-induced errors. Id.
at *1-3. The court opined that the attorney violated the most basic duty of
candor before the court. Id. at *1. The court explained that several hours were spent checking the case citations proffered by the plaintiff's attorney, which created a delay for the court to address the merits of the motions. Id. The court issued a stern admonishment: "This
Court—being one of the busiest in the Country and with higher caseloads per
judge than nearly every other district court—can sorely afford to waste its
resources in this manner." Id. The court ordered the attorney to
conduct a thorough review of the legal citations in his court filings and
verify their accuracy. Id. at *4. He must submit correct copies of the
cases, highlight the pertinent text or legal reasoning, and provide precise
citations. Id. If the attorney cannot find a cited case or quotation, he
must explain why in a sworn declaration. Id. In a subsequent minute
order, the court found that the attorney admitted full responsibility for the
failures at issue. Kessler, 25-cv-288 (E.D. Cal. July 25, 2025), Dkt. No.
42. The court struck the portions of the briefs that rely on the cases cited in
order to show cause. Id. In Pop Top Corp. v. Rakuten Kobo Inc., No. 20-cv-4482, 2025 WL 2098597, at *1 (N.D. Cal. July 25, 2025), the court addressed a matter brought by a pro se interested party (a judgment debtor). The judgment debtor sought to vacate a previous court order denying his motion to quash post-judgment discovery and also sought admonishment against the defendant's counsel for alleged litigation and procedural abuse. Id. The court denied the motions, denying the motion to vacate because the judgment debtor failed to provide evidence supporting his claims of false representations by the defendant's counsel or procedural unfairness, and denying the motion for admonishment as the court found no basis for such action against the defendant's counsel. Id. at *1, *3-6. In deciding the matter, the court noted that the judgment debtor used an AI tool, which led to the citation of nonexistent cases in his filings. Id. at *1. The court acknowledged the increasing reliance on AI in legal proceedings and the associated risks of citing imaginary cases, emphasizing the responsibility of parties, including self-represented ones, to verify the accuracy of AI-generated information. Id. at *1, *3. The court warned the judgment debtor that future citations to non-existent cases could result in sanctions. Id. at *3. In a business dispute, the court addressed the defendant's motion to compel arbitration and the pro se plaintiff's motion for a TRO and for a preliminary injunction. Deleman v. HighLevel Inc., No. 25-cv-1284, 2025 WL 2101965, at *1 (M.D. Pa. July 25, 2025). The court granted the motion to compel arbitration, finding that the plaintiff agreed (via a click-through check box). Id. at *5-6. The court denied the plaintiff's motion for injunctive relief, as he failed to demonstrate irreparable harm that would render the arbitration proceeding meaningless. Id. at *7-8. With regards to AI implications, the plaintiff admitted to using GAI tools while drafting his court filings and provided certificates of use to the court. Id. at *5 n.4. The court expressed skepticism about Deleman's understanding of legal concepts, such as "consideration," and reminded him that false representations to the court could warrant sanctions. Id. At a hearing, the court observed that the plaintiff "appeared to be relying entirely on AI generated arguments and citations." Id. When the court asked the plaintiff if "he read the cases he cited," the plaintiff claimed that he did. Id. The court was skeptical of the plaintiff's claim and reminded him that false representations to the court may warrant sanctions. Id. In O'Neill v. Whitehouse Indep. Sch. Dist., No. 24-cv-395, 2025 WL 2947020, at *1 (E.D. Tex. July 25, 2025), the pro se plaintiff alleged that her child experienced verbal sexual harassment and sexual assault by other students. The plaintiff claimed that the defendant school failed to take appropriate action, leading to further harassment and the child's withdrawal from the school. Id. In reviewing the defendant's motion to dismiss, the court dismissed most of the claims (without prejudice) and denied the motion with respect to the plaintiff's ADA claim. Id. at *7. In ruling, the court observed that several case citations in the plaintiff's response appeared to be fabricated, warned the plaintiff that further citation to non-existent cases could result in sanctions. Id. In Malone-Bey v. Lauderdale Cnty. Sch. Bd., No. 25-cv-380, 2025 WL 2098352, at *1 (N.D. Miss. July 25, 2025), the pro se plaintiff sued the defendants for alleged violations of federal and state law, as well as multiple state torts. The issue before the court was the plaintiff's motion to disqualify some of the defendants' law firm for an alleged conflict of interest. Id. at *2-3. The court denied the motion, finding no reasonable basis to conclude that the representation by the law firm may be materially limited. Id. at *3. The court opined that "the mere assertion that potential conflicts may arise is not enough to warrant disqualification." Id. In reaching a conclusion, the court addressed the plaintiff's use of fictitious legal opinions in his filings, which may have been generated by AI. Id. at *3. The court warned the plaintiff that future filings with fictitious citations could result in sanctions. Id. at *5. In a pro se case, the plaintiff alleged that he was denied access to a lavatory due to his non-revenue passenger status, publicly embarrassed by flight attendants, and subsequently removed from the flight. Nunez v. Am. Airlines, Inc., No. 25-cv-21630, slip op. at 2 (S.D. Fla. July 24, 2025), Dkt. No. 50. The defendant's motion to dismiss was referred to the magistrate judge. Id. at 1. The primary issue was to determine whether the plaintiff's claims were preempted by the Montreal Convention, governing international air travel claims. Id. at 5. The magistrate concluded that all of the plaintiff's claims were preempted by the Convention, as they arose from the international flight incident. Id. at 7. Additionally, the magistrate observed that the plaintiff's response brief contained phony caselaw. Id. at 15-16. Ultimately, the magistrate considered the statute of limitations under the Convention and the plaintiff's repeated violations of local rules and submission of fake caselaw, recommending dismissal with prejudice as a sanction. Id. at 14-15, 18. The district judge has not yet ruled on the magistrate's report and recommendation. In Everett J. Prescott, Inc. v. Beall, No. 25-cv-71, 2025 WL 2085275, at *1 (D. Me. July 24, 2025), the plaintiff filed a complaint against the pro se defendant (a former employee), alleging harassment through threatening messages and defamatory statements on social media. The court initially granted a TRO for public defamatory statements but dismissed claims related to private messages and intentional infliction of emotional distress, as a corporation cannot suffer emotional distress under the law. Id. At issue before the court was the resolution of numerous motions filed by both parties, as well as addressing the procedural chaos caused by the excessive filings. Id. In clearing up some of the impediments to the case's progress, the court decided to set aside the entry of default against the defendant, hold in abeyance his motion for leave to file counterclaims, and dismiss without prejudice the plaintiffs' motion to dismiss counterclaims. Id. at *51. Among the other motions, the court addressed the plaintiffs' motion for sanctions on the ground that the defendant allegedly included fictitious case citations in his filings. Id. at *5. The defendant acknowledged the use of AI and promised to check his authorities more carefully in the future. Id. In the related show cause order, the court ordered that the defendant "must include a written representation that he has personally checked each legal citation and each citation is accurate and stands for its asserted proposition." Everett J. Prescott, No. 25-cv-71, slip op at 5 (D. Me. July 24, 2025), Dkt. No. 140. The court warned that "any miscitations or factitious quotations" would warrant "additional filing restrictions and more severe sanctions." Id. Additionally, the court dismissed the plaintiffs' motion for sanctions without prejudice. Id. In Cojom v. Roblen LLC, No. 23-cv-1669 (D. Conn. July 23, 2025), Dkt. No. 49, the court ordered the plaintiff's counsel to show cause why he should not be sanctioned for citing to non-existent cases in the plaintiff's opposition filings to the defendant's motion to vacate and explain whether the non-existent citations resulted from the use of AI or some other failure of diligence or candor. Specifically, the court could not locate three cases from the District of Connecticut contained in the plaintiff's filings. Id. Subsequently, the court evaluated the defendant's motion based on whether the default was willful, whether vacating it would prejudice the plaintiff, and whether Berisha had a meritorious defense. Cojom, No. 23-cv-1669, slip op. at 2-3 (D. Conn. July 28, 2025), Dkt. No. 51. The court found that the defendant's "total silence juxtaposed with his awareness that there was an active suit against him is the sort of willfulness that makes vacatur inappropriate." Id. at 5-6. Next, the court found that vacatur was clearly prejudicial based on the plaintiff's testimony, particularly in light of the defendant’s knowledge of this action against him and his knowledge and experience in a similar litigation. Id. at 7. Finally, the court found that the defendant did not establish a sufficient showing of a meritorious defense. Id. The court denied the defendant's motion to vacate. Id. at 8. A recent article indicated the court was inclined to issue "a big sanction . . . to send a clear message about AI's pitfalls to [the plaintiff's counsel] and other lawyers," but the court reflected that it "would likely struggle to ascertain what the appropriate punishment might be." Aaron Keller, Judge Warns Fake AI Cites May Need 'Eye-Catching Sanction', Law360 (Sep. 9, 2025). However, there was no eye-catching sanction (or even a slap on the wrist). In determining an appropriate sanction, the court considered counsel's acknowledgment of the error, his commitment to cease using AI in his legal practice, and the steps he took to prevent future occurrences, such as canceling his AI tool license and completing CLE coursework on AI technology. Cojom, No. 23-cv-1669, 2025 WL 3205930, at *4 (D. Conn. Nov. 17, 2025). The court concluded that the most appropriate sanction amounted to $500. Id. In reaching a conclusion, the court noted that counsel was subject to another show cause hearing for AI misuse. Id. at *1 n.1. In a ten-count complaint, an incarcerated plaintiff alleged Eighth Amendment deprivations and negligence against the defendants (prison officials and officers with the Alabama Department of Corrections). Complaint at 1-2, 34, 45, 49, 51, 55, 58, 60, 63, 64, 77, Johnson v. Dunn, No. 21-cv-1701 (N.D. Ala. Dec. 27, 2021), Dkt. No. 1. During discovery, the defendant moved to depose the plaintiff; the plaintiff opposed the motion on the basis that counsel could not adequately prepare to present the plaintiff in the specified time frame and that the defendant cited "no legitimate authority" to support the proposition that such a deposition was appropriate. Plaintiff's Response to Defendant's Motion for Leave to Depose Incarcerated Persons, at 1, Johnson, No. 21-cv-1701 (N.D. Ala. May 15, 2025), Dkt. No. 186 (emphasis in original). The plaintiff claimed that the defendant's argument supporting the appropriateness of such a deposition was fabricated: the defendant's legal authority "appear[ed] to have been made up out of whole cloth." Id. at 2 (emphasis in original). The plaintiff accused the defendant of fabricating case law and argued that the defendant's motion should be denied for failing to cite any legitimate case law to support their position. Id. at 5 (emphasis in original). The court conducted an independent investigation of the case citations in the defendant's motion and could not locate the cases. Johnson, No. 21-cv-1701, 2025 WL 1465778, at *1 (N.D. Ala. May 16, 2025), Dkt. No. 187. The court issued a show cause order as to why sanctions should not be imposed "for making false statements of fact or law." In issuing the order, the court noted that four attorneys signed the defendant's motion. Id. Following a subsequent show cause hearing, the court ordered initial briefing to be completed by June 2, 2025. Johnson, No. 21-cv-1701 (N.D. Ala. May 21, 2025), Dkt. No. 199. In determining an appropriate sanction, the court noted that this case "demand[ed] substantially greater accountability than the reprimands and modest fines that have become common as courts confront this form of AI misuse." Johnson, No. 21-cv-1701, slip op. at 1 (N.D. Ala. July 23, 2025), Dkt. No. 204. The court underscored the urgency to impose greater accountability by declaring: [T]ime is telling us – quickly and loudly – that those sanctions are insufficient deterrents. In principle, they do not account for the danger that fake citations pose for the fair administration of justice and the integrity of the judicial system. And in any event, they have little effect when the lawyer’s client (here, an Alabama government agency) learns of the attorney’s misconduct and continues to retain him. Id. at 2. The court publicly reprimanded the three attorneys for making false statements. It ordered the publication of the reprimand, disqualified the attorneys from any further involvement in this case, and referred the matter to the state bar and other relevant licensing authorities. Id. Additionally, the court directed the clerk to submit this order for publication in the Federal Supplement. Id. at 50. Docket. See also Ralph Artigliere & William Hamilton, Reasonable or Overreach? Rethinking Sanctions for AI Hallucinations in Legal Filings, JDSupra (Aug. 18, 2025). In Elizondo vs. City of Laredo, No. 25-cv-50, 2025 WL 2071072, at *1 (S.D. Tex. July 23, 2025), the court addressed whether sanctions should be imposed on the plaintiff's counsel for submitting a response to the defendant's motion to dismiss that contained multiple fictitious or materially inaccurate case citations. The court found that counsel violated Rule 11 by submitting a filing with fabricated citations and misstatements of law that were not properly reviewed for accuracy. Id. Notably, the court identified that the inaccuracies in the case citations were likely due to the use of GAI by counsel's law clerk, which was not adequately verified for accuracy. Id. Counsel acknowledged his failure to verify the accuracy of the citations and took responsibility for the errors. Id. He also implemented new internal policies prohibiting the use of generative AI tools in drafting legal filings and requiring heightened citation review. Id. The court emphasized that attorneys were responsible for the contents of their filings under Rule 11, regardless of whether GAI was used in drafting any portion of the filing. Id. at *2. The court's local rules do not prohibit the use of GAI but require that any filing prepared with its assistance be thoroughly reviewed for factual and legal accuracy prior to submission. Id. In crafting a sanction, the court opined: "Given that the Laredo Division is one of the busiest court dockets in the nation, there are scant resources to spare ferreting out erroneous AI citations in the first place, let alone surveying the burgeoning caselaw on this subject." Id. at *3. The court imposed a monetary penalty in the amount of $2,500, required counsel to complete continuing legal education in ethics or legal technology, and mandated that he serve a copy of the order on the plaintiff. Id. In Vita Law Offices v. Lockridge Grindal Nauen P.L.L.P., No. 25-cv-23576 (S.D. Fla. July 1, 2025), Dkt. No. 23, the plaintiff's brief appeared to contain multiple fabricated quotes. The court located at least two instances in the brief. Id. The court ordered the plaintiff to show cause "why sanctions should not issue for its submission of a brief with false or misleading case citations." Id. The court instructed the plaintiff to identify any other instances of inaccurate quotations found in the briefs submitted in this case. Id. The response from the plaintiff's attorney identified all of the instances of inaccurate quotations in the previously filed brief. Vita Law Offices, No. 25-cv-23576 (S.D. Fla. July 16, 2025), Dkt. No. 27. The court ordered the attorney to submit a supplemental response, where the attorney was permitted to make "[a] more candid admission of error" and "include a suggestion of an appropriate sanction that takes into account the time the Court has expended in reviewing for inaccuracies not only the original briefs, but also the Response to Order to Show Cause." Id. The court cautioned that sanctions would be considered. Id. ultimately, the court decided to conclude the matter upon the attorney's completion of four CLE courses focusing on topics such as the use of AI in legal practice, legal ethics, and federal practice (or a combination thereof). Vita Law Offices, No. 25-cv-23576 (S.D. Fla. July 23, 2025), Dkt. No. 30. The court also directed the attorney to submit documentation to the court detailing the course titles, the course providers, the completion dates, and a brief summary of each course. Id. The pro se plaintiff filed a lawsuit against the defendant, alleging breach of contract and other claims. Sumpter v. Navy Fed. Credit Union, No. 25-cv-347, 2025 WL 2557204, at *1 (N.D. Ga. July 21, 2025). The issue before the court was the plaintiff's renewed motion for a temporary restraining order to prevent the foreclosure of his residence. Id. The court determined that the plaintiff failed to demonstrate a substantial likelihood of success. Id. at *2. AI leaked into the case as the plaintiff's motion included fabricated legal citations. Id. at *3. The defendant identified the fabrications as a hallmark of GAI. Id. The court noted the importance of double-checking facts and citations, especially when utilizing AI, and warned the plaintiff about the potential for sanctions if fictitious citations are submitted in the future. Id. On July 21, 2025, in an appeal of the trial court's order terminating parental rights, the appellate court affirmed the ruling. In re Boy, 2025 IL App (4th) 241427, ¶ 1. Additionally, the appellate court ordered the respondent's counsel to show cause why he should not be sanctioned for citing eight non-existent cases in the briefs he filed for the respondent. Id. ¶ 2. The appellate court found that counsel violated Illinois Supreme Court Rule 375 and ordered counsel to disgorge the payment of $6,925.62 that he received for his work on this appeal and to pay $1,000 as monetary sanctions. Id. The appellate court also directed the clerk to send a copy of this opinion to the disciplinary commission. Id. A pro se plaintiff filed a lawsuit against the defendants in state court, which was removed to federal court due to federal claims. Muhammad v. Gap Inc., No. 24-cv-3676, 2025 WL 1836657, at *1 (S.D. Ohio July 3, 2025). The court addressed the issue of whether the plaintiff's amended complaint sufficiently alleged claims against the defendants. Id. The court found that the complaint failed to plausibly allege claims against all defendants, leading to the dismissal of the amended complaint without prejudice. Id. Additionally, the court expressed concerns about the plaintiff's litigation tactics, including the filing of numerous motions and the use of apparently fabricated case citations. Id. The court found that the plaintiff cited non-existent cases and purported to reference quotes from the cases. Id. at *13. The court provided six illustrative instances as a basis for the court's concerns. Id. at *13-14. The court ordered the plaintiff to show cause in writing why sanctions should not be imposed. Id. at *14. Subsequently, the plaintiff filed a notice of appeal and moved for leave to appeal in forma pauperis, and also filed a response to the show cause order. Muhammad, No. 24-cv-3676 (S.D. Ohio July 10, 2025), Dkt. No. 119. The court observed that the latter filing did not include the information required in the court's show cause order. Id. While the court lacked jurisdiction over the merits of the case in light of the plaintiff's notice of appeal, the court retained jurisdiction to resolve collateral matters such as the imposition of sanctions. Id. at 2. The court ordered the plaintiff to bring specific materials (copies of pertinent cases to demonstrate that the cases existed) to a subsequent hearing. Id. at 2-4. The court also required the plaintiff to provide a complete written list of any AI tools, citation generators, or legal databases used in preparing his previous filings. Id. at 4. Next, the court denied the plaintiff's motion to continue the show cause hearing. Minute Entry, Muhammad, No. 24-cv-3676 (S.D. Ohio July 16, 2025). Later, the court stayed the proceedings (including the sanctions matter) in light of the plaintiff's notice of appeal until the Sixth Circuit resolved the notice of appeal. Notation Order, Muhammad, No. 24-cv-3676 (S.D. Ohio July 16, 2025). The court ordered that the plaintiff was prohibited from filing any further documents in the case. Id. The court noted that the plaintiff's failure to appear at the July 16, 2025, show cause hearing directly violated three court orders. Id. While the court held the issue of sanctions in abeyance, the court warned the plaintiff "that the potential sanctions in this case may include monetary sanctions, dismissal, revocation of his right to proceed pro se in this Court, and/or a vexatious litigator determination." Id. The court provided the following as a basis for the sanctions warning: the plaintiff's admission that he presented hallucinated cases before the court; his admission of continued use of ChatGPT to prepare filings; and his violation of three separate orders requiring him to appear in person at the show cause hearing. Id. The plaintiff's appeal was denied for lack of jurisdiction (none of the lower court's orders were final). Muhammad, No. 25-3496, 2025 WL 2823437, at *1 (6th Cir. Sep. 24, 2025). After the appeal, the court addressed the plaintiff's repeated failure to appear at scheduled hearings, despite multiple warnings that such absences could lead to sanctions, including dismissal of the case. Muhammad, No. 24-cv-3676, 2025 WL 3525908, at *1 (S.D. Ohio Dec. 9, 2025). The court noted the plaintiff's history of filing numerous frivolous motions, using AI-generated and hallucinated case citations, and failing to attend proceedings that he himself had requested. Id. at *2. Ultimately, the court dismissed the case with prejudice due to the plaintiff's "contumacious" conduct, which included willful disobedience and actions taken in bad faith, thereby prejudicing the defendants by delaying litigation and increasing their costs. Id. at *1-2. Additionally, the court ordered the plaintiff to compensate the defendants for attorney fees and costs incurred due to his non-appearances and designated him a vexatious litigant, imposing filing restrictions to prevent further abuse of the judicial process. Id. at *3-4. In the ruling, the court calculated various fees and costs associated with the plaintiff's failure to appear as scheduled. Id. at *4. In crafting a monetary sanction, the court imposed a deeply discounted penalty of $1,500 ($375 for each of the four defendants). Id. at *6. The court issued an amended opinion to correct an error, where the court intended to dismiss the action without prejudice, but subject to certain filing restrictions should the plaintiff seek to refile. Muhammad, No. 24-cv-3676, 2025 WL 3558475, at *1 n.* (S.D. Ohio Dec. 10, 2025) (emphasis added). In Crespo v. Tesla, Inc., No. 25-cv-80129, 2025 WL 1799411, at *1 (S.D. Fla. June 30, 2025), the pro se
plaintiff filed several discovery motions against the defendant. The defendant responded and filed a motion to strike the plaintiff's
replies due to the submission of fake case citations. Id. The court
found that the plaintiff cited non-existent cases and misrepresented quotes
from existing cases; the plaintiff admitted using AI for his filings and took
responsibility for the errors. Id. at *1-2. The court noted that the
plaintiff apologized to the court for wasting its time, but neglected to
apologize to defense counsel. Id. at *2. The court exercised its
inherent authority to sanction the misuse of AI when it affected the court's
docket, case disposition, and rulings. While considering the plaintiff's pro se
status, the court imposed sanctions requiring him to apologize in writing to
defense counsel and to pay the defendant's reasonable attorney fees incurred to
address the fabricated citations. Id. With respect to the fees, the court
ordered the parties to resolve and agree on the amount of reasonable attorney
fees with the expectation that "the amount of fees would not be
great." Id. at *4. Subsequently, the defendant sought attorney fees amounting to $1,096 for 5.2 hours billed for researching the fake citations, filing of a motion to strike, and responding to the plaintiff's motion to compel. Crespo, No. 25-cv-80129, 2025 WL 1921903, at *1 (S.D. Fla. July 11, 2025). The plaintiff claimed that the defendant failed to confer in good faith and asked the defendant to “waive the fee or charge a symbolic $1 as a gesture of goodwill.” Id. at *2. The court dismissed the plaintiff's one-dollar counteroffer as "a frivolous and bad faith attempt at conferral." Id. at *3. In reviewing the defendant's request, the court found that two hours billed for the same task and reduced the duplicative hourly charge. Id. at *4. Ultimately, the court reduced the billing time to 4.5 hours and awarded $921 in attorney fees. Id. In a breach of contract action, the court addressed the plaintiff's response to the defendant's motion to dismiss, which contained citations to non-existent cases. Jackson v. Auto-Owners Ins. Co., No. 24-cv-136, 2025 WL 1932274, at *1 (M.D. Ga. July 14, 2025). Following a show cause hearing, the court found that the plaintiff's attorney used AI to generate the response, but it was not intended to be filed as it contained these hallucinated citations. Id. at *2. The attorney acknowledged his responsibility for the error and explained that it was due to a staff member's incorrect filing. Id. In considering whether sanctions were warranted, the court first determined that the attorney had not acted in bad faith. Id. at *3. Nevertheless, the court opined that "[t]he failure of any attorney to thoroughly review documents prepared using AI is as unacceptable as failing to review documents prepared by a paralegal or legal assistant—which is in effect allowing an unlicensed individual to practice law using an attorney's name and signature." Id. at *4. Accordingly, the court ruled that sanctions were warranted pursuant to Rule 11. Id. The court imposed sanctions in the amount of $1,000 and ordered the attorney to attend an approved CLE course on AI. Id. at *5. The court also awarded the defendant all reasonable attorney fees for the time and expenses incurred in researching and replying to the plaintiff's response, as well as attending the show cause hearing. Id. Subsequently, the court entered the parties' agreed-upon amount of $6,462.40 for attorney fees and costs. Jackson, No. 24-cv-136, slip op. at 1 (M.D. Ga. July 30, 2025), Dkt. No. 26. The plaintiff was apprehended by immigration officials after crossing the Canadian border, and her attorney filed a petition for a writ of habeas corpus to prevent her deportation to India. Kaur v. Desso, No. 25-cv-00726, 2025 WL 1895859, at *1 (N.D.N.Y. July 9, 2025). The issue before the court was whether the plaintiff's attorney should be sanctioned for submitting a legal brief containing AI-generated, fabricated quotations from cited legal authorities. Id. For the court, there was no question that the attorney violated Rule 11 by failing to confirm the existence and validity of the legal authorities on which he relied. Id. at *3. In response, the attorney pointed to several factors to explain, but not justify, the decision to use AI without checking for accuracy. Id. The court found that the attorney's conduct was taken in subjective bad faith and was worthy of sua sponte sanctions, where the attorney "knowingly resorted to a faulty tool and failed to check its work." Id. The court imposed a $1,000 monetary sanction and ordered the attorney to complete a CLE course on the ethical use of AI in legal writing, underscoring the importance of caution and verification when incorporating AI tools into legal submissions. Id. In Ezzy Credit, LLC v. Prescription Technologies, Inc., No. 24-cv-2436, 2025 WL 3067426, at *1 (M.D. Fla. July 8, 2025), the plaintiffs filed a response to the defendants' motion to dismiss; the plaintiffs' response contained citations to six non-existent cases. The defendants moved to strike the response and sought sanctions, alleging that the plaintiffs deliberately relied on AI-generated citations without verifying their authenticity. Id. The court found that the plaintiff's attorney's submission of six fictitious cases was reckless and constituted frivolous conduct. Id. at *3. The court declined to strike the plaintiffs' response, as it would unfairly sanction the plaintiffs, who had no role in the drafting and filing of the response. Id. at *4. Rather, the court ordered the attorney to pay $3,000 to the defendants to compensate for the wasted resources caused by her submission. Id. The court opined:
Id. (quoting Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enters., LLC, No. 17-CV-81140, 2025 WL 1440351, at *7 (S.D. Fla. May 20, 2025)). Allegations of janky AI arose in a former Dominion Voting Systems executive's defamation case against MyPillow CEO Mike Lindell. See Thy Vo, Judge Orders MyPillow Attys To Explain AI Use, Fake Citations, Law360 (Apr. 23, 2025). With the trial approaching, the defendants’ brief in opposition to the plaintiff’s motion in limine roused suspicion when the court identified nearly 30 defective citations. Coomer v. Lindell, No. 22-cv-01129, slip op. at 3 (D. Colo. Apr. 23, 2025), Dkt. No. 309. The court noted several errors in the brief, including misquotations of cited cases and misrepresentations of legal principles related to those cases. Id. This included discussions of the legal principles not appearing in the decisions cited. Id. There were also inaccuracies concerning whether certain case law originated from a binding authority, such as the Tenth Circuit, and misattributions of case law to the District Court of Colorado. Id. Most notably, the court highlighted the "most egregious" error, which was the citation of cases that do not exist. Id. Even though the court presented the opportunity to explain how the brief was replete with such fundamental errors, the defendants' counsel declined to offer any explanation. Id. After much obfuscation, the court directly asked the defendants' counsel if the brief was a product of GAI; only then did counsel admit to the use of GAI. Id. at 4. The court ordered the defendants, the law firm representing the defendants, and the individual attorneys to show cause why sanctions should not be imposed and why the individual attorneys should not be referred for disciplinary proceedings. Id. at 5-6. Per the court's ruling, the defendants' counsel must show cause in writing by May 5, 2025. Id. at 6. Meanwhile, the defendants sought to delay a June defamation trial because of the pending sanctions determination for using phony case citations. Defendants' Motion to Amend/Correct/Modify Pretrial Order, Coomer, No. 22-cv-01129 (D. Colo. Apr. 28, 2025), Dkt. No. 312. After conducting an extensive analysis, the court denied the defendants' motion to continue the trial. Coomer, No. 22-cv-01129, slip op. at 1-3 (D. Colo. May 14, 2025), Dkt. No. 334. In arguing for a continuance, the defendants asserted that the court's show cause order imposed a “significant distraction from trial preparation.” Id. at 1 (internal quotation omitted). The court observed that the show cause order "would not have issued so close to trial—or at all—had Defendants reviewed their filing at any point between its submission and the Final Pretrial/Trial Preparation Conference or filed a properly cited brief in the first instance." Id. at 2. With respect to the defendants' concern for a tainted jury pool, the court noted that "voir dire can and should be used to address these concerns." Id. at 3. Ultimately, the court ruled that all of the factors used to determine whether a trial should be continued weighed against ruling in favor of the defendants. Id. at 3-4. See also Rogers v. Andrus Transp. Servs., 502 F.3d 1147, 11151 (10th Cir. 2007) (articulating the "four factors that must be examined to determine whether a trial should be continued"). Following a trial that resulted in a judgment in favor of the plaintiff, Coomer, No. 22-cv-1129 (D. Colo. June 24, 2025), Dkt. No. 381, the court addressed the problematic citation practices of the defendants' counsel. Coomer, No. 22-cv-1129, 2025 WL 1865282 (D. Colo. July 7, 2025). The court recapped that the errors included misquotes, misrepresentations of legal principles, misstatements about the origin of case law, and citations to non-existent cases. Id. The show cause proceedings revealed that lead counsel and co-counsel both signed and certified the relevant filings. Id. at *2. Moreover, lead counsel admitted that AI was used in the drafting process but that he did not personally check the citations afterward. Id. The court found that lead counsel and co-counsel violated Rule 11 by unreasonably certifying that the claims and legal contentions in their filings were justified by existing law or a valid argument for changing the law. Id. at *8. The court imposed sanctions in the amount of $3,000 on both lead counsel (and his firm) and co-counsel. Id. at *9. See also Olivia Prentzel, MyPillow CEO’s lawyers fined for AI-generated court filing in Denver defamation case, Colorado Sun (July 7, 2025); Robin Shea, AI hallucinations cause bad trip for lawyers, JDSupra (May 2, 2025). In an action depriving a student of a visa, the court issued a show cause order for the plaintiff to explain why sanctions should not be imposed for citing a non-existent case in a brief. Minute Order, Doe v. Noem, No. 25-cv-01352 (D.D.C. July 1, 2025). The plaintiff's counsel acknowledged the misuse and apologized for failing to verify the accuracy of the case citation. Response to Order to Show Cause at 1-2, Doe v. Noem, No. 25-cv-01352 (D.D.C. July 3, 2025), Dkt. No. 26. Subsequently, the court received and credited counsel's candid and contrite response. Minute Order, Doe v. Noem, No. 25-cv-01352 (D.D.C. July 10, 2025). The court declined to impose sanctions, but admonished counsel about her use of AI technology in the future when drafting briefs. Id. The court ordered that if a similar error occurs in any case before another judge, counsel shall notify that court about these proceedings, to enable an informed decision on possible sanctions. Id. In a wrongful termination case, the defendant moved to dismiss the federal claims, arguing that the Title VII claim failed to state a claim and that the ADEA claim was barred by Eleventh Amendment immunity. Hill v. Oklahoma, No. 25-cv-522, 2025 WL 1840659, at *1 (D. Okla. July 3, 2025). The court granted the defendant's motion and declined to exercise supplemental jurisdiction over the remaining state-law claim and remanded it to state court. Id. at *2-4. Additionally, the court admonished the plaintiff's counsel regarding citations in the response brief. Id. at *4. The court found that the brief contained case citations that were inaccurate, non-existent, and included direct quotes that could not be located. Id. The court opined that "these inaccuracies signal that Plaintiff's counsel may have used AI to assist in the drafting of Plaintiff's Response (or otherwise counsel produced exceptionally sloppy work)." Id. While the court declined to impose sanctions, the court's order served as a strong admonishment to the plaintiff's counsel, and "forewarned of possible sanctions that the state court [on remand] may choose to impose should counsel continue to submit filings with such inaccuracies as those contained in its Response." Id. at *5. The plaintiff initiated a discrimination action against the defendants, asserting violations of federal and state laws. Taylor v. Cooper Power & Lighting Corp., No. 22-cv-2236, 2025 WL 1734142, at *1 (E.D.N.Y. June 13, 2025). The magistrate judge addressed a motion to vacate a default judgment filed by two of the co-defendants. Id. The magistrate judge recommended denying the motion to vacate the default judgment, concluding that the default was willful, the defendant failed to present a meritorious defense, and vacating the judgment would prejudice the plaintiff. Id. at *8. While AI was not directly referenced, the magistrate judge questioned one of the case citations in the co-defendants' brief, indicating that the case, “or any case resembling it,” could not be located. Id. at *2 n.4. The magistrate judge instructed the co-defendants' counsel to submit a copy of the case or show cause why he should not be sanctioned. Id. Counsel admitted to fabricating the case and claimed it was used as a "placeholder" in a draft. Id. Despite this dubious explanation, the magistrate judge declined to recommend further action with respect to sanctions in lieu of the recommendation to deny the motion. Id. The district judge adopted the magistrate's "well-reasoned" report and recommendation. Minute Order, Taylor, No. 22-cv-2236 (E.D.N.Y. July 2, 2025). The pro se plaintiff filed a lawsuit against the United States, seeking damages for alleged misconduct by various parties during a previous lawsuit he filed against United Airlines under the Americans with Disabilities Act. Parra v. United States, No. 25-cv-431, 2025 WL 1792979, at *1 (Fed. Cl. June 27, 2025). After filing the complaint, the plaintiff filed numerous procedural motions (nine), which the court stayed to address the defendant's motion to dismiss. Id. at *1-2. At the outset, the court explained that it (the United States Court of Federal Claims) "is not a forum for all federal claims; it is one of limited jurisdiction." Id. at *3. The court’s statutory jurisdiction encompasses three types of monetary claims: those arising from contracts with the United States, illegal government exactions, and money-mandating laws or regulations. Id. After an exacting review of the case, the court granted the defendant's motion, concluding that it lacked jurisdiction over the plaintiff's claims. Id. at *1. During the course of its review, the court found that the plaintiff cited fake cases due to an apparent use of AI. Id. at *10. The court observed that the plaintiff submitted a detailed, typed response along with a sur-reply to the defendant's reply brief, both within hours of the defendant's filings. Id. Additionally, the plaintiff's exhibits included what appeared to be questions from the AI program he used to generate many of the 400 pages of documents. Id. The court recognized that while the plaintiff's use of AI did not violate court rules, the citation of fictitious cases did. Id. The court also noted the plaintiff's citation of non-existent cases in his filings. Id. at *11. While the court found that the plaintiff's conduct "failed to meet the bare minimum required by Rule 11," it concluded that "a warning will suffice," as the court lacked jurisdiction over the claims and the defendant did not request sanctions. Id. The court advised the plaintiff that he was on notice of the risks of using AI and may face sanctions for court filings referencing AI-generated fugazi legal authority. Id. The corporate plaintiff filed a lawsuit in state court, asserting various tort and breach of contract claims against the defendant. Sister City Logistics, Inc. v. Fitzgerald, No. 24-cv-148, 2025 WL 1779561, at *1 (S.D. Ga. June 27, 2025). The defendant filed a notice of removal to federal court, which generated a flurry of motions landing before the court. Id. To further conflate the proceedings, an individual signed the corporate plaintiff's complaint and other filings as "attorney in fact," suggesting that the individual was not a licensed attorney. Id. at *1-2. It is well established that a corporation may not be represented pro se by a non-attorney. Id. at *2. Subsequently, an attorney appeared on behalf of the corporate plaintiff. Id. at *1. In addressing the multitude of motions (including the plaintiff's two motions to remand the case to state court), the court ultimately remanded the case to state court. Id. at *2, 4. In a footnote, the court addressed the two motions to remand, the first of which was filed pro se. Id. at *2 n.2. The court noted that the intention of the plaintiff's attorney for the original motion to remand was unclear (i.e, whether it was incorporated into the new motion). Id. As such, the court sought "to address a troubling issue with the original motion." Id. The court observed that the pro se motion was littered with non-existent case law and falsified quotations that do not appear in the cited authorities. Id. In previous cases, the court imposed Rule 11 sanctions against a pro se plaintiff relying on sham legal authority: the court will do so again if sanctions were warranted. Id. (citing Nichols v. Walmart, Inc., No. 24-cv-236, 2025 WL 1178592, at *2 (S.D. Ga. Apr. 23, 2025)). In the end, the court allowed the plaintiff's attorney "the benefit of the doubt by assuming he did not intend to adopt the original motion." Id. Nevertheless, the court warned that any further use of fallacious legal authority would result in a show cause order as to why the culpable party or attorney should not be sanctioned. Id. In Rock v. Perlow, No. 24-cv-181, 2025 WL 2946170, at *1 (W.D. Ky. June 27, 2025), the pro se plaintiffs filed several motions seeking injunctive or extraordinary relief against multiple defendants. The magistrate judge recommended denying all of the motions, citing failure to meet the necessary legal standards for mandamus relief and the lack of jurisdiction to initiate criminal proceedings through a civil action. Id. at *1, *4. Additionally, the court noted that the filings contained fabricated legal citations and incoherent language, raising concerns about the misuse of AI in the legal filings. Id. at *2. The court cautioned the plaintiffs of the risks of being deemed a vexatious litigant due to the frivolous filings and abuse of the judicial process. Id. at *3. A pro se plaintiff initiated an action against the defendants, alleging violations of the Fair Debt Collection Practices Act (FDCPA) and state law claims such as wrongful eviction and breach of contract. Gordon v. CSS Serv. Inc., No. 23-cv-5400, 2025 WL 2743677, at *1 (N.D. Ga. June 26, 2025). In a report and recommendation, the magistrate judge addressed several motions, including motions to dismiss filed by the defendants, a motion for judicial notice, a motion to strike, and a motion for clerk's entry of default and default judgment. Id. The court recommended granting the defendants' motion to dismiss the FDCPA claims due to the expiration of the statute of limitations and the lack of plausible allegations. Id. at *7-8. The magistrate judge also recommended declining to exercise supplemental jurisdiction over the remaining state law claims and dismissing the claims without prejudice. Id. at *9. Additionally, the magistrate judge denied the plaintiff's motions for judicial notice, to strike, and for default judgment. Id. In reaching a conclusion, the magistrate judge suspected that the plaintiff used an AI application to generate her briefs, which fabricated case citations and misidentified court cases. Id. at *5. The magistrate judge opined that under other circumstances, the matter would be set for a show cause hearing on why she should not be sanctioned for this misconduct. Id. In light of the plaintiff's pro se status and the dismissal recommendation, the magistrate judge declined to do so. Id. The district judge adopted the magistrate's recommendation and overruled the plaintiff's objections. Gordon, No. 23-cv-5400, 2025 WL 2743671, at *3-4 (N.D. Ga. July 29, 2025). Accordingly, the defendants' motion to dismiss regarding the federal claims was dismissed, and the court declined to exercise jurisdiction over the state claims. Id. The court directed the clerk to close the case. Id. In Romero v. Goldman Sachs Bank USA, No. 25-cv-2857, 2025 WL 1916119, at *1 (S.D.N.Y June 25, 2025), the pro se plaintiff filed a motion in limine to preclude new evidence in support of the defendant's motion to compel arbitration. A significant issue arose when the court found that two of the plaintiff's key citations were erroneous. Id. The court suspected that these errors resulted from using GAI tools—known to hallucinate legal authority (and other things). Id. Acknowledging the plaintiff's status as an unrepresented litigant, the court declined, at this point, to make any findings that the plaintiff submitted fictitious AI-generated citations. Id. Rather, the court reminded the parties of their obligations under Rule 11 (applying to both represented and pro se litigants) and warned that violations could result in sanctions. Id. at *1-2. Specifically, the court advised the parties that citations, quotations, and holdings generated by GAI may be fictitious, and presenting such false material to the court was sanctionable conduct. Id. at *2. In a pro se habeas proceeding before a magistrate judge, the pro se petitioner challenged the calculation of his earned time credits under the First Step Act during his pretrial detention. McClellon v. Rickard, No. 24-cv-10053, 2025 WL 3286917, at *1 (S.D.N.Y. June 24, 2025). The petitioner was convicted of wire and bank fraud and sentenced to 42 months in prison. Id. He argued that he was entitled to time credits for programs completed during his pretrial detention. Id. The magistrate judge recommended denying the petition for habeas relief, finding that under the pertinent act, prisoners cannot earn time credits for programs completed before their sentence commences. Id. at *8. Moreover, the magistrate judge also dismissed his conditions-of-confinement claims as moot since he was no longer at the facility in question and recommended dismissing his request for compassionate release for lack of jurisdiction, as it must be filed in the sentencing court. Id. at *10-11. Additionally, the case highlighted the potential misuse of AI tools in legal research, as the petitioner cited non-existent cases in his filings. Id. at *12. The magistrate judge declined to impose monetary sanctions on the petitioner, a pro se litigant, possibly due to a lack of awareness about the risks of using AI tools that generate fake citations. Id. The magistrate judge recommended that the petitioner submit a copy of the report to any court where he has an active case to prevent similar issues from arising in the future. Id. In Schoene v. Oregon Dep't of Hum. Servs., No. 23-cv-742, 2025 WL 1755839, at *1 (D. Or. June 25, 2025), the pro se plaintiff initiated an action against the defendants, asserting federal statutory claims and state law claims. The defendants moved for summary judgment on all claims, and the plaintiff responded to some but not all of their arguments, as well as seeking leave to file an amended complaint. Id. The court granted the defendants' motion on the federal claims and declined to exercise jurisdiction over the state-law claims; the court denied the plaintiff's motion to amend the complaint. Id. at *8. In examining the plaintiff's motion to amend the complaint, the court found several non-existent case citations in the plaintiff's reply brief to support her motion to amend. Id. at *7. The court opined that the false citations appeared to be hallmarks of AI tools. Id. The court noted AI-hallucinated case citations were now well known, and a basic internet search seeking guidance on AI conducting legal research or drafting legal briefs advised that AI-generated content must be verified. Id. The court cautioned the plaintiff to verify the accuracy of any future citations in court filings. Id. In a pro se action, the plaintiff sought redress against the defendants for "handling a complaint against him." Reilly v. Conn. Interlocal Risk Mgmt. Agency, No. 25-cv-640, 2025 WL 1726366, at *1 (D. Conn. June 20, 2025). The plaintiff also sought to proceed in forma pauperis; however, the court found that the plaintiff's complaint likely failed to state a claim upon which relief could be granted. Id. The court issued a show cause order, indicating its intent to dismiss the action unless the plaintiff could provide further facts or legal arguments to support his claims. Id. The court concluded that the complaint did not, as the plaintiff failed to address the court's concerns substantively and instead focused on arguments about the screening process for in forma pauperis complaints. Id. at *1-2. Additionally, the court noted that the plaintiff's filings contained several instances where case citations did not match the propositions for which they were cited, and one quote attributed to a case was incorrect. Id. at *2. The court surmised that the plaintiff might have used AI to draft his submissions. Id. The court cautioned the plaintiff to ensure that future submissions contain only accurate representations, highlighting the potential and limitations of AI in legal proceedings. Id. at 2-3. The court dismissed the action and requested the clerk to close the case; the plaintiff's pending motions were denied as moot. Id. at *2. On June 16, 2025, the appellate court held that the trial court did not abuse its discretion in denying a motion to reduce child support. In re Isom, 2025 IL App (3d) 240491-U, ¶ 1. In reaching a decision, the appellate court found two incorrect citations in the appellant's brief. Id. ¶ 15. The appellate court opined: "The brief reads as though [the appellant] conducted his legal research through ChatGPT rather [than] through reliable resources like Westlaw or Lexis." Id. Ultimately, the appellate court concluded that the appellant's "failure to support his position with any valid legal authority or an adequate record violate[d] Supreme Court Rule 341(h)(7)." Id. ¶ 17. In an appeal involving a contract dispute, the court ordered the plaintiffs to file copies of cases that could not be located in the plaintiffs' appellate brief. Rochon-Eidsvig v. JGB Collateral, LLC, No. 05-00123-CV, slip op. at 1-2 (Tex. Ct. App. Apr. 10, 2025). After receiving the plaintiff's response, the court ordered the plaintiff's counsel to appear at a hearing on the "drafting" of the plaintiff's opening brief. Rochon-Eidsvig, No. 05-00123-CV, slip op. at 1 (Tex. Ct. App. Apr. 24, 2025). Following the May 8, 2025, hearing, at the court's request, the defendant filed an affidavit providing the costs ($6,232) related to evaluating and addressing the four non-existent cases cited in the plaintiff's appellate brief. Affidavit of David G. Webster at 3, Rochon-Eidsvig, No. 05-00123-CV (Tex. Ct. App. May 13, 2025). Subsequently, the court addressed counsel’s use of technology to prepare a legal brief that included citations to non-existent cases. Rochon-Eidsvig, No. 05-00123-CV, slip op. at 2 (Tex. Ct. App. June 12, 2025). The court determined that counsel did not intend to deceive. Id. However, she did not verify the information before submitting it to the court and failed to clarify or correct the citations, even after opposing counsel pointed out in their opening brief that the citations referred to cases that did not exist. Id. In imposing sanctions, the court opined that "[t]he use of AI or other technology does not excuse carelessness or failure to follow professional standards." Id. at 4. Ultimately, the court ordered counsel to complete continuing legal education courses on ethics, technology, and GAI use, as well as imposing a monetary sanction of $2,500. Id. at 4-5. In Ferris v. Amazon.com Servs. LLC, No. 24-cv-304, 2025 WL 1122235, at *1 (N.D. Miss. Apr. 16, 2025), the court issued a show cause order involving the citation of false authority and the use of GAI. The court was inclined to dismiss the plaintiff's case due to the numerous fabricated citations in his filings; however, relevant Fifth Circuit authorities provided for less final sanctions. Id. at *2. Recognizing the considerable discretion to craft an appropriate sanction, the court ruled that the plaintiff must pay the costs incurred by the defendant to respond to the phony citations. Id. at *2-3. In ruling, the court opined: Courts exist
to decide controversies fairly, in accordance with the law. This function is
undermined when litigants using AI persistently misrepresent the law to the
courts. AI is a powerful tool, that when used prudently, provides immense
benefits. When used carelessly, it produces frustratingly realistic legal
fiction that takes inordinately longer to respond to than to create. While one
party can create a fake legal brief at the click of a button, the opposing
party and court must parse through the case names, citations, and points of law
to determine which parts, if any, are true. As AI continues to proliferate,
this creation-response imbalance places significant strain on the judicial
system. Trials are a
search for the truth. Parties who cite false cases not only seek to secure
unfair advantage, they are, in fact, avatars of a post-truth world. Some people
seem to believe that facts and truth no longer matter, but that is not how we
do things in this Court. If the third branch of government in these United
States cannot hold course and tack against the headwinds of foolishness and
utter contempt for the truth daily poured into the body politic by strivers
saluted by the fourth estate, then we are condemned to a: “Depressing view,”
said K. “The lie made into the rule of the world.” Id. at *1-2 (quoting Franz Kafka, The Trial 147 (1925)). Subsequently, the court granted the defendant's motion to dismiss with prejudice, thereby closing the case. Ferris, No. 24-cv-304, 2025 WL 1643484, at *3 (N.D. Miss. June 9, 2025). The final amount of the sanctions was not yet revealed, as the defendants have not yet filed a detailed bill of costs as directed by the court in the previous show cause order. Ferris, No. 24-cv-304, 2025 WL 1122235, at *3. In a pro se employment discrimination lawsuit, the court addressed several motions, including the defendant's motion to dismiss, the plaintiff's motion for leave to file a second amended complaint, and the defendant's motion to strike one of the plaintiff's briefs. Goins v. Father Flanagan's Boys Home, No. 23-cv-477, 2025 WL 1592038, at *1 (D. Neb. June 5, 2025). The defendant moved to strike the plaintiff's brief in opposition to the motion to dismiss, in part, because the defendant suspected the plaintiff may have used GAI to cite fictitious cases. Id. at *2. The court noted that local rules permitted the use of GAI programs, but all parties, including pro se litigants, must certify and verify the accuracy of all generated text in court filings. Id. at *3. The court observed that the plaintiff's brief contained no such certification, and the plaintiff denied using AI. Id. The court found that while most citations in the plaintiff's brief were valid, some either lacked legal support or contained typographical errors resembling previously identified hallucinatory citations. Id. The court warned that repeated misconduct could lead to sanctions, even for a pro se litigant. Id. Ultimately, the court ruled in favor of the defendant and dismissed the case. Id. at *7. | |||||||||||||||||||||||||||||||||
The court
considered several motions by one of the pro se co-defendants, as well as a
demand for sanctions. Powhatan Cnty. Sch. Bd. v. Skinger, No. 24-cv-874,
2025 WL 1559593, at *1 (E.D. Va. June 2, 2025). Notably, the plaintiff raised
concerns about the citations used by the co-defendant in her filings, noting
that many citations refer to non-existent or irrelevant cases. Id. In
addition to technical deficiencies, the court identified numerous instances
where the co-defendant cited cases that do not exist or provided incorrect
citations, making it difficult to verify the authority. Id. at *1-2.
Significantly, the court enumerated 42 citations to authority by the
co-defendant that did not exist. Id. at *3-8. The court noted that the
co-defendant admitted in writing to using GAI in at least one of her filings. Id.
at *9. The court opined: The pervasive
misrepresentations of the law in [the co-defendant's] filings cannot be
tolerated. It serves to make a mockery of the judicial process. It causes an
enormous waste of judicial resources to try to find cited cases that do not
exist and to determine whether a cited authority is relevant or binding, only
to determine that most are neither. In like
fashion, [the co-defendant's] adversaries also must run to ground the
nonexistent cases or address patently irrelevant ones. The adversaries must
thus incur needless legal fees and expenses caused by [the co-defendant's]
pervasive citations to nonexistent or irrelevant cases. Id. at *10. The court observed that attorneys would be subject to sanctions for such abuses; however, the pro se co-defendant "appear[ed] to be judgment proof so monetary sanctions likely will not deter her from the abusive practices reflected in her filings and in her previously announced, consistently followed, abuse of the litigation proceedings created by . . . 20 U.S.C. § 1400, et seq." Id. The court concluded that the most appropriate remedy was to strike the co-defendant's filings to the extent they were burdensome by virtue of volume and exceeded page limitations, they were not cogent or understandable, and they misrepresented the law by citing nonexistent or utterly irrelevant cases. Id. at *11. In Andersen v. Olympus as Daybreak, No. 25-cv-178, 2025 WL 1547065, at *1-2 (D. Utah May 30, 2025), the magistrate judge denied the pro se plaintiff's motion for alternative service on the grounds that he failed to establish reasonable diligence in the service attempts. In reaching that conclusion, the magistrate judge rejected the plaintiff's arguments that federal courts recognized financial hardship justified alternative service. Id. at *2 n.17. Notably, the plaintiff failed to provide any support for the argument other than conclusory statements. Id. Importantly, the magistrate judge could not locate the cases cited by the plaintiff. Id. Previously in this case, the district judge addressed this issue in a recent order, noting that the plaintiff included "a case quotation in his motion that did not exist." Id. The magistrate judge reiterated that any further instances of such conduct warranted sanctions under Rule 11. Id. In the Southern District of Indiana, a magistrate judge issued a report and recommendation to impose sanctions for an attorney’s failure to recognize non-existent AI-generated cases in his filings. Mid Cent. Operating Eng’rs Health & Welfare Fund v. HoosierVac LLC, No. 2:24-cv-00326, 2025 WL 574234, at *3 (S.D. Ind. Feb. 21, 2025), Dkt. No. 99. At a show cause hearing to explain the citations to non-existent cases, the attorney explained that he had previously used AI to assist with legal matters, and he was unaware of AI’s potential for creating fictitious cases and citations. Id. at *1. The attorney claimed that the materials “appeared to be credible,” and he did not conduct any further inquiry into the validity of the citations. Id. The judge observed that the appearance of validity of the AI-generated material did not absolve the attorney from “his duty to conduct a reasonable inquiry” under Rule 11. Id. at *3. In reaching a conclusion, the judge recommended that the attorney be sanctioned in the amount of $15,000 ($5,000 for each of the three briefs filed with false citations) and referred the matter to the chief judge for consideration of further discipline pursuant to local rule. Id. at *5. In a subsequent ruling, the district judge referred the matter to the Indiana Attorney Disciplinary Commission for investigation and prosecution pursuant to local rules. Mid Cent. Operating Eng’rs, No. 24-cv-00326, at *1 (S.D. Ind. Mar. 6, 2025). Upon reviewing the magistrate's report and recommendation, the court determined that a penalty of $6,000 would be adequate to prevent the recurrence of such conduct or similar conduct by others in comparable situations. Mid Cent. Operating Eng’rs, No. 2:24-cv-00326, slip op. at 3 (S.D. Ind. May 28, 2025), Dkt. No. 121. In reaching its conclusion, the court noted that the attorney argued the sanctions were moot because he suffered "significant and irreversible harm" to his professional reputation. Id. at 1. The court rejected the attorney's argument because the admitted violations were within the court's jurisdiction to impose sanctions. Id. at 2. In reducing the amount of sanctions from $15,000 to $6,000, the court considered the attorney's remedial measures in educating himself on the responsible use of AI and the collateral consequences to the attorney's reputation. Id. In closing, the court opined that sanctions were warranted partly because the penalties previously imposed on other attorneys for similar misconduct have clearly failed to serve as a deterrent. Id. at 3. In Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enters. LLC, No. 17-cv-81140, 2025 WL 1440351, at *1 (S.D. Fla. May 20, 2025), the court sua sponte considered the imposition of sanctions on the defendants for filing a response brief containing "a clear hallucination" of legal authority. In a reply brief, the plaintiff claimed that the citation could not be located, and the court verified this claim that no such case existed. Id. In response, the defendants indicated that counsel attempted to use AI to help with legal, "never having used it before." Id. at *2. Once counsel determined that the case cited did not exist, he called the plaintiff's counsel to apologize and to take appropriate remedial actions. Id. In considering sanctions, the court opined, "there is nothing inherently wrong with an attorney properly and competently utilizing AI or any of its subsets to practice law or litigate cases." Id. at *4. In the face of evolving technology, the court noted that "[j]ust as a competent attorney would very carefully check the veracity and accuracy of all case citations in any pleading, motion, response, reply, or other paper prepared by a law clerk, intern, or other attorney before it is filed, the same holds true when attorneys utilize AI or any other form of technology." Id. The court concluded that sanctions should be imposed only on the attorneys for the defendants (as they had no role in drafting and filing the offending document). Id. at *5. The court also issued the following warning: This case should be a warning to lawyers that your pleadings, motions, responses, replies, and other papers filed with any Court must be first checked and then double-checked. There is no room in our court system for the submission of fake, hallucinated case citations, facts, or law. And it is entirely preventable by competent counsel who do their jobs properly and competently. Id. at *7. The court ruled that the plaintiff would be awarded all reasonable attorney's fees and costs incurred by its counsel for time spent in researching and replying to the defendants' response. Id. The court also ordered the defendants' counsel (both lead and local) to attend and complete CLE training on AI usage and to pay fines ($1,000 for lead counsel and $500 for local counsel) to the Registry of the Clerk. Id. The plaintiff's attorney subsequently filed a notice, indicating that fees and costs amounted to $11,881. Versant Funding LLC, No. 17-cv-81140 (S.D. Fla. May 28, 2025), Dkt. No. 391. The court found the proposed amount to be high, expecting the total to be between $2,500 and $5,000. Id. The court ordered the parties' counsel to confer and resolve the issue. Id. After conferring, the parties agreed that the reasonable attorneys’ fees and costs incurred by the plaintiff’s attorneys for researching and replying to the defendants’ response amounted to $5,000. Joint Notice Regarding Settlement of Plaintiff’s Attorneys’ Fees at 2, Versant Funding LLC, No. 17-cv-81140 (S.D. Fla. May 30, 2025), Dkt. No. 393. The court noted counsel's "prompt compliance and cooperation" and closed this particular matter. Versant Funding LLC, No. 17-cv-81140 (S.D. Fla. May 30, 2025), Dkt. No. 394. In Nextpulse, LLC v. Life Fitness, LLC, No. 22-cv-03239, slip op. at 1 (N.D. Ill. Mar. 7, 2025), Dkt. No. 180, the magistrate judge sua sponte entered a show cause order against the plaintiff's lead counsel "to show why she should not be sanctioned for including false case citations in a brief filed in this matter." In a response brief to the defendant's motion to compel, counsel discussed a legal standard set forth by the Seventh Circuit and cited three cases as legal authority. Id. at 1-2. Six days later, the plaintiff filed a Notice of Errata, indicating in part that two of those case citations did not exist and should be ignored. Id. at 2. The plaintiff also noted a misattributed quotation in the brief. Id. At the subsequent motion hearing, lead counsel did not appear, but a new and unprepared local counsel appeared on behalf of the plaintiff. Id. at 3. The magistrate judge continued the hearing and required lead counsel to appear to address the errors in the plaintiff's response brief, including those noted in the accompanying errata. Id. In response, lead counsel claimed that the false case citations were inadvertently added to the brief while demonstrating the potential pitfalls of using AI for legal work to her daughter, leading to an unedited version being submitted to a paralegal. Id. at 4-5. Lead counsel only became aware of the error days later when local counsel could not find two of the cited cases, prompting her to prepare an erratum to notify both counsel and the Court. Id. at 5. The magistrate judge found defense counsel's explanation dubious (the "defense beggars belief"), particularly her claim that including fabricated cases in her brief was necessary for a “teachable moment.” Id. at 6. The proffered timeline of discovering the error and scrambling to address it was implausible, raising doubts about defense counsel's candor and honesty. Id. at 6-7. It appears that local counsel informed her of the issue soon after the brief was filed, contradicting her assertion of a five-day delay. Id. at 7. Consequently, the magistrate judge concluded that defense counsel’s use of GAI showed bad faith and warranted sanctions. Id. at 8. In light of the case's pending settlement, the magistrate limited the sanctions to a penalty of $5,000 and referral to the executive committee for further consideration. Id. at 9. Following a hearing on the plaintiff's objections to the aforementioned ruling, the district judge rejected the magistrate judge's report and recommendation for reasons stated on the record. Nextpulse, LLC, No. 22-cv-03239, slip op. at 1 (N.D. Ill. May 27, 2025), Dkt. No. 195. The parties' stipulated dismissal likely played a part in the district judge's determination. Stipulated Dismissal with Prejudice at 1-2, Nextpulse, LLC, No. 22-cv-03239 (N.D. Ill. May 1, 2025), Dkt. No. 193. The petitioner opposed the issuance of a notice of determination concerning a tax issue. Bauche v. Comm'r, T.C.M. (RIA) 2025-48, 2025 WL 1446911, at *1 (T.C. May 20, 2025). The commissioner moved for summary judgment, which the court partially granted and partially denied, remanding the case for a second supplemental hearing. Id. The court concluded that the commissioner was not "deemed to have accepted" the petitioner's offer in compromise. Id. at *22. However, due to inadequacies in the administrative record regarding economic hardship and public policy or equity considerations, the court remanded the case for further development. Id. In reaching a decision, the court noted that the petitioner's brief inappropriately cited non-existent cases. Id. at *20. The court exercised discretion not to impose sanctions but warned the petitioner that further citation to non-existent case law would result in sanctions. Id. In Gjovik v. Apple Inc., No. 23-cv-4597, 2025 WL 1447380. at *1 (N.D. Cal. May 19, 2025), the pro se plaintiff filed a motion to strike and a motion for a more definite statement. The thrust of the plaintiff's motions circled around the defendant's affirmative defenses and the clarity of its responses to the plaintiff's claims. Id. The court granted the motion to strike several of the defendant's affirmative defenses due to a lack of concrete factual support, but allowed the defendant to amend its answer. Id. at *3. The court denied the motion for a more definite statement because the plaintiff was not required to file a responsive pleading, as the defendant had not filed any counterclaims. Id. at *1. The court also addressed the defendant's claims that the plaintiff's use of AI in preparing her court filings. Id. at *7. The defendant claimed that the plaintiff's use of AI was problematic due to her failure to verify the accuracy of the generated information. Id. The defendant highlighted several incorrect examples to support its argument. Id. The plaintiff claimed she made a good faith effort to review and edit the content as time and resources allowed. Id. The court declined to impose any sanctions. Id. However, the court warned the plaintiff that she must verify the accuracy of information generated or provided by AI, including case citations and content. Id. Failure to do so could result in sanctions, which may include a finding of contempt or the requirement to proceed pro se. Id. In closing, the court underscored that it was the plaintiff's responsibility to confirm the accuracy of information before she filed any papers with the court; the burden was not on the defendant to identify what information was problematic. Id. Additionally, the court informed the defendant that if it pursued Rule 11 sanctions based on the plaintiff's filings, it must adhere to the rule's procedures, including the safe harbor provision. Id.
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