AI-related case
Saxena v. Martinez-Hernandez et al.
AI UseThe plaintiff submitted citations that were entirely fabricated. When challenged, Saxena denied AI use and insisted the cases existed, offering no evidence. The court concluded either he fabricated the citations or relied on AI and failed to verify them.Hallucination DetailsSpokane v. Douglass turned out to conflate unrelated decisions and misused citations from other casesHummel v. State could not be found in any Nevada or national database; citation matched an unrelated Oregon caseThe court found no plausible explanation for these citations other than AI generation or outright fabrication.Ruling/SanctionThe court dismissed the case with prejudice for repeated failure to comply with Rule 8 and for the submission of fictitious citations. Though no separate sanctions motion was granted, the court's ruling incorporated the AI misuse into its reasoning and concluded that Saxena could not be trusted to proceed further in good faith.Key Judicial ReasoningCiting Morgan v. Cmty. Against Violence, the court reasoned that “courts do not make allowances for a plaintiff who cites to fake, nonexistent, misleading authorities.” Saxena’s refusal to acknowledge the fabrication compounded t…
Judges: Cristina Dionne Silva