District of Columbia · federal district court · 2025

N-Bar Trade Inc. v. amazon.com Services LLC

District Court, District of Columbia, 22 October 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · D.D.C.

  1. Court. District Court, District of ColumbiaCOURT
  2. Level. federal district courtLEVEL
  3. Date. 22 October 2025DATED
  4. Docket. No. Civil Action No. 2025-0918DOCKET
  5. Judge. Judge Rudolph ContrerasJUDGE
  6. Documents. one document, 4 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

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

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 22 October 2025 · source · PDF · 16 pages

VI. USE OF NONEXISTENT QUOTATIONS As this Court has observed, “[c]ourts have recently seen increasing reliance on artificial intelligence in legal proceedings, leading to the use of nonexistent citations in court documents.” Williams v. Cap.

Mr. Nawash is advised that it is not acceptable to submit filings to the Court containing nonexistent quotations. Such conduct contravenes an attorney’s duty toward his client to exercise professional judgment and responsibility.

The Court agrees with the Second Circuit that, at minimum, such rules “require that attorneys read, and thereby confirm the existence and validity of, the legal authorities on which they rely.” Park, 91 F.4th at 615. Courts have taken diverse disciplinary actions against attorneys who have filed pleadings and other court papers citing nonexistent legal authorities and quotations, ranging from striking the pleadings, see, e.g., Grant v. City of Long Beach, 96 F.4th 1255, 1256–57 (9th Cir.

16 However, if this case somehow returns to this Court, Mr. Nawash will be required to show cause why he ought not be sanctioned for his use of nonexistent quotations in his filing. VII.

What the text mentions

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

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

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