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District of Columbia · federal district court · 2025

Williams v. Capital One Bank, N.A.

District Court, District of Columbia, 18 March 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. 18 March 2025DATED
  4. Docket. No. Civil Action No. 2024-2032DOCKET
  5. Judge. Judge Rudolph ContrerasJUDGE
  6. Documents. one document, 6 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, 18 March 2025 · source · PDF · 16 pages

See Compl. at 31–32 (Count Four). 6 Lastly, the Court will address Williams’s citation of nonexistent authority. See Pl.’s Opp’n at 2– 5.

15 C. Citations to Nonexistent Legal Authority Courts have recently se en increasing reliance on artificial intelligence in legal proceedings, leading to the use of nonexistent citations in court documents. See Park v.

See Pl.’s Opp’n at 2–3 (referring to legal generative AI program CoCounsel); Def.’s Reply at 3 (explaining that Capital One “can find no such cases with the listed case captions that stand for the position Plaintiff claims they do”). Williams cites to cases that do not exist and may either be from his imagination or represent hallucinations of artificial intelligence. See Pl.’s Opp’n at 4–5.

Other cases cited in Williams’s brief present similar issues. The use of these nonexistent citations dramatically weakens Williams’s opposition to Capital One’s motion to dismiss because he fails to cite to supporting authority. It is not acceptable for parties to submit filings to the Court containing citations to legal authority that does not exist, whether drafted with the assistance of artificial intelligence or not.

See Park, 91 F.4th at 616 (referring attorney for investigation for drafting her brief by relying on 16 ChatGPT, an artificial intelligence tool); Ruggierlo, 2023 WL 5846798, at n.5 (warning a pro se defendant that using generative artificial intelligence to create citations may result in court- imposed sanctions and wasted the court’s, the opposing party’s, and defendant’s own resources); Anonymous, 2024 WL 3460049, at *7 (warning a pro se plaintiff that citations generated by artificial intelligence are unreliable, and that citation to nonexistent legal authority is unacceptable).

Dated: March 18, 2025 RUDOLPH CONTRERAS United States District Judge 6 The Court notes that Williams has other cases pending before other judges of this Court. If Williams has followed the same practices in those courts to generate pleadings that remain pending, he must notify such courts and correct citations to erroneous or non-existent cases.

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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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