A court sanctions invented citations
On 11 June 2026 a federal judge in the Eastern District of Texas, in McCormick v. Texakoma Financial, sanctioned the plaintiff's lawyer: her response to a motion contained an invented case, invented quotations from a real case and propositions the cited decisions do not contain. The court imposed a public reprimand, a USD 5,000 penalty and a review of every filing she signed since 1 January 2026.
Why it matters
The order shows where courts' response has moved: from an admonition and a small fine to a public reprimand, a compulsory review of earlier filings and service on every judge of the district. The court itself writes that fines so far have not deterred enough. An editorial assessment.
The case is a Telephone Consumer Protection Act suit, no. 4:25-cv-773. The response to a summary-judgment motion, filed on 14 January 2026, contained a fictitious case, Noviello v. Bayview, two fictitious quotations from a real case, Texas v. American Blastfax, and six propositions that the cited decisions do not support. The court issued an order to show cause on 15 May and held the hearing on 28 May. It found counsel's explanation, that a clerk drafted it and the wrong version was filed, not credible. The sanctions: a public reprimand; the order to be published in the Federal Supplement and served on every district and magistrate judge of the district; a review of every filing she signed since 1 January 2026 in any federal or state court, with a sworn certification within ninety days; a USD 5,000 penalty within fourteen days, jointly with her firm; the response stricken, with a corrected one allowed within five days; at least two hours of training on the ethical use of AI; for one year a signed certification of verification on every filing that cites authority. The defendant may move for its fees. The court cites a database of AI-hallucination cases among US lawyers: 239 cases as the Fifth Circuit noted, and 434 as of 11 June 2026. What the record does not claim: the order does not say which system wrote the text, counsel could not establish it and the court did not determine it. The words about a 'systemic threat to justice' that a paraphrase of the order carried are not in it.