Published opinion, 10 April 2026 · source · PDF · 6 pages
Some of the cited cases both exist and are cited for legal propositions that the cited cases actually represent. Some of the cited cases do not exist. And some of the cited cases are cited for legal propositions that the cited cases do not actually represent.
And some of the cited cases are cited for legal propositions that the cited cases do not actually represent. We recently addressed a similar scenario where a pro se litigant submitted a filing to this Court that cited to non-existent cases, as well as cited to actual cases which did not stand for the legal propositions asserted in the filing . See Hessert v.
3 produced by pro se litigants and attorneys alike with the assistance of AI that cite non-existent cases or that cite actual cases for inaccurate legal propositions.” Hessert, 2026 WL 785016, at *1.
Ultimately, in Hessert we issued an order to show cause why the pro se litigant in that case should 5 not be sanctioned for filing a petition that contained non-existent cases and that cited to cases for inaccurate legal propositions.