Delaware · other tribunal · 2025

Daniel Jaiyong An v. Archblock, Inc.

Court of Chancery of Delaware, 4 April 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Del. Ch.

  1. Court. Court of Chancery of DelawareCOURT
  2. Level. other tribunalLEVEL
  3. Date. 4 April 2025DATED
  4. Docket. No. 2024-0102-LWWDOCKET
  5. Judge. Will V.C.JUDGE
  6. Documents. one document, 5 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, 4 April 2025 · source · PDF · 6 pages

25) (“Mot.”). 2 The defendants likewise observe that the Motion “fabricates authority that does not exist.” See Defs.’ Opp’n to Pet.’s Mot. to Compel (Dkt. 26) ¶ 43.

2004) (recognizing that relying on “non - existent precedent generated by” AI is “an abuse of the adversary system” (citation 2024-0102-LWW April 4, 2025 Page 4 of 6 The petitioner’s submission of a filing with fictitious citations is sanctionable.13 “[I]t is improper and unacceptable for litigants —including pro se litigants—to submit ‘non -existent judicial opinions with fake quotes and citations.’”14 At the same time, “Delaware judges traditionally (and naturally) treat self-represented individuals with some degree of latitude” so long as the party’s pro se status does not “impose[] on the party opponent in a material way.”15 Mindful of these interests, I would have been inclined to […]

New York City Dep’t of Educ ., 2024 WL 3460049, at *7 (S.D.N.Y. July 18, 2024) (“Sanctions may be imposed for submitting false and nonexistent legal authority to the Court.” (citations omitted)). 14 Id.

Supp. 3d at 448); Morgan, 2023 WL 6976510, at *7 (“Although courts ‘make some allowances for the pro se [p]laintiff’s failure to cite to proper legal authority,’ courts do not make allowances for a [party] who cites to fake, nonexistent, misleading authorities.” (quoting James v. Wadas, 724 F.3d 1312, 1315 (10th Cir.

Sept. 6, 2024) (reminding a pro se litigant that she must comply with procedural rules and that “future filings with citations to nonexistent cases may result in sanctions such as dismissal of her claims”) ; Dukuray v. Experian Info.

What the text mentions

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Where this fits

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More from Court of Chancery of Delaware, from Delaware, 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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