Indiana · federal district court · 2026

Lawtone-Bowles v. Purdue University Global

District Court, N.D. Indiana, 20 April 2026 to 8 July 2026. What the court wrote about citations that did not exist, in its own words, from 2 documents on file.

Case record · N.D. Ind.

  1. Court. District Court, N.D. IndianaCOURT
  2. Level. federal district courtLEVEL
  3. Dates. 20 April 2026 to 8 July 2026DATED
  4. Docket. No. 4:26-cv-00028DOCKET
  5. Judge. Philip P. SimonJUDGE
  6. Documents. 2 documents, 12 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.

Docket entry 59, 8 July 2026 · source · PDF · 5 pages

Docket text. BRIEF in Opposition to 47 MOTION for Hearing (DEFENDANTS' RESPONSE IN OPPOSITION TO PLAINTIFF'S RENEWED MOTION FOR PRELIMINARY INJUNCTION DKT. 48) filed by Sarah Diab, Shaun Jamison, Purdue Global Law School, Purdue University Global, Brian Victor, Victoria Vidt. (Gallagher, Amanda) (Entered: 07/08/2026)

Here, Purdue Global did not rely solely, or even primarily, on AI -detection software. The findings rested on other evidence: fabricated citations, implausible completion times, and Plaintiff’s inability to demonstrate the same knowledge when questioned. Declaration of Carolyn Nordstrom, Dkt.

Id. at ¶¶ 18-19. Her submissions contained fabricated legal citations , either to citations that did not exist or cases unrelated to the propositions for which they were offered. Id. at ¶ 34.

Id. at ¶ 45. They were based on content, timing, citation fabrication, and credibility —none of which can be explained by speech -to-text software. Id. at ¶¶ 43-45.

Id. at ¶¶ 43-45. Fabricated citations, inability to demonstrate knowledge during oral examination, and implausible completion times are not the product of dictation technology. Id. at ¶ 44.

Docket entry 16, 20 April 2026 · source · PDF · 85 pages

Docket text. (Unsigned) BRIEF in Support of 3 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction titled Plaintiff's Reply in Support of Motion for Temporary Restraining Order filed by Nicole Lawtone-Bowles. (Attachments: # 1 Exhibit, # 2 Envelope)(jdb) (Entered: 04/20/2026)

34. The Committee identified numerous issues in Plaintiff's w'ork, including: a. inaccurate or fabricated legal citations; b. citations that did not correspond to the propositions for which they were offered; c. inconsistencies in Plaintiff's explanations regarding how the work was prepared. • 35. The Committee concluded that Plaintiff's submissions did not reflect genuine legal researG~ and writing and were consistent with the use of unauthorized assistance or fabrication.

In the materials provided by the student, there was her own article, "When Accommodation Becomes Suspicion," explaining her situation. Of the five sources cited/referenced, two were fabricated sources (Harbour and Onwuachi-Willig). After reviewing all submitted materials and following a hearing where the student was provided an opportunity to present information, the preponderance of evidence supports the conclusion that the student engaged in conduct inconsistent with the University's academic integrity policy.

These errors are more consistent with fabrication or hallucination associated with generative Al than with mere inadvertence. ·•As to the assignment in Module 8, the evidence of academic misconduct is even stronger. • First, as the Student conceded during oral argument, the years given for the case citations in her assignment were almost all incorrect, with Appeal of Aversa as the apparent exception. • Second, with the same exception, the cited cases bore little or no relation to the propositions for which they were offered.

Appeal to Provost Provost Decision Expected By ----------------------- --------- Committee Processing System at oral argument that she had fabricated those citations, which would explain why she could not provide the Committee with the corresponding decisions from that reporter rather than from the public website. • Taken together, these errors and shifting explanations lead me to conclude that the Module 8 assignment did not reflect genuine legal research and writing but was rather the product of Al hallucinations.

These inaccuracies are notable in light of the student's stated advanced legal training (including a master's degree in law) and her representation during oral argument that she was trained to carefully proofread citations. Under such circumstances, these errors are less consistent with ordinary inadvertence and more consistent with citation fabrication or Al­ generated hallucination, both of which undermine the credibility of the submission. With respect to the Module 8 assignment: As the student conceded during oral argument, the years given for the case citations in her assignment were almost all incorrect, with Appeal of Aversa as the apparent exception.

That explanation, however, is difficult to reconcile with her March 24, 2026, email to the Committee, in which she stated that she was providing PDFs of the cases so that the Committee could "cross-check" them against the propositions in her paper and verify that "the cases are real." Moreover, with respect to the citations to the Education Department Reporter, the student appeared to acknowledge at oral argument that she had fabricated those citations, which would explain why she could not provide the Committee with the corresponding decisions from that reporter rather than from the public website.

Of the five sources .. cited/referenced, two were fabricated sources (Harbour and Onwuachi-Willig). . • After reviewing all submitted materials and following a hearing where the student was provided an opportunity to present information, the preponderance of evidence supports the conclusion that the student engaged in conduct inconsistent with the University's academic integrity poHcy,.

Under such circumstances, these errors are less consistent with ordinary inadvertence and more consistent with citation fabrication or Al-generated hallucination, both of which undermine the credibility of the submission.

What the text mentions

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Where this fits

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More from District Court, N.D. Indiana, from Indiana, or from 2026. 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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