District Court, N.D. Georgia, 6 November 2025 to 4 December 2025. What the court wrote about citations that did not exist, in its own words, from 3 documents on file.
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 14, 4 December 2025 · source · PDF · 10 pages
Docket text. ORDER AND NON-FINAL REPORT AND RECOMMENDATION. The Court RECOMMENDS the imposition of sanctions against Mr. Patterson as set forth in this order for negligently submitting inaccurate citations to the Court, and ORDERS McGuire Woods, LLP to submit a supplemental statement by December 31, 2025. Signed by Magistrate Judge Justin S. Anand on 12/4/2025. (ane) (Entered: 12/05/2025)
As the Court explained in its Order and Report and Recommendation [8] on the Motion to Dismiss, Plaintiff’s Complaint clearly fails to state a claim. There was little need or 3 incentive to fabricate citations to the Court to demonstrate such plain deficiencies, and the Court is assured that Mr. Patterson did not intend to do so.
Patterson’s denials in those regards. The cases miscited in the Memorandum of Law were not “hallucinated” and, as noted above, mostly contained language similar in substance to Defendant’s citations. While these errors could have been generated by AI, they are also consistent with Mr.
As other courts have explained, even where lawyers or unrepresented parties: accept responsibility and apologize profusely, much damage is done. The opposing party expends resources identifying and exposing the fabrication; the court spends time reviewing materials, holding hearings, deliberating about sanctions, and explaining its ruling; the substance of the case is delayed; and public confidence about the trustworthiness of legal proceedings may be diminished. Johnson v.
Docket entry 12, 25 November 2025 · source · PDF · 24 pages
Docket text. RESPONSE re 10 Order to Show Cause filed by Bank of America, N.A. (Attachments: # 1 Exhibit A)(Patterson, Danny) Modified docket text on 11/26/2025 (ane). (Entered: 11/25/2025)
Counsel has explained both in this response and his sworn d eclaration how and why these mistakes occurred to the best of his knowledge and recollection . This was not a situation of knowingly citing or quoting non-existing cases or otherwise fabricating legal principles. Through the Court’s diligence, fortunately these errors were identified and were not material to the Court’s Order and Non- Final Report and Recommendation.
Docket entry 10, 6 November 2025 · source · PDF · 10 pages
Docket text. ORDER: Counsel for Defendant is ORDERED TO SHOW CAUSE in writing, within 21 Days of the date of this Order, why the citations identified above were in fact accurate. Otherwise, counsel must explain the reasons for any inaccuracies, what steps will be implemented going further to prevent recurrence of such problems in this and other cases, and why sanctions should not be imposed as a remedial and/or deterrent measure. In doing so, among any other things counsel may wish to explain, counsel must specifically state, via sworn statement, whether ChatGPT or other A.I.- assisted tools, including those operated by major legal research databases, were used to prepare submissions and, if so, what steps were undertaken to ensure that any such submissions complied with Rule 11 and other ethical and professional obligations. See Fed. R. Civ. P. 11. Signed by Magistrate Judge Justin S. Anand on 11/6/2025. (ane) (Entered: 11/06/2025)
Rather, by this separate Order, the Court identifies several concerns with the accuracy of citations in Defendant’s Memorandum of Law [2-1] (“Defendant’s Brief”). Upon careful review of Defendant’s specific case citations, several appear to be inaccurate, include incorrect docket and/or reporter numbers, 2 and/or quote sentences that do not exist in the opinion. These apparently inaccurate citations were not material to the Court’s Order and Non- Final Report and Recommendation, as the Court independently determined based on well-established legal principles that the Complaint contained obvious deficiencies requiring at least repleading.
[2-1] at 11– 12. Again, this exact quote does not exist. The closest that the undersigned can locate to this language is the following: “ Simply put, when payment is made upon condition, e.g., the condition that, if accepted, it will fulfill the debtor’ s obligation to the creditor, ‘the acceptance of the payment carries with it the acceptance of the condition.’” Neal H.
What the text mentions
Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.
Tools namedChatGPT, CoCounsel
Mentionsdismissal
Mentionsa self-represented party
MentionsRule 11
Mentionssanctions
Mentionsan order to show cause
Dollar figures near "sanction", "fine", "pay" or "fees"$1,500
Where this fits
This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.