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Massachusetts · federal district court · 2026

Rosario Aguilar v. The Crawford Group, Inc.

District Court, D. Massachusetts, 25 September 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · D. Mass.

  1. Court. District Court, D. MassachusettsCOURT
  2. Level. federal district courtLEVEL
  3. Date. 25 September 2026DATED
  4. Docket. No. 1:25-cv-12395DOCKET
  5. Judge. Angel KelleyJUDGE
  6. Documents. one document, 8 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 155, 25 September 2026 · source · PDF · 19 pages

Docket text. District Judge Angel Kelley: ORDER entered. MEMORANDUM AND ORDER. For the foregoing reasons, Enterprise Defendants' Motion for Sanctions Dkt. 65 is GRANTED and the Court imposes sanctions on its own initiative pursuant to Federal Rule of Civil Procedure 11. SO ORDERED. (CEH)

With its great many promises, 2 AI also brings perils. As old institutions work to catch up with new technologies, the legal news outlets regularly report another brief or opinion that was published with fictitious citations or facts. This is another one of those cases.

This is another one of those cases. Defendants the Crawford Group, Inc., ELCO Administrative Services Company, EAN Trust, and EAN Holdings, LLC (collectively, “the Enterprise Defendants”) have filed a Motion for Sanctions based upon fictitious and misleading citations in Plaintiff’s Opposition to the Enterprise Defendants’ Motion to Strike the Second Amended Complaint. The Enterprise Defendants also alerted the Court to errors in Plaintiff’s Opposition to their Motion to Dismiss, and the Court independently identified errors in two of Plaintiff’s filings, including Plaintiff’s Opposition to Defendant Travelers Property Casualty Company of America’s (“Travelers”) Motion to Dismiss.

[Dkt. 51 at 2, 13-14]. • Attributing a quotation to a case with a fictitious Westlaw citation. [Id. at 12 (citing Federal Deposit Insurance Corp. v.

Computervision Corp., 90 F.3d 617, 623 (1st Cir. 1996), for a non-existent quote. [Dkt.

2 When enumerating the errors in Plaintiff’s Oppositions, the Court has omitted reference to any errors that are conceivably scriveners’ errors. 3 While describing the errors in Plaintiff’s papers, the Court has omitted incorrect citations to avoid repeating fictitious citations. 5 62].

135 at 13-14]. On December 5, 2026, the Enterprise Defendants filed the present Motion for Sanctions, alleging that the Strike Opposition contained inaccurate and fictitious authority, resulting from Lindemann’s use of AI. [Dkts.

135 at 5]. 6 provided citation is fictitious.5 [Dkt. 97 at 8-9; see also id. at 24 (same for Hertz Corp. v.

103]. After confirming the identified errors in the Enterprise Opposition and identifying errors in Plaintiff’s Opposition to Travelers’ Motion to Dismiss (“the Travelers Opposition”), the Court issued an Order to Show Cause, asking Plaintiff to show cause why sanctions should not be imposed for the inaccurate and fictitious citations in the Enterprise, Travelers, and Strike Oppositions. [Dkt.

What the text mentions

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Where this fits

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More from District Court, D. Massachusetts, from Massachusetts, 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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