Pro se litigant cited AI hallucinated cases but court found no harm, no foul

A bankruptcy case took a turn during a hearing when the court asked the pro se debtor how he had found the cases he cited in his legal filings. Debtor admitted that he had used artificial intelligence to generate legal arguments and case citations. When the court reviewed those citations, it found they were either misrepresented, irrelevant, or entirely fictitious. One citation led to a case that had been vacated. Another did not say anything close to what debtor claimed. And one did not exist at all.

The court made clear that parties, whether attorneys or pro se litigants, must make a reasonable inquiry before submitting legal contentions to the court. That means personally verifying that cited case law actually supports the argument being made. Using AI without checking the accuracy of the output is not enough.

Even so, the court declined to impose sanctions under the relevant rule. It noted that the case was already being dismissed for independent reasons under bankruptcy law and saw no need to pile on. Essentially, the judge applied a “no harm, no foul” approach. But the warning was clear: AI-generated case law that has not been verified cannot be trusted and will not be tolerated.

In re Perkins, No. 24-32731-thp13, 2025 WL 1871049 (Bankr. D. Or. July 7, 2025)