US | United States District Court for the District of Oregon
Docket: 3:24-cv-298-SI • first instance
2025-10-27
Green Building Initiative, Inc. v. Peacock — opinion and order denying interim attorney’s fees and order to show cause
ChatGPT (suspected) no human verificationfake case citationmis-citation / wrong sourcesuspected generative ai use
I. Executive Summary
The court identified that a key authority cited to support an interim fee request was “totally fake” and described as a hallucinated case, with attributes consistent with generative AI output.
The court explained that reliance on fake precedent can violate Rule 11’s reasonable-inquiry obligations.
It denied the interim fee motion without prejudice and ordered the plaintiff to show cause why sanctions should not be imposed for citing hallucinated cases.
II. Conduct Analysis
A party seeking interim fees cited a non-existent case and other mis-citations that the court characterized as hallmarks of generative AI, suggesting the filing relied on unverified AI-generated authorities.
III. Legal Foundations
Fed. R. Civ. P. 11(b)
Fed. R. Civ. P. 11(c)(1)
IV. Key Facts
1) The fee motion cited Stell v. Cardenas with a Westlaw citation that the court found did not exist and described as a hallucinated case.
2) The court found additional citation problems, including citations pointing to unrelated or different cases.
3) The court ordered the party to show cause why Rule 11 sanctions should not issue for citing hallucinated authority and required the party to propose appropriate sanctions.
V. Consequences & Sanction
1) The interim attorney-fee motion was denied without prejudice.
2) The party was ordered to show cause by a specified deadline why sanctions should not be imposed for citing hallucinated authority.