Perry v. Exeter Finance LLC
U.S. District Court, District of Arizona · D. Ariz. · Arizona bar guidance
Conduct
Pro se plaintiff cited two fabricated cases and one fake quotation attributed to a real case in opposition brief.
Consequence
Warning issued. No formal sanction. Court attributed citations to suspected AI use and warned future fictitious cases would trigger Rule 11.
Lesson
AI hallucinations include not just invented cases but also real cases paired with fabricated quotations. Both require verification.
Verified May 14, 2026
- Citation
- Perry v. Exeter Fin. LLC, No. 2:25-cv-01552-DWL (D. Ariz. Feb. 26, 2026) (Lanza, J.)
- Decided
- February 26, 2026
Summary
Pro se plaintiff Carissa Perry filed an opposition brief that District Judge Dominic W. Lanza found contained fabricated case citations and apparently false quotations attributed to real cases. The court identified specific defects: a citation to "Anderson v. Dean Witter Reynolds, Inc., 306 F.3d 726 (9th Cir. 2002)" that does not return an identified case, a citation to "Chavez v. Bank of Am., 2014 WL 2159382 (D. Ariz. 2014)" that does not return an identified case, and a fake quotation attributed to Matterhorn, Inc. v. NCR Corp., 763 F.2d 866 (7th Cir. 1985). The court observed that "It appears the incorrect citations may be the result of [Plaintiff] using artificial intelligence to draft [her] filings."
- AI tool:
- Generative AI suspected, specific tool not named in the order
What sanction did the court impose?
No formal sanction. Warning issued. The court stated that "in the future, filing documents with fictitious cases will subject [Plaintiff] to sanctions under Rule 11," using the Rule 11 formulation that reappears in Judge Lanza's later FTC v. Noland order.
Why does Perry v. Exeter Finance LLC matter for law firms using AI?
Perry v. Exeter Finance LLC is the earlier of two D. Arizona AI-citation orders Judge Dominic W. Lanza issued in early 2026; FTC v. Noland followed five weeks later on March 31, 2026 and used parallel Rule 11 warning language. What distinguishes Perry is the granularity of the citation defects. The order does not just identify invented cases; it separately documents three distinct failure modes: a Ninth Circuit citation that does not resolve to any identified case, a District of Arizona Westlaw citation that does not resolve, and a quotation attributed to a real Seventh Circuit case (Matterhorn, Inc. v. NCR Corp.) that appears to be fabricated. This third failure mode is particularly important because verification protocols that check only whether a case exists, but not whether the quoted language appears in the case, will miss it. Pattern: Lanza’s chambers attributes the conduct to suspected AI use and issues a Rule 11 warning rather than imposing a formal sanction on a first occurrence; a represented party (or pro se litigant who repeats the conduct after this warning) can expect a different result. Cross-reference: FTC v. Noland (D. Ariz. Mar. 31, 2026); Ghadimi v. Arizona Bank & Trust (D. Ariz. Oct. 15, 2025).
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Train associates to verify both the case citation AND the quoted language against the source; the Matterhorn quotation in this case was attributed to a real Seventh Circuit decision but appears to have been fabricated separately by the AI.
- Note the Lanza chambers Rule 11 warning formulation, used here and again in FTC v. Noland (Mar. 31, 2026) five weeks later, as a precedent reference for what AI-citation conduct triggers in this district.
- When opposing pro se litigants in D. Arizona, document any suspected AI artifacts (citations that do not resolve, quotations not in the cited cases) for the court's screening review under Rule 11.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.