Alzado-Lotz v. Bock
D. Colorado · Jan 16, 2026
What happened in this matter?
The court identified that the defendant submitted a motion to dismiss containing a non-existent case citation and a fabricated quotation. The magistrate judge explicitly noted these errors in the order, identifying the specific non-existent case and the likely source of the misattributed quote, though no formal monetary sanction was imposed.
- Why the court cared
- Fabricated: Case Law | Defendant cited a non-existent Tenth Circuit decision 'Hinzo v. State of N.M., 79 F.4th 1164, 1175 (10th Cir. 2023)'; the court determined that citation is non-existent and does not support the argument. || False Quotes: Case Law | Defendant quoted language purportedly from Nikwei v. Ross Sch. of Aviation, Inc. (822 F.2d 939) that the court found does not appear in Nikwei; the court noted the wording likely originates from Aetna Business Credit, Inc., 635 F.2d 434, 435 (5th Cir. 1981).
- Why it matters now
- Fabricated circuit-court cites with invented pinpoint quotes are the fastest path to an on-the-record finding — run every quote through a text search before filing.
Why this matter is tracked
In a contract and securities litigation, the defendant submitted a motion to dismiss containing two instances of AI-generated hallucinations. The court identified that the defendant cited a non-existent Tenth Circuit decision, 'Hinzo v. State of N.M., 79 F.4th 1164, 1175 (10th Cir. 2023),' and provided a fabricated quotation purportedly from 'Nikwei v. Ross Sch. of Aviation, Inc., 822 F.2d 939.' The court noted that the cited case does not exist and the quoted language likely originated from a Fifth Circuit decision. While the court addressed these errors in its order, it did not impose a formal monetary sanction, focusing instead on the substantive merits of the motion to dismiss.
Fabricated circuit-court cites with invented pinpoint quotes are the fastest path to an on-the-record finding — run every quote through a text search before filing.
Record details
What the record establishes about AI use
The source does not name a tool, implying AI usage through the nature of the hallucinations.
Order and Recommendation of United States Magistrate Judge on Defendant's Motion to Dismiss and Motion for Judicial Notice.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Defendant cited a non-existent Tenth Circuit decision 'Hinzo v. State of N.M., 79 F.4th 1164, 1175 (10th Cir. 2023)'; the court determined that citation is non-existent and does not support the argument.
- False Quotes: Case Law | Defendant quoted language purportedly from Nikwei v. Ross Sch. of Aviation, Inc. (822 F.2d 939) that the court found does not appear in Nikwei; the court noted the wording likely originates from Aetna Business Credit, Inc., 635 F.2d 434, 435 (5th Cir. 1981).
Questions this record answers
- What happened in Alzado-Lotz v. Bock?
- The court identified that the defendant submitted a motion to dismiss containing a non-existent case citation and a fabricated quotation. The magistrate judge explicitly noted these errors in the order, identifying the specific non-existent case and the likely source of the misattributed quote, though no formal monetary sanction was imposed.
- Why does Alzado-Lotz v. Bock matter for legal AI risk?
- Fabricated circuit-court cites with invented pinpoint quotes are the fastest path to an on-the-record finding — run every quote through a text search before filing.
- What does the public record establish about Alzado-Lotz v. Bock?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Alzado-Lotz v. Bock summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.