Dennis Thornton v. Flathead County, et al.
D. Montana · Jan 23, 2026
- Jurisdiction
- federal
- Court
- D. Montana
- Record ID
- dennis-thornton-v-flathead-county-et-al-2026-01-23
- Observed outcome
- The Court granted in part and denied in part the motion to dismiss and ordered the plaintiff to file hard-copy source documents for every cited authority by February 6, 2026.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court ordered the pro se plaintiff to file conventional hard-copy source documents for every legal citation in his filings after identifying that he used AI to generate fabricated case law, nonexistent citations, and misattributed quotes in his briefing.
Fabricated: Case Law | Defendants identified 'Younger v. City of Seattle, 70 F.4th 1099, 1107 (9th Cir. 2023)' as a nonexistent Ninth Circuit citation; 70 F.4th 1099 corresponds to an unrelated Eighth Circuit case and no Ninth Circuit case with that title appears to exist. || Fabricated: Case Law | Thornton cited 'United States v. Craner, 652 F. App'x 560, 562 (9th Cir. 2016)'; the Court noted this citation appears incorrect/nonexistent as cited and may reflect a miscitation (perhaps meant 652 F.2d 23 (9th Cir. 1981)), which does not support Thornton's asserted proposition. || Fabricated: Case Law | Thornton cited 'United States v. Smith, 629 F.3d 1082, 1084 (9th Cir. 2011)'; the Court identified this citation as nonexistent in the form cited and treated it as a fabricated authority in Thornton's briefing. || False Quotes: Case Law | Thornton quoted language attributed to Odd v. Malone, 538 F.3d 202 (3d Cir. 2008); the Court found the quoted language is not in that opinion and the opinion was not authored by the judge Thornton referenced (misquoted/misattributed).
This record documents a Pro Se Litigant filing issue in D. Montana, with the listed outcome: Order to file conventional hard-copy source documents for every cited authority.
Failure modes and consequences
- Fabricated_case_law
- Hallucinated_citations
- Misattributed_quotes
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Explicitly Recorded
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order on Defendants' motion to dismiss, with a specific directive regarding the plaintiff's use of fabricated legal authority.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The Court explicitly stated the plaintiff used AI to generate false citations.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.