Sammie Dwayne McPhaul v. College Hills OPCO
D. Kansas · Jan 6, 2026
What happened in this matter?
The court issued an Order to Show Cause requiring plaintiff's counsel to explain the inclusion of multiple fabricated case law quotations and incorrect citations in his briefing. The court did not definitively attribute the errors to AI but noted the counsel's history of AI use in other jurisdictions and the nature of the hallucinations.
- Why the court cared
- False Quotes: Case Law | Plaintiff quoted a passage attributed to Cory v. Troth that does not appear in that opinion; court identified the quotation as inaccurate. || False Quotes: Case Law | Plaintiff attributed a quotation to Mason v. Gerin Corp. that is not found in the opinion; court flagged it as inaccurate. || False Quotes: Case Law | Plaintiff quoted Fanning v. Sitton Motor Lines as containing language about showing 'some cognitive awareness' that the opinion does not contain; court noted the misquotation. || False Quotes: Case Law | Plaintiff attributed a phrase about 'even the movement of the toes or legs of the decedent' to Cochrane v. Schneider Nat’l that does not exist in that opinion; court flagged it. || False Quotes: Case Law | Plaintiff quoted Lemmons v. Board of County Comm’rs for a relation-back principle quotation that is absent from that decision; court identified the inaccuracy. || Misrepresented: Case Law | Plaintiff cited Pape v. Kansas Power & Light Co. with an incorrect citation number; court noted the citation was not correct.
- Why it matters now
- Five fabricated quotations in one brief triggers show-cause — require line-by-line quote verification against the source opinion.
Why this matter is tracked
In a nursing home negligence and wrongful death action, the court granted the defendants' motion to dismiss for improper claim-splitting, finding the plaintiff attempted to circumvent scheduling orders in a prior pending case by filing a duplicative action. During the briefing, the court identified multiple instances where the plaintiff's counsel included fabricated case law quotations and incorrect citations. The court noted that while it could not confirm the use of AI, the nature of the errors was consistent with AI-generated hallucinations. Consequently, the court ordered the plaintiff's counsel to show cause why he should not be sanctioned under Rule 11(c) for the inclusion of false citations and quotations in his filings.
Five fabricated quotations in one brief triggers show-cause — require line-by-line quote verification against the source opinion.
Record details
What the record establishes about AI use
The court noted counsel's use of AI in other jurisdictions as context for the hallucinations.
Order to Show Cause issued following a granted motion to dismiss for improper claim-splitting.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Plaintiff quoted a passage attributed to Cory v. Troth that does not appear in that opinion; court identified the quotation as inaccurate.
- False Quotes: Case Law | Plaintiff attributed a quotation to Mason v. Gerin Corp. that is not found in the opinion; court flagged it as inaccurate.
- False Quotes: Case Law | Plaintiff quoted Fanning v. Sitton Motor Lines as containing language about showing 'some cognitive awareness' that the opinion does not contain; court noted the misquotation.
- False Quotes: Case Law | Plaintiff attributed a phrase about 'even the movement of the toes or legs of the decedent' to Cochrane v. Schneider Nat’l that does not exist in that opinion; court flagged it.
- False Quotes: Case Law | Plaintiff quoted Lemmons v. Board of County Comm’rs for a relation-back principle quotation that is absent from that decision; court identified the inaccuracy.
- Misrepresented: Case Law | Plaintiff cited Pape v. Kansas Power & Light Co. with an incorrect citation number; court noted the citation was not correct.
Questions this record answers
- What happened in Sammie Dwayne McPhaul v. College Hills OPCO?
- The court issued an Order to Show Cause requiring plaintiff's counsel to explain the inclusion of multiple fabricated case law quotations and incorrect citations in his briefing. The court did not definitively attribute the errors to AI but noted the counsel's history of AI use in other jurisdictions and the nature of the hallucinations.
- Why does Sammie Dwayne McPhaul v. College Hills OPCO matter for legal AI risk?
- Five fabricated quotations in one brief triggers show-cause — require line-by-line quote verification against the source opinion.
- What does the public record establish about Sammie Dwayne McPhaul v. College Hills OPCO?
- 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 Sammie Dwayne McPhaul v. College Hills OPCO 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
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