Sammie Dwayne McPhaul v. College Hills OPCO
D. Kansas · Jan 6, 2026
- Jurisdiction
- federal
- Court
- D. Kansas
- Record ID
- sammie-dwayne-mcphaul-v-college-hills-opco-2026-01-06
- Observed outcome
- Motion to dismiss granted; counsel ordered to show cause regarding Rule 11(c) sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Five fabricated quotations in one brief triggers show-cause — require line-by-line quote verification against the source opinion.
Failure modes and consequences
- False Quotes: Case Law
- Misrepresented: Case Law
- Fabricated Quotes
- Misrepresented Authority
- Tort
- Trial
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order to Show Cause issued following a granted motion to dismiss for improper claim-splitting.
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 noted counsel's use of AI in other jurisdictions as context for the hallucinations.
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.
- Retain a matter-level record of source checks and corrections.