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Sycophantic Fabrication

🚧 Under Construction

This entry is a placeholder. I am currently cataloguing both the fake citations that are shown in real cases and the citation graph of real AI hallucination cases. The canonical write-up is still in progress and is currently incomplete, with stub articles generated from the data in the Interactive Map of AI Hallucination Sanctions Cases. Please don't treat it as final or authoritative yet.

Definition​

Why it matters​

Worked examples​

III. How the Fake Cases Were Generated

Mr. Ayala apparently drafted the Motions in Limine and uploaded the brief onto "MX2.law" to add case law. [ECF No. 168, at 2, ¶ 11]; [ECF No. 167-4, at 2, ¶ 3]. This website appears to be an in-house database launched by Mr. Ayala and Mr. Morgan's firm, Morgan & Morgan. [ECF No. 167-4, at 2, ¶ 3]. When Mr. Ayala uploaded the brief, he made the following inquiries:

  • "add to this Motion in Limine Federal Case law from Wyoming setting forth requirements for motions in limine"
  • "add more case law regarding motions in limine"
  • "Add a paragraph to this motion in limine that evidence or commentary regarding an improperly discarded cigarette starting the fire must be precluded because there is no actual evidence of this, and that amounts to an impermissible stacking of inferences and pure speculation. Include case law from federal court in Wyoming to support exclusion of this type of evidence."
  • Similar requests to add more case law.
  1. Wyoming v. U.S. Department of Energy, 2006 WL 3801910 (D. Wyo. 2006);
  2. Holland v. Keller, 2018 WL 2446162 (D. Wyo. 2018);
  3. United States v. Hargrove, 2019 WL 2516279 (D. Wyo. 2019);
  4. Meyer v. City of Cheyenne, 2017 WL 3461055 (D. Wyo. 2017);
  5. U.S. v. Caraway, 534 F.3d 1290 (10th Cir. 2008);
  6. Benson v. State of Wyoming, 2010 WL 4683851 (D. Wyo. 2010);
  7. Smith v. United States, 2011 WL 2160468 (D. Wyo. 2011);
  8. Woods v. BNSF Railway Co., 2016 WL 165971 (D. Wyo. 2016); and
  9. Fitzgerald v. City of New York, 2018 WL 3037217 (S.D.N.Y. 2018).

See [ECF No. 141]. The problem with these cases is that none exist, except United States v. Caraway, 534 F.3d 1290 (10th Cir. 2008).

— Wadsworth v. Walmart, Inc., 348 F.R.D. 489 (D. Wyo. 2025)

Cases with examples of this failure mode​

  • Wadsworth v. Walmart (D. Wyo., 2025) — 8 instances
    • Wyoming v. U.S. Dep't of Energy, 2006 WL 3801910 (D. Wyo. 2006)
    • Holland v. Keller, 2018 WL 2446162 (D. Wyo. 2018)
    • United States v. Hargrove, 2019 WL 2516279 (D. Wyo. 2019)
    • Meyer v. City of Cheyenne, 2017 WL 3461055 (D. Wyo. 2017)
    • Benson v. State of Wyoming, 2010 WL 4683851 (D. Wyo. 2010)
    • Smith v. United States, 2011 WL 2160468 (D. Wyo. 2011)
    • Woods v. BNSF Railway Co., 2016 WL 165971 (D. Wyo. 2016)
    • Fitzgerald v. City of New York, 2018 WL 3037217 (S.D.N.Y. 2018)

See also​