But Dr. Holguin's report also contains "hallucinated" citations to academic articles which appear generated by artificial intelligence. [...] The Court agrees with Defendants and finds that Dr. Holguin's multiple hallucinated citations "shatter[] his credibility with this Court." [...] Dr. Holguin's lack of diligence in verifying the sources that he represented were the basis for his opinion, prevent Plaintiff from meeting her burden to show that Dr. Holguin's opinion is "based on sufficient facts or data," is "the product of reliable principles and methods," or "reflects a reliable application of the principles and methods to the facts of the case." [...] The Court GRANTS Defendants' motion for summary judgment. Plaintiff's remaining claims are DISMISSED WITH PREJUDICE.
Every other fabricated-citation case on this page is a lawyer's filing. This one reached the expert witnesses, which is the one document in a case whose whole value is that somebody read the underlying literature and can say so. The plaintiff's lawyer had already been sanctioned here for filing citations she had not verified. She had also used Claude or ChatGPT to generate a formatted citation table for academic articles and given the same table to two of her experts as an appendix, and neither of them caught the errors before signing his report. A third expert, Dr Gabriel Holguin, filed a report carrying fabricated academic citations of its own, in passages the plaintiff later withdrew. On 18 August 2026 the court held that the hallucinated citations shattered his credibility even though they sat only in the withdrawn portions, excluded the opinion, granted summary judgment to the defendants and dismissed the remaining claims with prejudice.
