So in Zelma v. Wonder Group, Inc. 2025 WL 2976546 (D. N.J. Oct. 22, 2025) the Plaintiff appears to have used AI to generate a brief opposing Plaintiff’s motion to dismiss. (Seems like a category 2 situation since Plaintiff isn’t a lawyer.) Here is what the Court said on the subject (this is long but good): Plaintiff included fabricated quotations from real cases, and at other points, cited to cases that, to the best of the Court’s knowledge, do not exist. See id.