Court orders litigant to explain inaccurate court citations

The show-cause order addressed misleading statements and inaccurate citations in Miller’s filings[2]. The court invoked Federal Rule of Civil Procedure 11(c) and relied on its inherent authority to regulate its docket, promote judicial efficiency and deter frivolous filings[2]. Miller was representing himself in a dispute with the Colorado Department of Revenue[1][2]. The AI connection should be described carefully: a case database identifies Miller as the party using AI, but marks the AI tool entry “Implied”[2]. The evidence does not identify a specific AI product[2].

The court could not locate the Hurley case Miller cited, and the Westlaw citation he supplied led to Cohen v. Federal Express Corp.[2]. The court also found that available Hurley orders did not support Miller’s quoted claim about whether the Servicemembers Civil Relief Act covered interest and similar charges[2]. Another citation, Brewster, was a Ninth Circuit case, but the court determined it did not address the SCRA provision or the forgiveness of excessive interest Miller attributed to it[2]. These findings identify problems with the cited support; they do not establish which tool, if any, produced them.

The court found no public-docket support for an assertion Miller made, and none of the public docket entries reflected the amount of any settlement[2]. The database also reports that Batie v. Subway was dismissed for lack of subject-matter jurisdiction against the corporate defendant[2]. Miller, a U.S. Army member, brought claims concerning state tax-collection actions involving a restaurant he owned; his first four claims alleged violations of the SCRA[3]. The Missouri Court of Appeals had affirmed denial of a motion for continuance[2].

Judge Wang overruled Miller’s objections and adopted the magistrate judge’s recommendation to grant the Colorado Department of Revenue’s motion to dismiss the amended complaint[3]. Separately, the case database reports an order to show cause and says that no professional sanction was imposed[2]. For legal professionals reviewing AI-assisted work, the practical lesson is to check each cited authority and quoted proposition against the underlying source before filing.