Petersen v. Iran Air does not exist — a fabricated AI citation

There is no decision reported at 905 F. Supp. 2d 121, and no case styled “Petersen v. Iran Air” in the D.D.C. reporter. This is the third of six wholly invented airline-injury opinions that ChatGPT generated when attorney Steven Schwartz asked it for case law supporting his client's position in Mata v. Avianca, Inc.

Iran Air litigation is a real and reasonably well-documented category — the airline has been a defendant in genuine U.S. federal suits stemming from historical incidents — which is precisely what made a fabricated case bearing its name plausible on a skim. The volume and page number simply do not correspond to any actual F. Supp. 2d entry; had anyone opened Westlaw or PACER before filing, the fabrication would have been caught in under a minute.

Opposing counsel for Avianca could not locate any of the six citations, including this one, and flagged the discrepancy to the court — the discovery that ultimately led to the May 2023 show-cause order and the $5,000 sanction against Schwartz, Peter LoDuca, and their firm. Petersen is a useful reminder that a single fabricated citation embedded among real, verifiable ones is often harder to catch on a read-through than an obviously implausible one — nothing about its formatting stands out until someone actually tries to pull the reporter volume.