United States v. Tittsworth does not exist — a fabricated AI citation

“United States v. Tittsworth”, cited to 630 F.3d 1029 in the Tenth Circuit, appears nowhere in that reporter. In Gregory Ashley Moyer v. James V. Murray, et al., the Tenth Circuit found that appellant Moyer had cited this fabricated case not once but across multiple separate motions — a detail the court's order specifically flagged, since repetition across filings suggested the citation was being reused from a single unverified source rather than independently rediscovered each time.

Beyond the fabrication itself, the panel noted a compounding procedural problem: the pattern of citing this nonexistent authority also violated 10th Cir. R. 46.5(B)(2), the circuit's own rule governing citation practice. The order functioned as a formal warning of possible sanctions rather than an immediate penalty — the kind of first-strike outcome this database sees often when a court wants to put a litigant on notice before escalating.

The name “Tittsworth” is distinctive enough that it is unlikely to be confused with a real case by a similarly named party; anyone encountering this exact citation, at this exact volume and page, in Tenth Circuit briefing should treat it as conclusively fabricated absent independent verification directly against F.3d itself. Repeated use of the same fabricated citation across separate filings, as happened here, is itself a signal worth watching for: it suggests a single unverified research artifact — a memo, a chat transcript, a prior brief — being copied forward rather than freshly checked each time it's reused.