Arron v. Custer, et al.
S.D. Ohio · May 21, 2026
What happened in this matter?
The Court identified that the pro se plaintiff cited a non-existent 2023 Ohio Supreme Court opinion, 'Arron v. Arron.' The Court explicitly stated it could not locate or confirm the existence of this case, treating the citation as unverified within its Opinion and Order.
- Why the court cared
- The Court noted the citation was unverified because it could not locate or confirm the existence of the purported 2023 Ohio Supreme Court opinion 'Arron v. Arron' cited by the plaintiff.
- Why it matters now
- This case illustrates the risk of pro se litigants using AI-generated hallucinations in federal filings. It highlights the necessity for courts to verify the existence of cited authorities, even when the underlying jurisdictional issues are the primary focus of the litigation.
Why this matter is tracked
In a civil rights action, the pro se plaintiff Shelby Arron submitted an objection to a Magistrate Judge's Report and Recommendation. Within her filing, the plaintiff cited a purported 2023 Ohio Supreme Court opinion titled 'Arron v. Arron' to support her arguments regarding custody and constitutional claims. Upon review, the District Court for the Southern District of Ohio could not locate or confirm the existence of the cited case. The Court explicitly noted this failure to verify the authority in its Opinion and Order. While the Court addressed the underlying jurisdictional issues regarding the domestic relations exception and the Rooker-Feldman doctrine, the citation itself was treated as unverified and effectively disregarded in the Court's analysis of the merits.
This case illustrates the risk of pro se litigants using AI-generated hallucinations in federal filings. It highlights the necessity for courts to verify the existence of cited authorities, even when the underlying jurisdictional issues are the primary focus of the litigation.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
The District Court conducted a de novo review of a Magistrate Judge's Report and Recommendation following the plaintiff's objection, ultimately sustaining in part and overruling in part the recommendation.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited a purported 2023 Ohio Supreme Court opinion 'Arron v. Arron'; the Court could not locate or confirm its existence and treated the citation as unverified.
Questions this record answers
- What happened in Arron v. Custer, et al.?
- The Court identified that the pro se plaintiff cited a non-existent 2023 Ohio Supreme Court opinion, 'Arron v. Arron.' The Court explicitly stated it could not locate or confirm the existence of this case, treating the citation as unverified within its Opinion and Order.
- Why does Arron v. Custer, et al. matter for legal AI risk?
- This case illustrates the risk of pro se litigants using AI-generated hallucinations in federal filings. It highlights the necessity for courts to verify the existence of cited authorities, even when the underlying jurisdictional issues are the primary focus of the litigation.
- What does the public record establish about Arron v. Custer, et al.?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Arron v. Custer, et al. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.