Avalon Holdings Corp. v. Guy Gentile
S.D. New York · Jan 22, 2026
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- avalon-holdings-corp-v-guy-gentile-2026-01-22
- Observed outcome
- The court issued a formal warning to the defendant regarding future compliance with Rule 11 and the accuracy of legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to the pro se defendant regarding his obligations under Rule 11 of the Federal Rules of Civil Procedure after he submitted a fictitious case citation and quotation, which the court attributed to the potential use of generative artificial intelligence.
Fabricated: Case Law | Gentile cited a non-existent Second Circuit opinion and attributed a quotation to it; the court could not locate any such opinion or the quoted language and concluded the citation was fictitious, possibly produced by generative AI.
This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Contract
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- generative artificial intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court was reviewing objections filed by the defendant to a Magistrate Judge's Report and Recommendation concerning a motion to clarify a judgment and a motion to reinstate a civil arrest warrant.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court suggested the fictitious citation was likely the result of using generative AI.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.