Beedemariam Kassaw v. Wal-Mart Corporation
W.D. New York · Mar 30, 2026
- Jurisdiction
- federal
- Court
- W.D. New York
- Record ID
- beedemariam-kassaw-v-wal-mart-corporation-2026-03-30
- Observed outcome
- The court granted summary judgment for the defendant and ordered the Clerk of Court to strike Dkt. 79 from the docket due to the inclusion of hallucinated case law.
- Known monetary consequence
- $0
Why this matter warrants attention
The court struck the plaintiff's memorandum of law (Dkt. 79) from the docket after finding it contained fabricated case citations, which the court attributed to the use of artificial intelligence. The court denied the defendant's request for monetary sanctions, opting instead to issue a formal warning to the pro se litigant regarding future compliance with Rule 11.
The court determined that the plaintiff's memorandum of law (Dkt. 79) contained fabricated case citations. Although the court declined to impose monetary sanctions under Rule 11 due to the plaintiff's pro se status and lack of prior warnings, it exercised its discretion to strike the offending document from the docket to maintain the integrity of the record.
Courts will strike entire briefs sua sponte when AI hallucinations are apparent — no motion required.
Failure modes and consequences
- Pro Se
- Fake Citations
- Employment
- Trial
- Struck Filing
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- $0
- Procedural posture
- The court issued a Decision and Order granting the defendant's motion for summary judgment and denying the defendant's motion for sanctions without prejudice, while ordering the specific striking of a filing containing hallucinated cases.
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 noted the plaintiff appeared to use artificial intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.