Cotto v. United States
D. Colorado · Nov 17, 2025
What happened in this matter?
The court denied the plaintiff's motion for reconsideration after determining that the plaintiff relied on a fabricated case citation. The court explicitly noted that the cited 'Ayala v. Holmes, 29 F.4th 1015' does not exist and reaffirmed that pro se status does not exempt litigants from procedural rules or the obligation to cite the record.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited 'Ayala v. Holmes, 29 F.4th 1015' for summary-judgment guidance; the Court found no such decision exists, noted the 29 F.4th pin cite aligns with Barrera Arreguin v. Garland, 29 F.4th 1010, and that an unrelated Ayala v. Holmes, 29 F. App'x 548 (10th Cir. 2002) exists.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Motion for reconsideration denied; court identified the cited case/citation as nonexistent/miscited and rejected reliance on it..
Why this matter is tracked
In a motion for reconsideration, a pro se plaintiff cited a non-existent Tenth Circuit decision, 'Ayala v. Holmes, 29 F.4th 1015,' to argue that the court should not hold pro se litigants to strict procedural standards regarding record citations. The court identified that the cited case does not exist, noting that the volume and page number actually correspond to an unrelated immigration case, 'Barrera Arreguin v. Garland.' The court clarified that while it construes pro se pleadings liberally, it is not required to act as an advocate or parse the record for uncited materials. The court denied the motion for reconsideration, finding no manifest injustice or clear error in its prior grant of summary judgment for the defendant.
This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Motion for reconsideration denied; court identified the cited case/citation as nonexistent/miscited and rejected reliance on it..
Record details
What the record establishes about AI use
The record does not name a tool, but the error is characteristic of AI hallucination.
Order denying plaintiff's motion for reconsideration of a prior summary judgment order.
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 'Ayala v. Holmes, 29 F.4th 1015' for summary-judgment guidance; the Court found no such decision exists, noted the 29 F.4th pin cite aligns with Barrera Arreguin v. Garland, 29 F.4th 1010, and that an unrelated Ayala v. Holmes, 29 F. App'x 548 (10th Cir. 2002) exists.
Questions this record answers
- What happened in Cotto v. United States?
- The court denied the plaintiff's motion for reconsideration after determining that the plaintiff relied on a fabricated case citation. The court explicitly noted that the cited 'Ayala v. Holmes, 29 F.4th 1015' does not exist and reaffirmed that pro se status does not exempt litigants from procedural rules or the obligation to cite the record.
- Why does Cotto v. United States matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Motion for reconsideration denied; court identified the cited case/citation as nonexistent/miscited and rejected reliance on it..
- What does the public record establish about Cotto v. United States?
- 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.
- Which source supports this Cotto v. United States 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.