David J. Donovan v. Kathryn Thorson
CA New Mexico · Nov 12, 2025
- Jurisdiction
- state
- Court
- CA New Mexico
- Record ID
- david-j-donovan-v-kathryn-thorson-2025-11-12
- Observed outcome
- The court issued a warning regarding citation practices but declined to strike the filing or impose sanctions, ultimately affirming the lower court's judgment.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The New Mexico Court of Appeals issued a warning to a pro se litigant for submitting inaccurate legal citations and fabricated quotations. The court declined to strike the filing or impose further sanctions, opting instead to caution the litigant to ensure future compliance with proper citation standards.
Misrepresented: Case Law | Plaintiff's authorities cited incorrect appellate reporters or otherwise mis-cited case law; the court's review confirmed the citations were inaccurate and complicated appellate review. || False Quotes: Case Law | Plaintiff attributed direct quotations to cited authorities that do not contain those quotations; the court found the quoted language absent from the cited sources.
This record documents a Pro Se Litigant filing issue in CA New Mexico, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fabricated Quotes
- Misrepresented Authority
- Contract
- Appellate
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a district court final judgment following a jury trial, where the court considered a motion to amend and the merits of the appellant's memorandum in opposition.
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 opinion identifies the use of incorrect citations and fabricated quotes, which are characteristic of AI-assisted drafting.
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
- Confirm that every authority actually supports the proposition for which it is offered.