Donnie Yarn and Deshawn Murphy v. Trader Joe's
D. Oregon · Dec 5, 2025
What happened in this matter?
The court issued an order to show cause regarding sanctions after the pro se plaintiffs cited a non-existent case, 'Miskew v. Hess,' which the court identified as a likely product of generative AI. The underlying motion to dismiss was granted with leave to amend.
- Why the court cared
- Fabricated: Case Law | Plaintiffs cited 'Miskew v. Hess, 211 Or. App. 499 (2007),' which the court found does not exist and noted may have been created by a generative AI tool; the citation prompted an order to show cause re sanctions.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in D. Oregon, with the listed outcome: Order to Show Cause.
Why this matter is tracked
In a civil action against Trader Joe's, self-represented plaintiffs Donnie Yarn and Deshawn Murphy filed a response to a motion to dismiss that included a citation to 'Miskew v. Hess, 211 Or. App. 499 (2007).' The U.S. Magistrate Judge determined that this case does not exist and noted it may have been generated by an AI tool. Consequently, the court issued an order to show cause regarding potential sanctions for the inclusion of the fabricated citation. The court also granted the defendant's motion to dismiss the plaintiffs' amended complaint for failure to state a claim, while granting leave to amend. The matter remains pending regarding the show cause order.
This record documents a Pro Se Litigant filing issue in D. Oregon, with the listed outcome: Order to Show Cause.
Record details
What the record establishes about AI use
The court noted the citation may have been created by a generative AI tool.
The court granted the defendant's motion to dismiss the amended complaint with leave to amend and issued a separate order to show cause regarding sanctions for the use of a fabricated citation.
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 | Plaintiffs cited 'Miskew v. Hess, 211 Or. App. 499 (2007),' which the court found does not exist and noted may have been created by a generative AI tool; the citation prompted an order to show cause re sanctions.
Questions this record answers
- What happened in Donnie Yarn and Deshawn Murphy v. Trader Joe's?
- The court issued an order to show cause regarding sanctions after the pro se plaintiffs cited a non-existent case, 'Miskew v. Hess,' which the court identified as a likely product of generative AI. The underlying motion to dismiss was granted with leave to amend.
- Why does Donnie Yarn and Deshawn Murphy v. Trader Joe's matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in D. Oregon, with the listed outcome: Order to Show Cause.
- What does the public record establish about Donnie Yarn and Deshawn Murphy v. Trader Joe's?
- 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 Donnie Yarn and Deshawn Murphy v. Trader Joe's 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.