Donnie Yarn and Deshawn Murphy v. Trader Joe's
D. Oregon · Dec 5, 2025
- Jurisdiction
- federal
- Court
- D. Oregon
- Record ID
- donnie-yarn-and-deshawn-murphy-v-trader-joes-2025-12-05
- Observed outcome
- The court granted the motion to dismiss with leave to amend and issued an order to show cause regarding sanctions for the fabricated citation.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in D. Oregon, with the listed outcome: Order to Show Cause.
Failure modes and consequences
- Pro Se
- Fake Citations
- Contract
- Trial
- Ordered To Show Cause
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 citation may have been created by a generative AI tool.
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.
- Escalate and correct a suspect filing promptly, with a documented response.