Donte McClellon v. E. Rickard, Warden of FCI Otisville, et al.
S.D. New York · Mar 11, 2026
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- donte-mcclellon-v-e-rickard-warden-of-fci-otisville-et-al-2026-03-11
- Observed outcome
- The court denied the habeas petition and related motions and issued a formal warning to the petitioner regarding the submission of AI-hallucinated legal authorities.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to the pro se petitioner after he submitted AI-hallucinated case law in his filings. The District Judge declined to impose a more severe sanction requiring the petitioner to disclose the court's order in other active cases, but explicitly cautioned the petitioner that future use of AI resulting in hallucinations could lead to sanctions.
The court reasoned that submitting non-existent judicial opinions with fake quotes constitutes subjective bad faith, wastes judicial resources, and undermines the integrity of the process. The judge noted that while pro se litigants must comply with procedural rules, the court exercised discretion to issue a warning rather than the Magistrate's recommended sanction of mandatory disclosure in other cases.
This case illustrates judicial responses to pro se litigants using AI to generate legal arguments. It highlights the court's preference for warnings over punitive sanctions for initial AI-related misconduct, while reinforcing the mandatory duty to verify all citations.
Failure modes and consequences
- Hallucinated_case_law
- Fabricated_quotations
- Lack_of_verification
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Implied
- Recorded tool
- Generative artificial intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Opinion and Order by the District Court adopting a Magistrate Judge's Report and Recommendation in part, denying a habeas petition and related motions, and issuing a warning regarding AI-generated hallucinations.
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 attributed the citation errors to the use of generative AI tools.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or 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.