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HomeCasesEddie Lawrence Quitugua v. Donna P. Quitugua, et al.
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Corpus matter record

Eddie Lawrence Quitugua v. Donna P. Quitugua, et al.

D. Guam · Dec 3, 2025

GU / federalEditorial impact: lowpro sefake citationsfabricated quotescivil rightsWarning
Direct answer

What happened in this matter?

The court issued a formal warning to the pro se plaintiff regarding the inclusion of fabricated case law and inaccurate quotations in his filings. While the court identified these as violations of Federal Rule of Civil Procedure 11, it opted to admonish the plaintiff rather than impose monetary or other formal sanctions.

Why the court cared
Fabricated: Case Law | Court could not locate the cited decision and suspects this cited authority may be an AI-fabricated case; flagged as potentially fabricated citation. || False Quotes: Case Law | Plaintiff attributed a quotation to Henrichs that does not appear in the opinion; court found the quoted language absent from the decision. || False Quotes: Case Law | Plaintiff claimed Kougasian contained a specific phrasing ('gravamen') that the opinion does not contain; court identified the quotation as inaccurate. || False Quotes: Case Law | Plaintiff quoted Leadsinger for a proposition about continuing violations using wording that does not appear in the opinion; court noted the quoted terms are absent.
Why it matters now
This record documents a Pro Se Litigant filing issue in D. Guam, with the listed outcome: Warning.

Why this matter is tracked

In a civil rights action, the District Court of Guam dismissed the plaintiff's amended complaint with prejudice. During the screening process, the court identified that the pro se plaintiff included multiple misquotations of Ninth Circuit case law (Henrichs, Kougasian, and Leadsinger) and cited a case (Mangiaracina) that the court could not locate, suspecting it to be an AI-fabricated citation. While the court noted that pro se litigants are bound by Federal Rule of Civil Procedure 11 to present legal contentions warranted by existing law, it declined to impose formal sanctions at this time. Instead, the court issued a formal warning, admonishing the plaintiff to ensure the accuracy of all future filings and to verify that all cited authorities exist.

Operational lesson

This record documents a Pro Se Litigant filing issue in D. Guam, with the listed outcome: Warning.

Record details

Explore GUOpen its source-linked jurisdiction page and related matters.
CourtD. Guam
Jurisdictionfederal
Circuit9th Circuit
DateDec 3, 2025
UN
AI toolunspecified
Party typePro Se Litigant
OutcomeThe court dismissed the complaint with prejudice and issued a formal warning to the plaintiff regarding his duty of candor and accuracy in legal filings.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

implied

The court suspected AI fabrication but did not name a specific tool.

Procedural posture

The court dismissed the plaintiff's amended complaint with prejudice following a mandatory screening under 28 U.S.C. § 1915(e).

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

4 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Court could not locate the cited decision and suspects this cited authority may be an AI-fabricated case; flagged as potentially fabricated citation.
  2. False Quotes: Case Law | Plaintiff attributed a quotation to Henrichs that does not appear in the opinion; court found the quoted language absent from the decision.
  3. False Quotes: Case Law | Plaintiff claimed Kougasian contained a specific phrasing ('gravamen') that the opinion does not contain; court identified the quotation as inaccurate.
  4. False Quotes: Case Law | Plaintiff quoted Leadsinger for a proposition about continuing violations using wording that does not appear in the opinion; court noted the quoted terms are absent.

Questions this record answers

What happened in Eddie Lawrence Quitugua v. Donna P. Quitugua, et al.?
The court issued a formal warning to the pro se plaintiff regarding the inclusion of fabricated case law and inaccurate quotations in his filings. While the court identified these as violations of Federal Rule of Civil Procedure 11, it opted to admonish the plaintiff rather than impose monetary or other formal sanctions.
Why does Eddie Lawrence Quitugua v. Donna P. Quitugua, et al. matter for legal AI risk?
This record documents a Pro Se Litigant filing issue in D. Guam, with the listed outcome: Warning.
What does the public record establish about Eddie Lawrence Quitugua v. Donna P. Quitugua, et al.?
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 Eddie Lawrence Quitugua v. Donna P. Quitugua, et al. 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.

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