Eddie Lawrence Quitugua v. Donna P. Quitugua, et al.
D. Guam · Dec 3, 2025
- Jurisdiction
- federal
- Court
- D. Guam
- Record ID
- eddie-lawrence-quitugua-v-donna-p-quitugua-et-al-2025-12-03
- Observed outcome
- The 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 monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in D. Guam, with the listed outcome: Warning.
Failure modes and consequences
- Hallucinated_case_law
- Fabricated_quotations
- Pro Se
- Fake Citations
- Fabricated Quotes
- Civil Rights
- AI attribution
- Implied
- Recorded tool
- unspecified
- Known monetary consequence
- Not recorded
- Procedural posture
- The court dismissed the plaintiff's amended complaint with prejudice following a mandatory screening under 28 U.S.C. § 1915(e).
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 suspected AI fabrication but did not name a specific 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.
- Confirm that every authority actually supports the proposition for which it is offered.