Emmanuel S. Yirenkyi v. Angela Hoover
M.D. Pennsylvania · Feb 2, 2026
What happened in this matter?
The court identified that the pro se petitioner submitted AI-generated legal hallucinations, specifically citing two non-existent Middle District of Pennsylvania cases to support his argument for release. The court formally labeled these citations as AI-generated and noted the petitioner's reliance on generative AI for his filings.
- Why the court cared
- Fabricated: Case Law | Petitioner cited 'Frederick v. Warden, 2019 WL 1318445 (M.D. Pa. Mar. 22, 2019)' to support that 8–10 months detention requires release; court found no such Middle District of Pennsylvania decision and labeled it an AI-generated legal hallucination. || Fabricated: Case Law | Petitioner cited 'Rodriquez v. Lowe, 2018 WL 683974 (M.D. Pa. Feb. 2, 2018)'; the court found the provided Westlaw citation redirected to an unrelated Quebec family-court decision and concluded no such M.D. Pa. case exists, calling it a legal hallucination.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in M.D. Pennsylvania, with the listed outcome: no adjudicated outcome recorded.
Why this matter is tracked
In a habeas corpus petition challenging immigration detention, the court granted the petitioner's request for a bond hearing. During the proceedings, the court identified that the pro se petitioner's filings were drafted with the assistance of generative artificial intelligence. The court explicitly noted two instances of AI-generated legal hallucinations: the citation of 'Frederick v. Warden, 2019 WL 1318445 (M.D. Pa. Mar. 22, 2019)' and 'Rodriquez v. Lowe, 2018 WL 683974 (M.D. Pa. Feb. 2, 2018).' The court found that the former case does not exist and the latter citation redirected to an unrelated Quebec family-court decision. The court criticized the reliance on AI for creating non-existent legal authority.
This record documents a Pro Se Litigant filing issue in M.D. Pennsylvania, with the listed outcome: no adjudicated outcome recorded.
Record details
What the record establishes about AI use
The court identified the use of generative artificial intelligence.
Habeas corpus petition under 28 U.S.C. § 2241 seeking release from immigration detention or a bond hearing.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Petitioner cited 'Frederick v. Warden, 2019 WL 1318445 (M.D. Pa. Mar. 22, 2019)' to support that 8–10 months detention requires release; court found no such Middle District of Pennsylvania decision and labeled it an AI-generated legal hallucination.
- Fabricated: Case Law | Petitioner cited 'Rodriquez v. Lowe, 2018 WL 683974 (M.D. Pa. Feb. 2, 2018)'; the court found the provided Westlaw citation redirected to an unrelated Quebec family-court decision and concluded no such M.D. Pa. case exists, calling it a legal hallucination.
Questions this record answers
- What happened in Emmanuel S. Yirenkyi v. Angela Hoover?
- The court identified that the pro se petitioner submitted AI-generated legal hallucinations, specifically citing two non-existent Middle District of Pennsylvania cases to support his argument for release. The court formally labeled these citations as AI-generated and noted the petitioner's reliance on generative AI for his filings.
- Why does Emmanuel S. Yirenkyi v. Angela Hoover matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in M.D. Pennsylvania, with the listed outcome: no adjudicated outcome recorded.
- What does the public record establish about Emmanuel S. Yirenkyi v. Angela Hoover?
- 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 Emmanuel S. Yirenkyi v. Angela Hoover 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.