Eric Andrew Perez v. Dr. Neil C. Evans, et al.
S.D. New York · Sep 25, 2025
What happened in this matter?
The court issued a warning regarding the plaintiff's use of ChatGPT to generate fabricated and misattributed legal citations in his court filings. While the court found these actions violated Rule 11(b) and wasted judicial resources, it declined to impose formal sanctions, opting instead to dismiss the underlying complaint with prejudice.
- Why the court cared
- The court reasoned that the plaintiff's use of AI to generate legal citations without verification violated Rule 11(b) of the Federal Rules of Civil Procedure. It emphasized that litigants have a duty to ensure the accuracy of all statements and citations, regardless of the tools used to draft them. The court noted that the creation of 'frustratingly realistic legal fiction' places an undue burden on the court and opposing parties to verify the truth of the submissions. However, the court declined to impose sanctions, noting the plaintiff's admission of AI use and the fact that the underlying claims were meritless regardless of the AI-related errors.
- Why it matters now
- This case illustrates the judicial response to AI-generated hallucinations in pro se filings. It reinforces the principle that litigants are responsible for verifying the accuracy of all AI-generated content and that failure to do so, even if not sanctioned, can result in significant procedural consequences.
Why this matter is tracked
In a pro se civil action, the S.D. New York court dismissed the plaintiff's amended complaint with prejudice. The court identified that the plaintiff used ChatGPT to draft his objections to a Magistrate Judge's Report and Recommendation, resulting in the inclusion of multiple hallucinated legal citations. Specifically, the plaintiff fabricated a case citation and misattributed a quotation to a non-existent decision, while also scrambling a citation to a real case that actually contradicted his legal argument. The court noted that while these AI-generated errors violated Rule 11(b) and wasted judicial resources, it declined to impose formal sanctions, citing the plaintiff's pro se status and his admission of AI use. The court ultimately adopted the Report and Recommendation in its entirety.
This case illustrates the judicial response to AI-generated hallucinations in pro se filings. It reinforces the principle that litigants are responsible for verifying the accuracy of all AI-generated content and that failure to do so, even if not sanctioned, can result in significant procedural consequences.
Record details
What the record establishes about AI use
The plaintiff admitted to using ChatGPT to draft his submission.
The court reviewed the plaintiff's objections to a Magistrate Judge's Report and Recommendation, which had recommended dismissal of the amended complaint. The court overruled the objections and adopted the Report and Recommendation in its entirety, dismissing the case with prejudice.
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 | Plaintiff attributed a quotation to 'Concepcion v. City of New York, No. 05 Civ. 8501 (RJS), 2008 WL 5395720, at *4 (S.D.N.Y. Dec. 17, 2008),' but no such December 17, 2008 S.D.N.Y. opinion exists; the quoted language actually appears in Armco, Inc. v. Penrod-Stauffer Building Systems, Inc., 733 F.2d 1087, 1089 (4th Cir. 1984). Court treated this citation as a hallucinated/fabricated citation and noted the misattribution and omission of context.
- Misrepresented: Case Law | Plaintiff cited 'United States v. Peterson, No. 3:17-cr-00065 (D. Conn. 2018)' and claimed the case supported a proposition about deception vitiating consent; the docket cited corresponds to United States v. Cook and the Peterson citation appears scrambled; the actual Peterson decision (No. 3:18-CR-00049, 2018 WL 6061571) holds the opposite of Plaintiff's asserted rule. Court treated this as an AI-generated misrepresentation/scrambled citation and noted the holding contradicted Plaintiff's use.
Questions this record answers
- What happened in Eric Andrew Perez v. Dr. Neil C. Evans, et al.?
- The court issued a warning regarding the plaintiff's use of ChatGPT to generate fabricated and misattributed legal citations in his court filings. While the court found these actions violated Rule 11(b) and wasted judicial resources, it declined to impose formal sanctions, opting instead to dismiss the underlying complaint with prejudice.
- Why does Eric Andrew Perez v. Dr. Neil C. Evans, et al. matter for legal AI risk?
- This case illustrates the judicial response to AI-generated hallucinations in pro se filings. It reinforces the principle that litigants are responsible for verifying the accuracy of all AI-generated content and that failure to do so, even if not sanctioned, can result in significant procedural consequences.
- What does the public record establish about Eric Andrew Perez v. Dr. Neil C. Evans, et al.?
- 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.
- Which source supports this Eric Andrew Perez v. Dr. Neil C. Evans, 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.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.