Eric Andrew Perez v. Dr. Neil C. Evans, et al.
S.D. New York · Sep 25, 2025
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- eric-andrew-perez-v-dr-neil-c-evans-et-al-2025-09-25
- Observed outcome
- The court overruled the plaintiff's objections, adopted the Magistrate Judge's Report and Recommendation, and dismissed the amended complaint with prejudice. The court issued a warning regarding the use of AI-generated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Hallucinated_case_law
- Misattributed_quotations
- Misrepresented_legal_authority
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Admitted
- Recorded tool
- ChatGPT
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 plaintiff admitted to using ChatGPT to draft his submission.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to ChatGPT output as to any other research input.