Erik Arthur Otteson v. JPMorgan Chase Bank NA
D. Arizona · Jul 17, 2026
- Jurisdiction
- federal
- Court
- D. Arizona
- Record ID
- erik-arthur-otteson-v-jpmorgan-chase-bank-na-2026-07-17
- Observed outcome
- The court issued a formal warning to the pro se plaintiff regarding the use of generative AI and the requirement to verify all citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a warning to a pro se litigant after identifying fabricated case law citations and quotations in his filings, which the court attributed to the likely use of generative AI. The court explicitly cautioned the plaintiff that future filings containing such fabrications could result in sanctions.
The court reasoned that regardless of whether the plaintiff used AI or simply imagined the cases, filing documents with fabricated citations causes confusion and unnecessary work for the court and opposing parties. The court cited the duty of all litigants to read everything cited in a court filing.
This case illustrates judicial intolerance for AI-generated hallucinations in pro se filings. It reinforces the expectation that all litigants, regardless of representation status, must verify the accuracy of every citation and quotation presented to the court.
Failure modes and consequences
- Pro Se
- Fabricated Quotes
- Contract
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court granted the defendant's motion to dismiss the complaint with leave to amend, while simultaneously issuing a warning regarding the plaintiff's use of AI-generated fabricated citations.
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 stated the incorrect citations likely resulted from the use of artificial intelligence.
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
- Implement mandatory verification protocols for all case law citations and quotations, regardless of the research tool used.
- Establish a review process for filings to detect potential AI-generated hallucinations before submission.
- Ensure that all legal research is cross-referenced against primary source documents to confirm the existence of cited language.