Gregory Ashley Moyer v. James V. Murray, et al.
10th Cir. CA · Jul 1, 2026
What happened in this matter?
The Tenth Circuit issued a formal warning to a pro se litigant for citing a nonexistent case in multiple motions. The court identified the citations as fabrications violating 10th Cir. R. 46.5(B)(2) but declined to impose further sanctions, opting instead to admonish the litigant and the bar regarding the duty to ensure all cited authorities are genuine.
- Why the court cared
- The court reasoned that the appellant's repeated citation of a nonexistent case violated 10th Cir. R. 46.5(B)(2), which mandates that filings be warranted by existing law. The court noted that while it possessed the authority to sanction the litigant, including by dismissing the appeal, it chose to issue a warning instead.
- Why it matters now
- This case highlights the judiciary's increasing focus on the integrity of legal citations. It serves as a reminder that pro se litigants and counsel are strictly responsible for verifying the existence and accuracy of all authorities cited in their filings, regardless of the research methods employed.
Why this matter is tracked
In an appellate decision affirming the dismissal of a pro se civil rights complaint, the Tenth Circuit Court of Appeals identified that the appellant, Gregory Ashley Moyer, cited a nonexistent case, 'United States v. Tittsworth, 630 F.3d 1029 (10th Cir. 2011),' in four separate motions to supplement the record. The court determined that these fabricated citations violated 10th Cir. R. 46.5(B)(2), which requires that legal arguments be warranted by existing law. While the court noted its authority to impose sanctions, including dismissal, it declined to do so in this instance. Instead, the court issued a formal warning to Moyer and all litigants appearing before the court regarding the necessity of verifying the authenticity of all cited legal authorities.
This case highlights the judiciary's increasing focus on the integrity of legal citations. It serves as a reminder that pro se litigants and counsel are strictly responsible for verifying the existence and accuracy of all authorities cited in their filings, regardless of the research methods employed.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Appellate review of a district court's dismissal of a civil rights complaint.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Moyer cited a nonexistent case "United States v. Tittsworth, 630 F.3d 1029 (10th Cir. 2011)" in multiple motions; the court found the citation fabricated, noted the violation of 10th Cir. R. 46.5(B)(2), and warned of possible sanctions.
Questions this record answers
- What happened in Gregory Ashley Moyer v. James V. Murray, et al.?
- The Tenth Circuit issued a formal warning to a pro se litigant for citing a nonexistent case in multiple motions. The court identified the citations as fabrications violating 10th Cir. R. 46.5(B)(2) but declined to impose further sanctions, opting instead to admonish the litigant and the bar regarding the duty to ensure all cited authorities are genuine.
- Why does Gregory Ashley Moyer v. James V. Murray, et al. matter for legal AI risk?
- This case highlights the judiciary's increasing focus on the integrity of legal citations. It serves as a reminder that pro se litigants and counsel are strictly responsible for verifying the existence and accuracy of all authorities cited in their filings, regardless of the research methods employed.
- What does the public record establish about Gregory Ashley Moyer v. James V. Murray, 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 Gregory Ashley Moyer v. James V. Murray, 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.