Gregory J. Van Etten v. Stephanie K. Fattman, et al.
D. Massachusetts · Mar 6, 2026 · Margaret R. Guzman
- Jurisdiction
- federal
- Court
- D. Massachusetts
- Record ID
- gregory-j-van-etten-v-stephanie-k-fattman-et-al-2026-03-06
- Observed outcome
- The Court adopted the Magistrate Judge's R&Rs, granted the motion to dismiss, and issued a formal warning to the pro se litigant regarding the use of generative AI in legal filings.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court issued a warning to a pro se litigant after identifying that the litigant relied on generative AI to produce inaccurate legal arguments and fabricated citations in his filings. The Court clarified the correct statutory framework governing Magistrate Judge authority and dismissed the underlying action for lack of subject matter jurisdiction.
Misrepresented: Legal Norm | Court flagged plaintiff's use of 28 U.S.C. § 636(b)(1)(B) to support the incorrect proposition that a magistrate 'may recommend but cannot strike pleadings absent district-judge adoption,' and corrected that §636(b)(1)(A) and Fed. R. Civ. P. 72 govern magistrate authority over non-dispositive matters. || Misrepresented: Case Law | Plaintiff asserted that the Magistrate Judge's R&R referenced Ankenbrandt v. Richards and Seminole Tribe v. Florida, but the Court noted neither case is cited in the R&Rs the plaintiff relied on. || Fabricated: Other | Court warned generative AI can create incorrect or made-up citations and noted plaintiff's filings contained inaccurate or fabricated citations.
This record documents a Pro Se Litigant filing issue in D. Massachusetts, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Misrepresented Authority
- Civil Rights
- Trial
- Warning
- AI attribution
- Explicitly Recorded
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum and Order adopting Magistrate Judge's Reports and Recommendations and granting Defendants' Motion to Dismiss.
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 noted the plaintiff appeared to rely on generative AI.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.