Habib Miah v. Morgan Stanley & Co. International PLC, et al.
S.D. New York · Oct 11, 2025
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- habib-miah-v-morgan-stanley-co-international-plc-et-al-2025-10-11
- Observed outcome
- The court granted the defendants' motion to dismiss for lack of subject matter jurisdiction and denied the plaintiff's motion for leave to amend.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court identified that the pro se plaintiff used AI to generate filings containing fabricated case law and non-existent quotations. While the court dismissed the case for lack of subject matter jurisdiction, it formally recorded the plaintiff's reliance on AI-generated hallucinations as a troubling aspect of the litigation record.
The court reasoned that the plaintiff's filings were unreliable due to the inclusion of fabricated citations and quotations, which the court identified as indicative of AI use, and further noted that the initial complaint contained residual AI-generated commentary.
This case illustrates the risks of pro se litigants using AI tools to generate legal filings, resulting in the submission of fabricated authorities. It serves as a reminder for courts to scrutinize filings for AI-generated hallucinations and for practitioners to verify all cited authorities.
Failure modes and consequences
- Hallucinated_case_law
- Hallucinated_quotes
- Residual_ai_prompt_text
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Explicitly Recorded
- Recorded tool
- unspecified AI platform
- Known monetary consequence
- Not recorded
- Procedural posture
- The district court adopted the magistrate judge's report and recommendation in full, granting the defendants' motion to dismiss for lack of subject matter jurisdiction and denying the plaintiff's motion for leave to amend.
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's use of an AI platform.
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.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.