Which source supports this Hayes v. Chipotle Mexican Grill 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.

HomeCasesHayes v. Chipotle Mexican Grill

Evidence review: primary document verified. The linked primary document was extracted and checked with page-level evidence locators.

Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 81/100. It passes the current publication gate; that is not a legal-editorial review or a guarantee that every field has been independently verified.

Corpus matter record

Hayes v. Chipotle Mexican Grill

M.D. Florida · Jan 9, 2026

FL / federal Editorial impact: low pro se fake citations civil rights trial Warning

Direct answer

What happened in this matter?

The court issued a formal warning to a pro se litigant after discovering multiple fabricated case citations in his filings. The judge explicitly attributed the likely use of AI tools to these inaccuracies and warned that further misrepresentations or citations of nonexistent authority could lead to sanctions.

Why the court cared: Fabricated: Case Law | Court found the citation to 'Capistrano v. Fin. Indus. Regulatory Auth., Inc., 2015 WL 1647091, at *3 (M.D. Fla. Apr. 14, 2015)' does not exist and flagged it as an inaccurate authority. || Fabricated: Case Law | Court found the citation to 'Dept. of Fair Emp't & Hous. v. Law Sch. Admission Council, Inc., 2014 WL 4269110, at *8 (N.D. Cal. Aug. 28, 2014)' does not exist and flagged it as an inaccurate authority. || Fabricated: Case Law | Court found the citation to 'Perez v. Zazo, 498 So. 2d 463, 465 (Fla. 3d DCA 1986)' does not exist as cited and flagged it as an inaccurate authority. || Fabricated: Case Law | Court found the citation to 'Byrd v. Shumann, 2013 WL 12091938, at *2 (S.D. Fla. Jan. 28, 2013)' does not exist and flagged it as an inaccurate authority.
Why it matters now: This record documents a Pro Se Litigant filing issue in M.D. Florida, with the listed outcome: Warning.

Why this matter is tracked

In a civil rights action against Chipotle, the M.D. Florida court dismissed the pro se plaintiff's complaint without prejudice for failure to state a claim under the ADA. During its review, the court identified multiple nonexistent case citations in the plaintiff's opposition brief. The court noted that these inaccuracies suggested the use of automated artificial intelligence tools for research and drafting. Emphasizing that pro se status does not exempt litigants from the duty of candor or procedural rules, the court issued a formal warning to the plaintiff. The court cautioned that continued misrepresentation of the record or citation of nonexistent authority may result in future sanctions, while granting the plaintiff leave to file an amended complaint.

Operational lesson

This record documents a Pro Se Litigant filing issue in M.D. Florida, with the listed outcome: Warning.

Record details

FloridaSingle-state evidence scope

Explore FLOpen its source-linked jurisdiction page and related matters.

CourtM.D. Florida

Jurisdictionfederal

Circuit11th Circuit

DateJan 9, 2026

AI toolAI (unspecified)

Party typePro Se Litigant

OutcomeComplaint dismissed without prejudice; plaintiff issued a formal warning regarding the use of AI and the duty of candor.

Known amountNot recorded

Professional sanctionNo

Attribution boundary

What the record establishes about AI use

implied

The court noted the likely use of automated artificial intelligence tools.

Procedural posture

Order granting in part and denying in part a motion to dismiss, with leave to amend.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

4 citation, quotation, or authority issues are recorded in the source dataset.

Fabricated: Case Law | Court found the citation to 'Capistrano v. Fin. Indus. Regulatory Auth., Inc., 2015 WL 1647091, at *3 (M.D. Fla. Apr. 14, 2015)' does not exist and flagged it as an inaccurate authority.
Fabricated: Case Law | Court found the citation to 'Dept. of Fair Emp't & Hous. v. Law Sch. Admission Council, Inc., 2014 WL 4269110, at *8 (N.D. Cal. Aug. 28, 2014)' does not exist and flagged it as an inaccurate authority.
Fabricated: Case Law | Court found the citation to 'Perez v. Zazo, 498 So. 2d 463, 465 (Fla. 3d DCA 1986)' does not exist as cited and flagged it as an inaccurate authority.
Fabricated: Case Law | Court found the citation to 'Byrd v. Shumann, 2013 WL 12091938, at *2 (S.D. Fla. Jan. 28, 2013)' does not exist and flagged it as an inaccurate authority.

Questions this record answers

What happened in Hayes v. Chipotle Mexican Grill?: The court issued a formal warning to a pro se litigant after discovering multiple fabricated case citations in his filings. The judge explicitly attributed the likely use of AI tools to these inaccuracies and warned that further misrepresentations or citations of nonexistent authority could lead to sanctions.
Why does Hayes v. Chipotle Mexican Grill matter for legal AI risk?: This record documents a Pro Se Litigant filing issue in M.D. Florida, with the listed outcome: Warning.
What does the public record establish about Hayes v. Chipotle Mexican Grill?: 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.
Which source supports this Hayes v. Chipotle Mexican Grill 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.

Johnson v. Florida Department of Juvenile Justice et alM.D. Florida · Feb 19, 2026same court · pro se + fake citations Peter J. Allsot v. Naseem LatifM.D. Florida · Jan 20, 2026same court · pro se + fake citations Jacob Barry Allston v. Ron DeSantis, et al.M.D. Florida · Dec 4, 2025same court · pro se + fake citations Charles C. Force v. Capital One, N.A., et al.M.D. Florida · Oct 15, 2025same court · pro se + fake citations Rose v. Arts Bonita, Inc.M.D. Florida · Aug 12, 2026same court · pro se + fake citations Edwards v. De Cubas & Lewis, P.A.M.D. Florida · Jul 1, 2026same court · pro se + fake citations

Linked evidence record

Damien Charlotin case archive

Publisher document archive
The recorded document is hosted in the upstream publisher archive.

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Public-record statuspublic record, not an allegation-only entry

Indexing eligibilitypublicly indexable with evidence status disclosed

Evidence-review statusprimary document verified

Published and maintained byManu Ayala · AI VortexIndependent legal AI risk intelligence

Evidence review recorded Jul 27, 2026

Source host classified Attribution boundary stated Limitations disclosed

Corpus checked Sep 10, 2026; latest tracked decision Sep 8, 2026. AI Vortex summarizes public records and does not replace the court document or legal research service.

Use this record

Open case brief Open M.D. Florida profile Explore jurisdiction

Evidence boundary

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.

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