Hayes v. Chipotle Mexican Grill
M.D. Florida · Jan 9, 2026
- Jurisdiction
- federal
- Court
- M.D. Florida
- Record ID
- hayes-v-chipotle-mexican-grill-2026-01-09
- Observed outcome
- Complaint dismissed without prejudice; plaintiff issued a formal warning regarding the use of AI and the duty of candor.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in M.D. Florida, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Civil Rights
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order granting in part and denying in part a motion to dismiss, with 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 likely use of automated artificial intelligence tools.
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.