Which source supports this Hodges v. McGough Enterprises LLC 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.

HomeCasesHodges v. McGough Enterprises LLC

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

Hodges v. McGough Enterprises LLC

S.D. New York · May 26, 2026

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

Direct answer

What happened in this matter?

The Court issued a warning to a pro se litigant after identifying multiple non-existent case citations in a motion, which the Court suspected were generated by AI. The Court ordered the litigant to produce the cited authorities and cautioned that continued reliance on fabricated citations could lead to formal sanctions or dismissal.

Why the court cared: The Court reasoned that the Plaintiff's inability to provide verifiable citations for five specific cases raised a significant concern of AI-generated hallucinations, noting that pro se status does not excuse the submission of fake legal authority.
Why it matters now: This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It reinforces that courts apply the same verification standards to pro se litigants as to counsel, with potential for sanctions if fake citations persist.

Why this matter is tracked

In a civil rights action, the pro se Plaintiff filed a motion for a protective order citing several legal authorities. The Court, upon review, was unable to locate or verify the existence of five specific cases cited by the Plaintiff. The Court expressed concern that these citations were the result of generative AI hallucinations and noted that submitting fake case citations is unacceptable for pro se litigants. The Court denied the Plaintiff's motion for a protective order and directed the Plaintiff to provide copies of the cited cases within one week. The Court further warned the Plaintiff that future filings containing nonexistent case citations could result in sanctions, including the striking of submissions, filing restrictions, or dismissal of the case.

Operational lesson

This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It reinforces that courts apply the same verification standards to pro se litigants as to counsel, with potential for sanctions if fake citations persist.

Record details

New YorkSingle-state evidence scope

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

CourtS.D. New York

Jurisdictionfederal

Circuit2nd Circuit

DateMay 26, 2026

AI toolAI (implied, unspecified)

Party typePro Se Litigant

OutcomeThe Court denied the motion for a protective order and issued a formal warning regarding the use of fabricated case law.

Known amountNot recorded

Professional sanctionNone

Attribution boundary

What the record establishes about AI use

implied

The Court identified the citations as potential AI hallucinations.

Procedural posture

The matter arose during discovery in a civil rights action pending in the S.D. New York, specifically regarding the Plaintiff's motion for a protective order.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

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

Fabricated: Case Law | Court was unable to locate or verify this case citation cited by Plaintiff and raised concern it may be AI-generated; Plaintiff directed to produce a copy.
Fabricated: Case Law | Court was unable to locate or verify this case citation cited by Plaintiff and raised concern it may be AI-generated; Plaintiff directed to produce a copy.
Fabricated: Case Law | Court was unable to locate or verify this case citation cited by Plaintiff and raised concern it may be AI-generated; Plaintiff directed to produce a copy.
Fabricated: Case Law | Court was unable to locate or verify this case citation cited by Plaintiff and raised concern it may be AI-generated; Plaintiff directed to produce a copy.
Fabricated: Case Law | Court was unable to locate or verify this case citation cited by Plaintiff and raised concern it may be AI-generated; Plaintiff directed to produce a copy.

Questions this record answers

What happened in Hodges v. McGough Enterprises LLC?: The Court issued a warning to a pro se litigant after identifying multiple non-existent case citations in a motion, which the Court suspected were generated by AI. The Court ordered the litigant to produce the cited authorities and cautioned that continued reliance on fabricated citations could lead to formal sanctions or dismissal.
Why does Hodges v. McGough Enterprises LLC matter for legal AI risk?: This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It reinforces that courts apply the same verification standards to pro se litigants as to counsel, with potential for sanctions if fake citations persist.
What does the public record establish about Hodges v. McGough Enterprises LLC?: 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 Hodges v. McGough Enterprises LLC 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.

Jason Wimberly v. Verizon New York Inc.S.D. New York · Jun 12, 2026same court · pro se + fake citations Mercy Wellington v. City of New YorkS.D. New York · Apr 30, 2026same court · pro se + fake citations Advani v. Appellate TermS.D. New York · Aug 1, 2025same court · pro se + fake citations Nelson Lin v. The Honorable Jonathan H. Shim, et al.S.D. New York · Apr 9, 2025same court · pro se + fake citations Fernando Justino Santana v. Shook Hardy & Bacon, et al.S.D. New York · Jul 31, 2026same court · pro se + fake citations Sana Hazina Butler v. Fidelity Management & Research Company LLCS.D. New York · Apr 30, 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 Aug 17, 2026; latest tracked decision Aug 13, 2026. AI Vortex summarizes public records and does not replace the court document or legal research service.

Use this record

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Evidence boundary

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.

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