Hodges v. McGough Enterprises LLC
S.D. New York · May 26, 2026
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- hodges-v-mcgough-enterprises-llc-2026-05-26
- Observed outcome
- The Court denied the motion for a protective order and issued a formal warning regarding the use of fabricated case law.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Civil Rights
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- 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.
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 identified the citations as potential AI hallucinations.
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.
- 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.