AI VORTEXLEGAL AI RISK
AI visibilityConsultingSearch free
Public trackerCorpus refreshed Sep 10, 2026 · Latest decision Sep 8, 2026Public incidents are risk signals, not usage-adjusted rates
HomeCasesIn re Molina
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

In re Molina

E.D. New York (Bankruptcy) · Sep 22, 2025

NY / federalEditorial impact: lowpro sefake citationsbar referralbankruptcyNone Adjudicated
Direct answer

What happened in this matter?

The court ordered the pro se defendant to file a sworn statement with every future filing certifying the accuracy of all cited legal authorities and to maintain copies of those authorities until the case concludes, following the defendant's submission of multiple nonexistent case citations.

Why the court cared
The court reasoned that while the defendant's submission of nonexistent cases was improper and unacceptable, monetary sanctions were not warranted because the defendant's pro se status required special solicitude and the record did not establish intentional bad faith or an attempt to deceive the court.
Why it matters now
This matter connects pro se and fake citations involving AI (implied, unspecified) with Order to sworn accuracy of citations in E.D. New York (Bankruptcy), making it a concrete reference point for verification, supervision, and response controls.

Why this matter is tracked

In this bankruptcy adversary proceeding, the pro se defendant filed a motion for relief from judgment under Rule 60(b), citing several judicial opinions that the court and opposing counsel could not locate. The court identified these as nonexistent citations. While the court declined to impose monetary sanctions, citing the defendant's pro se status and lack of clear bad faith, it expressed concern regarding the submission of fake legal authority. Consequently, the court ordered the defendant to file a sworn statement with every future document certifying that he has verified the accuracy of all cited legal authorities and to maintain copies of such authorities until the case is closed.

Operational lesson

This matter connects pro se and fake citations involving AI (implied, unspecified) with Order to sworn accuracy of citations in E.D. New York (Bankruptcy), making it a concrete reference point for verification, supervision, and response controls.

Record details

New YorkSingle-state evidence scope
Explore NYOpen its source-linked jurisdiction page and related matters.
CourtE.D. New York (Bankruptcy)
Jurisdictionfederal
Circuit2nd Circuit
DateSep 22, 2025
AI
AI toolAI (implied, unspecified)
Party typePro Se Litigant
OutcomeThe court denied the defendant's motion to vacate the judgment and denied all cross-motions for sanctions, but imposed a mandatory verification and certification requirement for all future filings.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

implied

The court referenced the defendant's use of legal research that resulted in nonexistent cases, implying AI usage.

Procedural posture

Memorandum Decision and Order denying the defendant's Rule 60(b) motion to vacate a settlement agreement and denying cross-motions for sanctions.

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.

  1. Fabricated: Case Law | Defendant cited a disciplinary decision that the Court and opposing counsel could not locate; viewed as a potentially fictitious citation.
  2. Fabricated: Case Law | Defendant cited an E.D.N.Y. opinion that the Court could not locate; treated as a nonexistent citation.
  3. Fabricated: Case Law | Defendant cited a California appellate decision the Court could not locate; flagged as potentially fictional.
  4. Fabricated: Case Law | Defendant cited an E.D. Cal. opinion that the Court could not find; treated as a possibly fabricated citation.

Questions this record answers

What happened in In re Molina?
The court ordered the pro se defendant to file a sworn statement with every future filing certifying the accuracy of all cited legal authorities and to maintain copies of those authorities until the case concludes, following the defendant's submission of multiple nonexistent case citations.
Why does In re Molina matter for legal AI risk?
This matter connects pro se and fake citations involving AI (implied, unspecified) with Order to sworn accuracy of citations in E.D. New York (Bankruptcy), making it a concrete reference point for verification, supervision, and response controls.
What does the public record establish about In re Molina?
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 In re Molina 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.

Philippeaux v. United States, et al.S.D. New York · Sep 8, 2026same jurisdiction · pro se + fake citationsMary-Rose F. Calenzo v. Waste Management, Inc.N.D. New York · Aug 5, 2026same jurisdiction · pro se + fake citationsFernando Justino Santana v. Shook Hardy & Bacon, et al.S.D. New York · Jul 31, 2026same jurisdiction · pro se + fake citationsKevin Krzeminski v. Janine McQuillanSC New York · Jul 6, 2026same jurisdiction · pro se + fake citationsJason Wimberly v. Verizon New York Inc.S.D. New York · Jun 12, 2026same jurisdiction · pro se + fake citationsLiveVideo.AI Corp. v. RedstoneS.D. New York · Jun 9, 2026same jurisdiction · fake citations + bar referral