Jackson v. BOK Financial Corporation et al (1)
N.D. Oklahoma · Aug 8, 2025
- Jurisdiction
- federal
- Court
- N.D. Oklahoma
- Record ID
- jackson-v-bok-financial-corporation-et-al-1-2025-08-08
- Observed outcome
- Motion to disqualify counsel stricken without prejudice; formal warning issued to the pro se plaintiff regarding future filings.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court struck the plaintiff's motion to disqualify counsel without prejudice after identifying multiple fabricated case law quotations. While the court declined to impose immediate Rule 11 sanctions, it issued a formal warning that continued submission of fabricated citations or frivolous filings could lead to future sanctions, including the dismissal of the plaintiff's claims.
The court reasoned that it is not the duty of the court or opposing parties to verify non-existent language in filings. Under Fed. R. Civ. P. 11(b)(2) and the court's inherent authority to manage judicial process, the court determined that striking the motion was appropriate to address the bad-faith conduct of presenting fabricated legal contentions.
This case illustrates the court's use of inherent authority to strike filings containing fabricated legal citations. It serves as a reminder that pro se litigants are held to the standard of reasonable inquiry under Rule 11, and that courts may issue warnings before escalating to formal sanctions for AI-assisted or manual citation fabrication.
Failure modes and consequences
- Pro Se
- Fabricated Quotes
- Other
- Trial
- Warning
- AI attribution
- Not Established
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Opinion and Order striking Plaintiff's Motion to Disqualify Respondents' Counsel and to Strike (ECF No. 39) without prejudice.
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 record does not identify a specific tool used to generate the fabricated quotes.
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
- Implement mandatory verification of all case law quotations and pincites against primary source documents.
- Establish a review protocol for filings to ensure that cited language exists within the referenced judicial opinions.
- Monitor pro se filings for patterns of citation errors that may indicate the use of unverified generative AI tools.