Jaii LeShawn Quinones v. Unknown Love, et al.
E.D. Missouri · Mar 31, 2026
What happened in this matter?
The court issued a show cause order requiring the pro se plaintiff to explain why he should not be sanctioned under Federal Rule of Civil Procedure 11(b) for citing non-existent case law and misrepresenting the holdings of real cases in his filings.
- Why the court cared
- The court reasoned that the plaintiff violated Federal Rule of Civil Procedure 11(b) by signing and presenting filings containing phony case law and mischaracterized holdings, noting that pro se litigants are not exempt from the duty to conduct a reasonable inquiry into the accuracy of their legal citations.
- Why it matters now
- Show-cause orders are now the reflex response to fabricated reporter citations — respond with full AI disclosure.
Why this matter is tracked
In a pro se civil action challenging passport denial due to child support arrearages, the plaintiff submitted filings containing multiple fabricated case citations and misrepresented legal holdings. The court identified that the plaintiff cited non-existent cases, such as a purported 628 F.2d 346 decision in Egelhoff v. Egelhoff, and mischaracterized the holding of Haig v. Agee. The court dismissed the complaint for failure to state a claim and issued a show cause order requiring the plaintiff to explain why he should not be sanctioned under Federal Rule of Civil Procedure 11(b) for presenting phony legal authority. The court emphasized that there is no pro se exception to the duty of reasonable inquiry under Rule 11(b).
Show-cause orders are now the reflex response to fabricated reporter citations — respond with full AI disclosure.
Record details
What the record establishes about AI use
The court identified the use of phony case law, which is characteristic of AI-generated hallucinations.
The court dismissed the plaintiff's complaint without prejudice for failure to state a claim and concurrently issued a show cause order regarding potential Rule 11(b) sanctions.
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.
- Misrepresented: Case Law | Plaintiff cited "Egelhoff v. Egelhoff, 628 F.2d 346" for the proposition that arbitrary passport restrictions are unconstitutional; the Court found the reporter cite fabricated and the asserted holding incorrect (real case is Egelhoff v. Egelhoff, 532 U.S. 141 (2001), which does not say that).
- Fabricated: Case Law | Plaintiff cited "Missouri ex rel. Wilkerson v. Wilkerson, 817 S.W.2d 77 (Mo. Ct. App. 1991)" and the Court found that citation does not exist as cited and does not support Plaintiff's proposition.
- Fabricated: Case Law | Plaintiff cited "Robinson v. Missouri Child Support Agency, 2021 WL 5437824 (Mo. Ct. App. 2021)" but the Court concluded the citation does not exist or does not support the asserted proposition.
- Misrepresented: Case Law | Plaintiff attributed to Haig v. Agee the proposition that "government-imposed passport restrictions must be justified by compelling evidence;" the Court explained Plaintiff's characterization is the opposite of the case's actual holding.
Questions this record answers
- What happened in Jaii LeShawn Quinones v. Unknown Love, et al.?
- The court issued a show cause order requiring the pro se plaintiff to explain why he should not be sanctioned under Federal Rule of Civil Procedure 11(b) for citing non-existent case law and misrepresenting the holdings of real cases in his filings.
- Why does Jaii LeShawn Quinones v. Unknown Love, et al. matter for legal AI risk?
- Show-cause orders are now the reflex response to fabricated reporter citations — respond with full AI disclosure.
- What does the public record establish about Jaii LeShawn Quinones v. Unknown Love, et al.?
- 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 Jaii LeShawn Quinones v. Unknown Love, et al. 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
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