Jamal Berry v. Early Warning Services
E.D. Pennsylvania · Apr 30, 2026
- Jurisdiction
- federal
- Court
- E.D. Pennsylvania
- Record ID
- jamal-berry-v-early-warning-services-2026-04-30
- Observed outcome
- The court granted the defendant's motion to dismiss the complaint and issued a formal warning to the plaintiff regarding future Rule 11 compliance.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to a pro se litigant for violating Rule 11 by submitting an opposition brief containing fabricated case law and misattributed quotes. The court explicitly attributed the use of these fictitious authorities to the plaintiff's use of artificial intelligence and cautioned that future violations could lead to severe sanctions.
The court reasoned that under Rule 11, all litigants, including those appearing pro se, must conduct a reasonable inquiry into the law before filing. The court found the plaintiff failed this duty by submitting nonexistent cases and mischaracterized opinions, which it determined were generated by artificial intelligence.
This case illustrates the judicial response to AI-generated hallucinations in pro se filings. It reinforces that Rule 11 obligations apply equally to unrepresented parties and that courts will actively identify and penalize the use of fictitious legal research.
Failure modes and consequences
- Fabricated Case Law
- Hallucinated Quotes
- Misrepresented Legal Authority
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Admitted
- Recorded tool
- Artificial Intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Motion to dismiss granted; Rule 11 warning issued.
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 stated the plaintiff used artificial intelligence.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.