Jamie Lee Saunders v. Albertsons/Safeway, LLC
D. Colorado · Apr 16, 2026
- Jurisdiction
- federal
- Court
- D. Colorado
- Record ID
- jamie-lee-saunders-v-albertsonssafeway-llc-2026-04-16
- Observed outcome
- The court issued a formal warning to the pro se plaintiff regarding future filings and the use of hallucinated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to a pro se litigant after she admitted to including a hallucinated, AI-generated case citation in a reply brief. The court declined to strike the motion, citing a lack of prejudice, but cautioned that future procedural violations or the use of fabricated citations could result in the summary striking of her filings.
The court declined to strike the motion because the plaintiff's delay in filing caused no prejudice to the defendant, and the plaintiff admitted and apologized for the AI-generated citation error.
Admit AI use the moment it's challenged; immediate apology is what kept this one at a warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Employment
- Trial
- Warning
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Order issued by a U.S. Magistrate Judge resolving motions for costs and a motion to strike.
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 refers to the citation as AI-generated but does not name a specific tool.
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 cited authorities and quoted propositions against the linked primary material.
- Preserve the verification record and identify unresolved exceptions before filing or relying.
- Escalate unsupported claims to the responsible human reviewer for a documented decision.