Jason Wimberly v. Verizon New York Inc.
S.D. New York · Jun 12, 2026 · Laura Taylor Swain
What happened in this matter?
The Court warned the pro se plaintiff regarding his Rule 11(b)(2) obligations after he submitted a filing containing a hallucinated case citation. The Court explicitly noted that the citation to a non-existent case suggested the use of generative artificial intelligence to draft the submission.
- Why the court cared
- The Court reasoned that the plaintiff's citation to a non-existent case, which did not appear in legal databases and led to an unrelated opinion, indicated the use of generative AI and violated the duty under Rule 11(b)(2) to conduct a reasonable inquiry into the validity of legal authorities.
- Why it matters now
- This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It reinforces that all litigants, regardless of representation, are subject to Rule 11 requirements to verify the existence and accuracy of cited legal authorities.
Why this matter is tracked
In a civil rights action against Verizon New York Inc., the pro se plaintiff filed an emergency motion for a temporary restraining order. During the proceedings, the Court identified that the plaintiff cited a non-existent legal opinion, United States v. Chawla, 453 F. Supp. 3d 571 (E.D.N.Y. 2020). The Court noted that the citation led to an unrelated case, United States v. Bedi, which did not support the plaintiff's proposition. The Court observed that such phantom citations are indicative of the use of generative artificial intelligence. Consequently, the Court issued a warning to the plaintiff regarding his obligations under Rule 11(b)(2) of the Federal Rules of Civil Procedure to verify the existence and validity of all legal authorities cited in court submissions.
This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It reinforces that all litigants, regardless of representation, are subject to Rule 11 requirements to verify the existence and accuracy of cited legal authorities.
Record details
What the record establishes about AI use
The Court identified the use of generative artificial intelligence.
The Court issued an order denying the plaintiff's motion for a temporary restraining order and addressing various procedural motions, including a motion to seal, while simultaneously warning the plaintiff regarding his citation practices.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited a non-existent opinion (United States v. Chawla, 453 F. Supp. 3d 571 (E.D.N.Y. 2020)); the Court could not locate the case and found the citation instead led to United States v. Bedi, which did not support the cited proposition.
Questions this record answers
- What happened in Jason Wimberly v. Verizon New York Inc.?
- The Court warned the pro se plaintiff regarding his Rule 11(b)(2) obligations after he submitted a filing containing a hallucinated case citation. The Court explicitly noted that the citation to a non-existent case suggested the use of generative artificial intelligence to draft the submission.
- Why does Jason Wimberly v. Verizon New York Inc. matter for legal AI risk?
- This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It reinforces that all litigants, regardless of representation, are subject to Rule 11 requirements to verify the existence and accuracy of cited legal authorities.
- What does the public record establish about Jason Wimberly v. Verizon New York Inc.?
- 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 Jason Wimberly v. Verizon New York Inc. 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.