Jason Wimberly v. Verizon New York Inc.
S.D. New York · Jun 12, 2026 · Laura Taylor Swain
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- jason-wimberly-v-verizon-new-york-inc-2026-06-12
- Observed outcome
- The Court denied the plaintiff's motion for a temporary restraining order and issued a formal warning regarding the duty to verify legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Hallucinated_case_law
- Pro Se
- Fake Citations
- Civil Rights
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- generative artificial intelligence
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 identified the use of generative 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.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.