Jeramiah Brown v. Fat Dough Incorp., doing business as Dominos Pizza
N.D. New York · Sep 17, 2025
What happened in this matter?
The court issued a warning to the pro se plaintiff regarding the inclusion of a fictitious legal citation in his filings. The court explicitly identified that the plaintiff used ChatGPT to draft his legal papers and reminded him of his obligation under Fed. R. Civ. P. 11(b) to verify the accuracy of all legal assertions.
- Why the court cared
- The court reasoned that all litigants, including pro se parties, must verify the truth of their legal assertions under Fed. R. Civ. P. 11(b). It noted that AI tools regularly hallucinate and that the plaintiff's specific citation was demonstrably false, as the Westlaw identifier belonged to an unrelated case.
- Why it matters now
- This case illustrates the ongoing challenge of AI-generated fake citations in pro se litigation. It reinforces the judicial expectation that litigants, regardless of representation status, must independently verify the existence and accuracy of all legal authorities cited in court submissions.
Why this matter is tracked
In a pro se employment discrimination action, the plaintiff submitted legal filings containing a fictitious case citation, 'Lynch v. U.S. Postal Service, 2016 WL 7338415 (N.D.N.Y. Dec. 19, 2016).' The court identified that the Westlaw citation actually corresponded to an unrelated habeas corpus case, 'Green v. New York,' and confirmed no such Lynch decision existed in that court. The plaintiff admitted to using ChatGPT to draft his legal papers. The court noted the 'epidemic' of AI-generated fake citations and reminded the litigant of the duty under Fed. R. Civ. P. 11(b) to ensure all assertions of fact and law are true. The court ultimately granted the defendant's motion for summary judgment on the merits of the underlying employment claims.
This case illustrates the ongoing challenge of AI-generated fake citations in pro se litigation. It reinforces the judicial expectation that litigants, regardless of representation status, must independently verify the existence and accuracy of all legal authorities cited in court submissions.
Record details
What the record establishes about AI use
The plaintiff testified to using ChatGPT to draft his legal papers.
The court addressed the plaintiff's motions for summary judgment and sanctions alongside the defendant's cross-motion for summary judgment. The court denied the plaintiff's motions and granted the defendant's motion for summary judgment.
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 included the fictitious citation 'Lynch v. U.S. Postal Service, 2016 WL 7338415 (N.D.N.Y. Dec. 19, 2016)'; court found the Westlaw citation actually corresponds to Green v. New York, No. 14-cv-2073, 2016 WL 7338415 (S.D.N.Y. Dec. 19, 2016), and no Lynch decision by this court in 2016.
Questions this record answers
- What happened in Jeramiah Brown v. Fat Dough Incorp., doing business as Dominos Pizza?
- The court issued a warning to the pro se plaintiff regarding the inclusion of a fictitious legal citation in his filings. The court explicitly identified that the plaintiff used ChatGPT to draft his legal papers and reminded him of his obligation under Fed. R. Civ. P. 11(b) to verify the accuracy of all legal assertions.
- Why does Jeramiah Brown v. Fat Dough Incorp., doing business as Dominos Pizza matter for legal AI risk?
- This case illustrates the ongoing challenge of AI-generated fake citations in pro se litigation. It reinforces the judicial expectation that litigants, regardless of representation status, must independently verify the existence and accuracy of all legal authorities cited in court submissions.
- What does the public record establish about Jeramiah Brown v. Fat Dough Incorp., doing business as Dominos Pizza?
- 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 Jeramiah Brown v. Fat Dough Incorp., doing business as Dominos Pizza 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.