Jeramiah Brown v. Fat Dough Incorp., doing business as Dominos Pizza
N.D. New York · Sep 17, 2025
- Jurisdiction
- federal
- Court
- N.D. New York
- Record ID
- jeramiah-brown-v-fat-dough-incorp-doing-business-as-dominos-pizza-2025-09-17
- Observed outcome
- The court denied the plaintiff's motion for sanctions and summary judgment, granted the defendant's motion for summary judgment, and issued a warning regarding the use of AI-generated fake citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Employment
- Trial
- Warning
- AI attribution
- Admitted
- Recorded tool
- ChatGPT
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 plaintiff testified to using ChatGPT to draft his legal papers.
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
- Implement mandatory verification protocols for all case citations generated by AI tools.
- Cross-reference Westlaw or LexisNexis identifiers against the actual case names and courts provided in filings.
- Educate pro se litigants on the risks of AI-generated hallucinations and the requirements of Rule 11(b).