John Doe v. James P. Ehrhard, Esq.
S.D. New York · Dec 1, 2025
What happened in this matter?
The Court issued a formal warning to a pro se litigant after identifying four fabricated case citations in the plaintiff's filings. The Magistrate Judge noted that the citations were likely the product of AI hallucinations and explicitly cautioned the plaintiff that future submission of non-existent case law would result in sanctions.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited four purported cases regarding CPLR § 3102(c) (three Westlaw citations and one New York Appellate Division cite); the Court could not locate any of them and concluded they were likely AI-generated fabrications.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
Why this matter is tracked
In a pro se action, the plaintiff submitted filings containing four citations to purported case law regarding CPLR § 3102(c). The presiding Magistrate Judge was unable to locate any of the cited decisions and concluded they were likely AI-generated fabrications. The Court issued a formal warning to the plaintiff, cautioning that future reliance on non-existent or AI-hallucinated case law would result in sanctions. The underlying litigation involved motions to remand, to proceed under a pseudonym, and to dismiss for lack of personal jurisdiction, which the Court addressed in its Report and Recommendation. The Court ultimately recommended granting the defendant's motion to dismiss for lack of personal jurisdiction.
This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The Court attributed the fabricated citations to AI hallucinations.
Report and Recommendation on motions to remand, to proceed under a pseudonym, and to dismiss for lack of personal jurisdiction.
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 four purported cases regarding CPLR § 3102(c) (three Westlaw citations and one New York Appellate Division cite); the Court could not locate any of them and concluded they were likely AI-generated fabrications.
Questions this record answers
- What happened in John Doe v. James P. Ehrhard, Esq.?
- The Court issued a formal warning to a pro se litigant after identifying four fabricated case citations in the plaintiff's filings. The Magistrate Judge noted that the citations were likely the product of AI hallucinations and explicitly cautioned the plaintiff that future submission of non-existent case law would result in sanctions.
- Why does John Doe v. James P. Ehrhard, Esq. matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
- What does the public record establish about John Doe v. James P. Ehrhard, Esq.?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this John Doe v. James P. Ehrhard, Esq. 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.