John Doe v. James P. Ehrhard, Esq.
S.D. New York · Dec 1, 2025
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- john-doe-v-james-p-ehrhard-esq-2025-12-01
- Observed outcome
- The Court issued a formal warning regarding the use of fabricated citations and recommended granting the defendant's motion to dismiss for lack of personal jurisdiction.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Tort
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Report and Recommendation on motions to remand, to proceed under a pseudonym, and to dismiss for lack of personal jurisdiction.
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 attributed the fabricated citations to AI hallucinations.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.