Jurkowski v. Berkowitz
SC DC · Apr 21, 2026
- Jurisdiction
- state
- Court
- SC DC
- Record ID
- jurkowski-v-berkowitz-2026-04-21
- Observed outcome
- The court denied the plaintiff's motion to amend due to statute of limitations concerns and issued a warning regarding the submission of AI-generated, nonexistent legal authority.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court found that the pro se plaintiff used AI tools to draft pleadings, resulting in the submission of a fabricated case citation. While the court denied the plaintiff's motion to amend primarily due to statute of limitations issues, it explicitly warned the plaintiff regarding the inclusion of AI-generated, nonexistent authority in court filings.
The court identified AI usage based on the disjointed and incoherent nature of the writing, the misuse of technical legal language, and the presence of text appearing to be AI-generated prompt responses. The court verified the fabrication of a specific citation by searching court reporters and Lexis, confirming the case did not exist.
This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It confirms that courts will actively verify citations when AI-assisted drafting is suspected and will address such conduct in the context of procedural motions.
Failure modes and consequences
- Hallucinated_case_law
- Pro Se
- Fake Citations
- Misrepresented Authority
- Employment
- Trial
- AI attribution
- Explicitly Recorded
- Recorded tool
- unspecified
- Known monetary consequence
- Not recorded
- Procedural posture
- Trial court order addressing multiple motions to dismiss, motions to amend, and motions to disqualify, issued April 21, 2026.
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 noted the use of artificial intelligence tools without naming a specific product.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- 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.