Kamia Nellum v. Credit Acceptance Corporation
S.D. Indiana · Nov 18, 2025
What happened in this matter?
The court issued a formal warning to the pro se plaintiff for submitting hallucinated and misrepresented case law citations in her filings. The court clarified that pro se litigants are not exempt from procedural rules and cautioned that continued submission of fabricated authority could lead to sanctions.
- Why the court cared
- Misrepresented: Case Law | Plaintiff cited 'Messina v. N. Cent. Distrib., Inc., 821 N.E.2d 236 (Ind. Ct. App. 2005)'; court found the citation/method of attribution incorrect and that the proper decision appears as Messina v. N. Cent. Distrib., Inc., 821 F.3d 1047, 1050 (8th Cir. 2016). Court noted the case was not addressed by the Indiana Court of Appeals as plaintiff claimed. || Fabricated: Case Law | Plaintiff cited 'Miller v. Credit Acceptance Corp., 2019 WL 2450930 (S.D. Ind. 2019)'; court found that citation does not exist (2019 WL 2450930 corresponds to an unrelated D. Utah decision) and that the Miller v. Credit Acceptance decisions found on Westlaw are from 2012 (N.D. Ohio).
- Why it matters now
- This record documents a Pro Se Litigant filing issue in S.D. Indiana, with the listed outcome: Warning.
Why this matter is tracked
In a contract dispute, the pro se plaintiff submitted filings containing fabricated and misrepresented case law. Specifically, the plaintiff cited 'Messina v. N. Cent. Distrib., Inc., 821 N.E.2d 236 (Ind. Ct. App. 2005)', which the court identified as a miscitation of an 8th Circuit decision, and 'Miller v. Credit Acceptance Corp., 2019 WL 2450930 (S.D. Ind. 2019)', a non-existent citation that corresponds to an unrelated habeas corpus case in the District of Utah. The court granted the defendant's motion to compel arbitration and issued a formal warning to the plaintiff, noting that pro se status does not excuse the submission of hallucinated citations and that such conduct may result in future sanctions.
This record documents a Pro Se Litigant filing issue in S.D. Indiana, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The source does not name a tool, but the nature of the errors implies automated generation.
The court granted the defendant's motion to compel arbitration and stayed the proceedings pending the outcome of arbitration, while simultaneously issuing a warning regarding the plaintiff's citation practices.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Case Law | Plaintiff cited 'Messina v. N. Cent. Distrib., Inc., 821 N.E.2d 236 (Ind. Ct. App. 2005)'; court found the citation/method of attribution incorrect and that the proper decision appears as Messina v. N. Cent. Distrib., Inc., 821 F.3d 1047, 1050 (8th Cir. 2016). Court noted the case was not addressed by the Indiana Court of Appeals as plaintiff claimed.
- Fabricated: Case Law | Plaintiff cited 'Miller v. Credit Acceptance Corp., 2019 WL 2450930 (S.D. Ind. 2019)'; court found that citation does not exist (2019 WL 2450930 corresponds to an unrelated D. Utah decision) and that the Miller v. Credit Acceptance decisions found on Westlaw are from 2012 (N.D. Ohio).
Questions this record answers
- What happened in Kamia Nellum v. Credit Acceptance Corporation?
- The court issued a formal warning to the pro se plaintiff for submitting hallucinated and misrepresented case law citations in her filings. The court clarified that pro se litigants are not exempt from procedural rules and cautioned that continued submission of fabricated authority could lead to sanctions.
- Why does Kamia Nellum v. Credit Acceptance Corporation matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in S.D. Indiana, with the listed outcome: Warning.
- What does the public record establish about Kamia Nellum v. Credit Acceptance Corporation?
- 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 Kamia Nellum v. Credit Acceptance Corporation 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.