Kevin Krzeminski v. Janine McQuillan
SC New York · Jul 6, 2026
- Jurisdiction
- state
- Court
- SC New York
- Record ID
- kevin-krzeminski-v-janine-mcquillan-2026-07-06
- Observed outcome
- The court denied the plaintiff's motion to strike and issued a formal warning regarding the submission of unverified legal authorities.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a warning to a pro se litigant for citing nonexistent and misstated case law, likely generated by AI. While the court denied the plaintiff's motion to strike defenses, it explicitly cautioned that the failure to verify citations wastes judicial resources and may warrant future sanctions regardless of pro se status.
The court reasoned that pro se litigants are not excused from the duty to verify legal citations. It noted that the submission of nonexistent or misstated authorities wastes the time of the court and opposing counsel, and that such conduct, even if unintentional, may justify sanctions under 22 NYCRR 130-1.1.
This case illustrates judicial intolerance for unverified AI-generated citations in pro se filings. It reinforces that courts expect basic due diligence in legal research and that pro se status does not provide immunity from warnings or potential sanctions for frivolous conduct.
Failure modes and consequences
- Fabricated Case Law
- Misrepresented Case Law
- Pro Se
- Fake Citations
- Misrepresented Authority
- Other
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Motion to strike affirmative defenses and counterclaims in a partition action.
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 unverified citations likely generated by AI.
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.