Leber v. Bryan Medical Center et al.
D. Nebraska · Dec 23, 2025
What happened in this matter?
The court issued a formal warning to a pro se litigant for submitting AI-hallucinated case citations in a motion for reconsideration. The court explicitly noted the plaintiff's failure to verify authorities despite a prior warning and a signed certification of accuracy, citing the potential for sanctions under Fed. R. Civ. P. 11(b) and local rules.
- Why the court cared
- Fabricated: Case Law | Plaintiff repeatedly cited 'Kelly v. St. Francis Medical Center, 899 N.W.2d 869 (Neb. 2017)'; the court found that '899 N.W.2d 869' corresponds to St. Jude Med., Inc. v. Carter (Minn. Ct. App. 2017), indicating the Kelly citation is likely AI-generated.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in D. Nebraska, with the listed outcome: Warning.
Why this matter is tracked
In a pro se tort action, the U.S. District Court for the District of Nebraska denied the plaintiff's motion for reconsideration. The court identified that the plaintiff repeatedly cited a non-existent case, 'Kelly v. St. Francis Medical Center, 899 N.W.2d 869 (Neb. 2017),' which the court determined was an AI-generated hallucination. The court noted that the cited volume and page number actually correspond to a Minnesota Court of Appeals decision. Despite the plaintiff's prior certification that all citations were verified, the court issued a formal warning regarding the duty to ensure the accuracy of legal authorities and compliance with court rules, citing Federal Rule of Civil Procedure 11(b) and local rules regarding potential sanctions for material misrepresentations.
This record documents a Pro Se Litigant filing issue in D. Nebraska, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court refers to the citation as a hallucination of artificial intelligence.
The matter was before the court on the plaintiff's motion for reconsideration of a previously denied motion for partial final judgment.
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 repeatedly cited 'Kelly v. St. Francis Medical Center, 899 N.W.2d 869 (Neb. 2017)'; the court found that '899 N.W.2d 869' corresponds to St. Jude Med., Inc. v. Carter (Minn. Ct. App. 2017), indicating the Kelly citation is likely AI-generated.
Questions this record answers
- What happened in Leber v. Bryan Medical Center et al.?
- The court issued a formal warning to a pro se litigant for submitting AI-hallucinated case citations in a motion for reconsideration. The court explicitly noted the plaintiff's failure to verify authorities despite a prior warning and a signed certification of accuracy, citing the potential for sanctions under Fed. R. Civ. P. 11(b) and local rules.
- Why does Leber v. Bryan Medical Center et al. matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in D. Nebraska, with the listed outcome: Warning.
- What does the public record establish about Leber v. Bryan Medical Center et al.?
- 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 Leber v. Bryan Medical Center et al. 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.