Lori Chavez-DeRemer v. NAB, LLC, Asia Trinh, and Nicole Brown
D. Nevada · Aug 11, 2025
- Jurisdiction
- federal
- Court
- D. Nevada
- Record ID
- lori-chavez-deremer-v-nab-llc-asia-trinh-and-nicole-brown-2025-08-11
- Observed outcome
- The court denied the defendants' motions to stay execution of the judgment and issued a formal warning regarding the use of AI-generated fake citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to the parties regarding the use of generative AI tools after identifying that a brief submitted by defendant Asia Trinh contained at least one fabricated case citation. The court cautioned that continued reliance on inaccurate or fake authority would lead to sanctions.
The court reasoned that generative AI tools pull information from unreliable sources and may hallucinate legal precedent. It held that under FRCP 11(b)(2), litigants have a duty to certify that legal contentions are warranted by existing law, and that presenting fake citations violates this duty.
This case illustrates judicial scrutiny of AI-generated research in pro se filings. It reinforces the court's expectation that litigants, regardless of representation status, must verify the existence and accuracy of all cited authorities to avoid sanctions.
Failure modes and consequences
- Fabricated Case Law
- Misrepresented Legal Authority
- Pro Se
- Fake Citations
- Misrepresented Authority
- Employment
- AI attribution
- Explicitly Recorded
- Recorded tool
- Generative AI software (e.g., ChatGPT)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order denying defendants' motions to stay execution of a monetary judgment pending appeal.
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 identified the use of generative AI software like ChatGPT.
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.