Lowrey v. City of Rio Rancho et al. (1)
D. New Mexico · Nov 5, 2025
- Jurisdiction
- federal
- Court
- D. New Mexico
- Record ID
- lowrey-v-city-of-rio-rancho-et-al-1-2025-11-05
- Observed outcome
- The Court denied the motion to remand and issued a formal warning to the plaintiff regarding the use of AI-generated or misleading legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court issued a formal warning to a pro se litigant for citing nonexistent cases and misrepresenting legal authority in an emergency motion to remand. The Court attributed these errors to the use of artificial intelligence and warned that future submissions of fabricated or misleading citations would result in sanctions, including potential dismissal.
Misrepresented: Case Law | Plaintiff cited Creekmore v. Food Lion, Inc., asserting it supports a rule about incomplete state-court records invalidating removal; the Court found that Creekmore does not support that proposition and Plaintiff misrepresented its holding. || Fabricated: Case Law | Plaintiff cited 'Cornell v. Precision Valve & Automation, Inc., 2011 WL 1420182 (D.N.M. 2011)' repeatedly; the Court was unable to find the case and concluded it is fictitious. || Fabricated: Case Law | Plaintiff relied on 'Baldwin v. Perdue Farms, Inc., 569 F. Supp. 2d 754 (E.D. Va. 2008)'; the Court could not locate this authority and concluded it is nonexistent. || Misrepresented: Case Law | Plaintiff quoted and over-extended a portion of Getty Oil's footnote and represented it as binding Tenth Circuit law; the Court found this characterization misleading. || Misrepresented: Case Law | Plaintiff attributed a non-existent quoted holding to Cornwall v. Robinson and represented it as Tenth Circuit precedent; the Court noted the quoted language does not appear in Cornwall and the issue was not decided there. || Misrepresented: Case Law | Plaintiff cited several Supreme Court and circuit opinions (e.g., Martin v. Franklin Capital, Carnegie-Mellon, Gibbs, Merrell Dow, Steel Co.) and misapplied or overstated their holdings for the proposition that removal should be invalidated here; the Court found those characterizations misleading.
This record documents a Pro Se Litigant filing issue in D. New Mexico, with the listed outcome: Warning.
Failure modes and consequences
- Hallucinated_case_law
- Misrepresented_legal_authority
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order denying emergency motion to remand and issuing a warning regarding potential future sanctions.
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 explicitly cautioned the plaintiff regarding the use of AI to draft filings.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.