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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
McKeown v. Paycom Payroll LLC
W.D. Oklahoma · Mar 31, 2025
OK / federalEditorial impact: lowpro sefake citationsemploymenttrial
Direct answer
What happened in this matter?
Fabricated: Case Law | Plaintiff previously filed a brief citing non-existent legal authority; the Court issued a warning against falsified citations (Dkt. 18). Outcome: Submission stricken out, and warning.
- Why the court cared
- The record concerns whether authorities presented to the decision-maker existed and could be verified. The tracked outcome is Submission stricken out, and warning; the linked source controls the precise reasoning.
- Why it matters now
- Repeat pro-se hallucinations get pleadings struck but no fee-shift; move for strike early to clear the docket.
Why this matter is tracked
Fabricated: Case Law | Plaintiff previously filed a brief citing non-existent legal authority; the Court issued a warning against falsified citations (Dkt. 18). Outcome: Submission stricken out, and warning.
AI Use
Although AI was not named and Plaintiff denied intentional fabrication, the court considered the citation (Adamov, 779 F.3d 851, 860 (8th Cir. 2015)) to be plainly fictitious. It noted the possibility that Plaintiff used generative AI tools, given the fabricated citation's plausible-sounding structure and mismatch with existing precedent.
Hallucination Details
Plaintiff submitted fabricated legal authorities in at least two filings, despite being explicitly warned by the court after the first incident. The false case cited in her sur-reply could not be located in any legal database. When asked to produce it, she responded that she had likely “garbled” the citation but provided no plausible alternative or correction.
Ruling/Sanction
The court declined to dismiss the action as a sanction, citing the limitations pro se litigants face in accessing reliable legal research tools. However, it granted the defendant’s motion to strike Plaintiff’s two unauthorized sur-replies and formally warned her that further violations of Rule 11 would lead to sanctions, including monetary penalties, filing restrictions, or dismissal.
Operational lesson
Repeat pro-se hallucinations get pleadings struck but no fee-shift; move for strike early to clear the docket.
Record details
OklahomaSingle-state evidence scope
CourtW.D. Oklahoma
Jurisdictionfederal
Circuit10th Circuit
DateMar 31, 2025
AI
AI toolAI (implied, unspecified)
Party typePro Se Litigant
OutcomeSubmission stricken out, and warning
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Submission stricken out, and warning
Correction behavior
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.
- Fabricated: Case Law | Plaintiff previously filed a brief citing non-existent legal authority; the Court issued a warning against falsified citations (Dkt. 18).
- Fabricated: Case Law | Plaintiff's sur-reply cited a non-existent case; the Court found the citation fictitious and noted the closest real case does not support the asserted proposition.
Questions this record answers
- What happened in McKeown v. Paycom Payroll LLC?
- Fabricated: Case Law | Plaintiff previously filed a brief citing non-existent legal authority; the Court issued a warning against falsified citations (Dkt. 18). Outcome: Submission stricken out, and warning.
- Why does McKeown v. Paycom Payroll LLC matter for legal AI risk?
- Repeat pro-se hallucinations get pleadings struck but no fee-shift; move for strike early to clear the docket.
- What does the public record establish about McKeown v. Paycom Payroll LLC?
- 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.
- Which source supports this McKeown v. Paycom Payroll LLC 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.