McNeal v. United Food and Commercial Workers Local 555; Safeway, Inc.
D. Oregon · Jan 22, 2026
What happened in this matter?
The court issued a formal warning to the pro se plaintiff regarding the citation of a fabricated case, noting it was likely generated by AI. The court reminded the plaintiff of the obligation under Rule 11 to verify the existence and validity of all legal authorities cited in court filings.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited a non-existent appellate decision 'Frey v. [ODOC], 204 P.3d 135 (Or. Ct. App. 2009)'; opposing counsel flagged the citation and the court explicitly warned the plaintiff that the opinion appears fabricated and may have been generated by AI.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in D. Oregon, with the listed outcome: Warning.
Why this matter is tracked
In an employment discrimination action, the pro se plaintiff, James McNeal, cited a non-existent appellate decision, 'Frey v. [ODOC], 204 P.3d 135 (Or. Ct. App. 2009),' in his response to a motion to dismiss. Opposing counsel identified the citation as fabricated. The court, in its Opinion and Order, explicitly warned the plaintiff that the opinion appears to be a hallucination generated by an artificial intelligence tool. The court emphasized that Rule 11 duties require self-represented parties to verify the existence and validity of all legal authorities relied upon in their filings, noting that reliance on fake opinions constitutes an abuse of the adversary system.
This record documents a Pro Se Litigant filing issue in D. Oregon, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court noted the citation may have been created by a generative AI tool.
Opinion and Order on Defendants' motions to dismiss the plaintiff's second amended complaint.
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 cited a non-existent appellate decision 'Frey v. [ODOC], 204 P.3d 135 (Or. Ct. App. 2009)'; opposing counsel flagged the citation and the court explicitly warned the plaintiff that the opinion appears fabricated and may have been generated by AI.
Questions this record answers
- What happened in McNeal v. United Food and Commercial Workers Local 555; Safeway, Inc.?
- The court issued a formal warning to the pro se plaintiff regarding the citation of a fabricated case, noting it was likely generated by AI. The court reminded the plaintiff of the obligation under Rule 11 to verify the existence and validity of all legal authorities cited in court filings.
- Why does McNeal v. United Food and Commercial Workers Local 555; Safeway, Inc. matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in D. Oregon, with the listed outcome: Warning.
- What does the public record establish about McNeal v. United Food and Commercial Workers Local 555; Safeway, Inc.?
- 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 McNeal v. United Food and Commercial Workers Local 555; Safeway, Inc. 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.