McNeal v. United Food and Commercial Workers Local 555; Safeway, Inc.
D. Oregon · Jan 22, 2026
- Jurisdiction
- federal
- Court
- D. Oregon
- Record ID
- mcneal-v-united-food-and-commercial-workers-local-555-safeway-inc-2026-01-22
- Observed outcome
- The court issued a formal warning to the pro se plaintiff regarding the use of fabricated legal authority.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in D. Oregon, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Employment
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Opinion and Order on Defendants' motions to dismiss the plaintiff's second amended complaint.
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 noted the citation may have been created by a generative AI tool.
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.