Megan Cowden v. US Treasury & IRS
E.D. Missouri · Oct 20, 2025
- Jurisdiction
- federal
- Court
- E.D. Missouri
- Record ID
- megan-cowden-v-us-treasury-irs-2025-10-20
- Observed outcome
- The court granted the defendants' Motion to Dismiss with prejudice, citing jurisdictional bars under the AIA and DJA, and issued a warning regarding the plaintiff's citation practices.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court did not impose sanctions. It noted that the plaintiff's filings contained unverified citations and potentially false quotations, suspecting AI generation, and warned that such conduct could violate Rule 11 obligations regarding the accuracy of filings.
The court reasoned that the plaintiff's failure to verify citations and the inclusion of false quotations wasted judicial resources and potentially violated Rule 11, though it stopped short of formal sanctioning.
This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It serves as a reminder that courts are actively monitoring for fabricated citations and quotations, with potential for future Rule 11 consequences.
Failure modes and consequences
- Hallucinated_case_law
- Fabricated_quotations
- Lack_of_verification
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum and Order granting the defendants' Motion to Dismiss with prejudice.
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 suspected the filings were generated by artificial intelligence.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- 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.