Moore v. Wireless CCTV LLC
S.D. Texas · Apr 27, 2026
- Jurisdiction
- federal
- Court
- S.D. Texas
- Record ID
- moore-v-wireless-cctv-llc-2026-04-27
- Observed outcome
- The court granted the motion to dismiss without prejudice and issued a formal warning to the plaintiff regarding her duty to verify legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to the plaintiff after identifying fabricated case law citations in her pleadings, which the court attributed to the use of generative AI. The court reminded the plaintiff of her Rule 11 obligation to verify the validity of all legal authorities cited in her filings.
The court reasoned that the plaintiff's citations were non-existent and that the Westlaw identifier for one citation pointed to an unrelated case, indicating the use of generative AI. The court emphasized that pro se status does not exempt a litigant from the Rule 11 duty to confirm the validity of cited legal authority.
This case highlights the judicial response to AI-generated hallucinations in pro se filings. It reinforces that courts will enforce Rule 11 verification requirements regardless of a party's pro se status and will explicitly identify and warn against the use of fabricated legal authorities.
Failure modes and consequences
- Pro Se
- Fake Citations
- Employment
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum Opinion and Order granting motion to dismiss without prejudice, with leave to amend.
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 identified the use of generative AI based on the presence of non-existent case law.
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
- Implement mandatory verification protocols for all case law citations, regardless of the research source.
- Cross-reference Westlaw/Lexis identifiers against case names to ensure citations are accurate and support the intended legal proposition.
- Establish internal review processes for pro se filings to identify potential AI-generated hallucinations before submission.