Nelson Lin v. The Honorable Jonathan H. Shim, et al.
S.D. New York · Apr 9, 2025
What happened in this matter?
The court dismissed the plaintiff's complaint for lack of subject-matter jurisdiction and failure to state a claim. It specifically identified and rejected a fabricated case citation ('Hernandez v. Spitzer') provided by the pro se plaintiff, noting that the opinion contains other non-existent citations preserved from the original record.
- Why the court cared
- The court determined that the cited case 'Hernandez v. Spitzer' does not exist and therefore rejected the plaintiff's reliance on it to support his arguments regarding federal court jurisdiction over constitutional torts in custody contexts.
- Why it matters now
- This case highlights the risks of pro se litigants, including those with legal training, submitting AI-generated or otherwise fabricated citations. It serves as a reminder for courts to verify the existence of all cited authorities.
Why this matter is tracked
In this civil rights action, the pro se plaintiff, a lawyer, alleged a conspiracy involving a New York Family Court judge and various private and public defendants regarding custody proceedings. The court granted the defendants' motions to dismiss for lack of subject-matter jurisdiction and failure to state a claim. During the proceedings, the plaintiff cited 'Hernandez v. Spitzer, No. 09-cv-3914, 2010 WL 11586928 (S.D.N.Y. Mar. 29, 2010)' to support his arguments. The court explicitly noted that this case does not exist and rejected the plaintiff's reliance on it. The court's opinion includes an editor's note stating that the decision preserves other incorrect or non-existent citations found in the original record.
This case highlights the risks of pro se litigants, including those with legal training, submitting AI-generated or otherwise fabricated citations. It serves as a reminder for courts to verify the existence of all cited authorities.
Record details
What the record establishes about AI use
The record implies AI usage through the presence of fabricated citations.
The court granted the defendants' motions to dismiss the Second Amended Complaint pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6).
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 cited 'Hernandez v. Spitzer, No. 09-cv-3914, 2010 WL 11586928 (S.D.N.Y. Mar. 29, 2010)'; the court found that this case does not exist and rejected reliance on it.
- Fabricated: Case Law | Editor's Note and court text indicate the opinion contains other incorrect or non-existent citation references preserved from the original record.
Questions this record answers
- What happened in Nelson Lin v. The Honorable Jonathan H. Shim, et al.?
- The court dismissed the plaintiff's complaint for lack of subject-matter jurisdiction and failure to state a claim. It specifically identified and rejected a fabricated case citation ('Hernandez v. Spitzer') provided by the pro se plaintiff, noting that the opinion contains other non-existent citations preserved from the original record.
- Why does Nelson Lin v. The Honorable Jonathan H. Shim, et al. matter for legal AI risk?
- This case highlights the risks of pro se litigants, including those with legal training, submitting AI-generated or otherwise fabricated citations. It serves as a reminder for courts to verify the existence of all cited authorities.
- What does the public record establish about Nelson Lin v. The Honorable Jonathan H. Shim, et al.?
- 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 Nelson Lin v. The Honorable Jonathan H. Shim, et al. 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
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