Nelson Lin v. The Honorable Jonathan H. Shim, et al.
S.D. New York · Apr 9, 2025
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- nelson-lin-v-the-honorable-jonathan-h-shim-et-al-2025-04-09
- Observed outcome
- The court granted the defendants' motions to dismiss the complaint in its entirety.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fabricated Case Law
- Pro Se
- Fake Citations
- Civil Rights
- Trial
- None Adjudicated
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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).
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 record implies AI usage through the presence of fabricated citations.
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.
- 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.