Ng v. AmGuard Insurance Company, et al.
S.D. New York · Dec 29, 2025
What happened in this matter?
The Court issued a formal warning to a pro se litigant for including a fabricated case citation in a court filing, which the Court attributed to the potential use of generative AI. The Judge warned that future submissions of nonexistent authorities could lead to sanctions, including dismissal.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited 'Greyhound-Thermalink, Inc. v. B.U.R. Realty Corp., 42 A.D.3d 319, 320 (N.Y. 1st Dep’t 2007)', which the Court's research found does not appear to exist; Court warned about AI-generated fake citations.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
Why this matter is tracked
In a civil action, the pro se plaintiff submitted a brief containing a citation to 'Greyhound-Thermalink, Inc. v. B.U.R. Realty Corp., 42 A.D.3d 319, 320 (N.Y. 1st Dep’t 2007)'. The Court's research indicated that this case does not exist. The Magistrate Judge noted that generative AI tools are known to produce fabricated citations and warned the plaintiff that submitting such material is unacceptable. The Court explicitly cautioned that future filings containing citations to nonexistent cases may result in sanctions, including the striking of submissions, filing restrictions, monetary penalties, or dismissal of the case. The Court also reminded all parties of the local requirement to disclose and verify the use of generative AI in court filings.
This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The Court attributed the fake citation to ChatGPT or similar AI programs.
Opinion and Order on motions to vacate Clerk’s Certificates of Default.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited 'Greyhound-Thermalink, Inc. v. B.U.R. Realty Corp., 42 A.D.3d 319, 320 (N.Y. 1st Dep’t 2007)', which the Court's research found does not appear to exist; Court warned about AI-generated fake citations.
Questions this record answers
- What happened in Ng v. AmGuard Insurance Company, et al.?
- The Court issued a formal warning to a pro se litigant for including a fabricated case citation in a court filing, which the Court attributed to the potential use of generative AI. The Judge warned that future submissions of nonexistent authorities could lead to sanctions, including dismissal.
- Why does Ng v. AmGuard Insurance Company, et al. matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
- What does the public record establish about Ng v. AmGuard Insurance Company, et al.?
- 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.
- Which source supports this Ng v. AmGuard Insurance Company, 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
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.