Ng v. AmGuard Insurance Company, et al.
S.D. New York · Dec 29, 2025
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- ng-v-amguard-insurance-company-et-al-2025-12-29
- Observed outcome
- The Court granted the defendants' motions to vacate the Clerk's Certificates of Default and issued a formal warning to the plaintiff regarding the use of AI-generated fake citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Tort
- Trial
- Warning
- AI attribution
- Reported
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Opinion and Order on motions to vacate Clerk’s Certificates of Default.
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 attributed the fake citation to ChatGPT or similar AI programs.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.