Nonnie Berg v. United Airlines, Inc. (1)
D. Colorado · Oct 30, 2025
What happened in this matter?
The court issued a formal warning to the pro se plaintiff regarding the submission of filings containing fabricated legal citations generated by artificial intelligence. The court affirmed the striking of previous filings and cautioned that continued use of AI to generate nonexistent legal authority would lead to more severe sanctions, such as monetary penalties or case dismissal.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited Salt Institute v. Leavitt, 440 F. Supp. 2d 240, 243 (D.D.C. 2006); court could not identify this citation in Westlaw and treated it as an AI-generated, non-existent opinion. || Fabricated: Case Law | Plaintiff cited In re Parke-Davis Sec. Litig., 177 F.R.D. 246, 250 N.6 (E.D. Mich. 1997); court could not verify the citation and treated it as fabricated AI output. || Fabricated: Case Law | Plaintiff cited Koch v. Koch Indus., Inc., 203 F.R.D. 479, 487 (D. Kan. 2011); court could not locate this citation in its database and treated it as a non-existent case likely generated by AI. || Fabricated: Case Law | Plaintiff cited Hodgson v. Mason & Hangar-Silas Mason Co., 545 F. Supp. 1189, 1192 (D. Kan. 1982); court could not identify this citation and considered it an AI-fabricated opinion. || Fabricated: Case Law | Plaintiff cited Smith v. Life Investors Ins. Co. of Am., 245 F.R.D. 580, 584 (D. Kan. 2007); court was unable to verify the citation and treated it as a fabricated case citation from AI-generated content. || Fabricated: Exhibits & Submissions | Plaintiff submitted a medical report (ECF No. 108-3) dated April 27, 2020 that the court found to contain indicia of AI generation (generic language, markdown artifacts, incomplete license info) and could not verify the physician.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Warning.
Why this matter is tracked
Fabricated: Case Law | Plaintiff cited Salt Institute v. Leavitt, 440 F. Supp. 2d 240, 243 (D.D.C. 2006); court could not identify this citation in Westlaw and treated it as an AI-generated, non-existent opinion. Outcome: Warning. In an earlier Report and Reccomendations, the court found that significant portions of the plaintiff's filings copied from an AI program included citations to cases that could not be identified in Westlaw and an apparent AI-generated medical report; the court struck the filings and instructed compliance with Rule 11 and practice standards.
This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court explicitly referenced the plaintiff's misuse of generative artificial intelligence.
District court review of a Magistrate Judge's Order and Recommendation following a pro se plaintiff's objection.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited Salt Institute v. Leavitt, 440 F. Supp. 2d 240, 243 (D.D.C. 2006); court could not identify this citation in Westlaw and treated it as an AI-generated, non-existent opinion.
- Fabricated: Case Law | Plaintiff cited In re Parke-Davis Sec. Litig., 177 F.R.D. 246, 250 N.6 (E.D. Mich. 1997); court could not verify the citation and treated it as fabricated AI output.
- Fabricated: Case Law | Plaintiff cited Koch v. Koch Indus., Inc., 203 F.R.D. 479, 487 (D. Kan. 2011); court could not locate this citation in its database and treated it as a non-existent case likely generated by AI.
- Fabricated: Case Law | Plaintiff cited Hodgson v. Mason & Hangar-Silas Mason Co., 545 F. Supp. 1189, 1192 (D. Kan. 1982); court could not identify this citation and considered it an AI-fabricated opinion.
- Fabricated: Case Law | Plaintiff cited Smith v. Life Investors Ins. Co. of Am., 245 F.R.D. 580, 584 (D. Kan. 2007); court was unable to verify the citation and treated it as a fabricated case citation from AI-generated content.
- Fabricated: Exhibits & Submissions | Plaintiff submitted a medical report (ECF No. 108-3) dated April 27, 2020 that the court found to contain indicia of AI generation (generic language, markdown artifacts, incomplete license info) and could not verify the physician.
Questions this record answers
- What happened in Nonnie Berg v. United Airlines, Inc. (1)?
- The court issued a formal warning to the pro se plaintiff regarding the submission of filings containing fabricated legal citations generated by artificial intelligence. The court affirmed the striking of previous filings and cautioned that continued use of AI to generate nonexistent legal authority would lead to more severe sanctions, such as monetary penalties or case dismissal.
- Why does Nonnie Berg v. United Airlines, Inc. (1) matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Warning.
- What does the public record establish about Nonnie Berg v. United Airlines, Inc. (1)?
- 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 Nonnie Berg v. United Airlines, Inc. (1) 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.