Nonnie Berg v. United Airlines, Inc. (1)
D. Colorado · Oct 30, 2025
- Jurisdiction
- federal
- Court
- D. Colorado
- Record ID
- nonnie-berg-v-united-airlines-inc-1-2025-10-30
- Observed outcome
- The court overruled the plaintiff's objection, adopted the Magistrate Judge's recommendation, and issued a formal warning regarding future AI-related conduct.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Other
- Trial
- Warning
- AI attribution
- Explicitly Recorded
- Recorded tool
- Generative artificial intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- District court review of a Magistrate Judge's Order and Recommendation following a pro se plaintiff's objection.
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 explicitly referenced the plaintiff's misuse of generative artificial intelligence.
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.