Owens v. Select Portfolio Servicing, Inc.
E.D. New York · Jun 4, 2026
- Jurisdiction
- federal
- Court
- E.D. New York
- Record ID
- owens-v-select-portfolio-servicing-inc-2026-06-04
- Observed outcome
- The court granted in part and denied in part the motion to dismiss and issued a formal warning to the plaintiff regarding the use of AI in legal filings.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to the pro se plaintiff regarding the use of AI-generated legal research after identifying fabricated citations and inaccurate case law quotations in the plaintiff's filings. The court cautioned that further violations of Rule 11(b) would result in sanctions, including potential summary dismissal.
The court reasoned that the plaintiff's use of fake or misleading citations violated Federal Rule of Civil Procedure 11(b), which requires legal arguments to be warranted by existing law, and noted that such conduct wastes the time of the opposing party and the court.
This case illustrates judicial enforcement of Rule 11(b) standards against pro se litigants who use AI tools to generate legal research. It highlights the court's expectation that all filers must verify the accuracy of AI-generated citations and quotations.
Failure modes and consequences
- Hallucinated_case_law
- Fabricated_citations
- Inaccurate_quotations
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Implied
- Recorded tool
- unspecified
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum Decision and Order on defendant's motion to dismiss under Federal Rule of Civil Procedure 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 court attributed the errors to the plaintiff's reliance on AI without specifying a tool.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or 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.