Paige Warthen v. Barclays Bank Delaware (Warthen I, II, III)
D. Maryland · Jul 13, 2026 · Matthew J. Maddox
What happened in this matter?
The Court issued a formal warning to the pro se litigant regarding the citation of non-existent legal authority, specifically 'Fed. R. Civ. P. 5.2(a)(5).' The Court clarified that such conduct is sanctionable and referenced case law concerning the use of AI-hallucinated or otherwise fabricated legal authority in court filings.
- Why the court cared
- The Court reasoned that the cited rule, Fed. R. Civ. P. 5.2(a)(5), does not exist and that the Plaintiff's reliance on it to demand redaction of personal contact information was meritless. The Court further reasoned that pro se status does not excuse the citation of fake or misleading authorities, justifying a formal warning to deter future misconduct.
- Why it matters now
- This case illustrates judicial vigilance against the use of fabricated legal citations in pro se filings. It reinforces that courts will not tolerate the submission of non-existent authorities, even from self-represented litigants, and may issue formal warnings to prevent further procedural abuse.
Why this matter is tracked
In a consolidated action involving pro se litigant Paige Elizabeth (formerly Paige Warthen), the District of Maryland addressed multiple motions, including requests to seal records and impose sanctions. The Court denied the Plaintiff's motions, noting that her reliance on 'Fed. R. Civ. P. 5.2(a)(5)' to demand redaction of her address was improper because that subsection does not exist. The Court explicitly warned the Plaintiff that citing non-existent legal authority is sanctionable, citing relevant precedent regarding the misuse of AI-hallucinated or fabricated legal authority. The Court further dismissed the Plaintiff's third action (Warthen III) for failure to state a claim and consolidated the remaining two actions, holding jurisdictional questions in abeyance pending supplemental briefing.
This case illustrates judicial vigilance against the use of fabricated legal citations in pro se filings. It reinforces that courts will not tolerate the submission of non-existent authorities, even from self-represented litigants, and may issue formal warnings to prevent further procedural abuse.
Record details
What the record establishes about AI use
The Court references the risk of 'AI-hallucinated' authority in the context of the Plaintiff's citation.
Memorandum Opinion resolving multiple pending motions, including motions to seal, for sanctions, to disqualify counsel, and for injunctive relief, while consolidating two actions and dismissing a third.
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: Legal Norm | Plaintiff cited 'Fed. R. Civ. P. 5.2(a)(5)' to demand redaction of her address; the Court found that this subsection does not exist and rejected the sealing request.
Questions this record answers
- What happened in Paige Warthen v. Barclays Bank Delaware (Warthen I, II, III)?
- The Court issued a formal warning to the pro se litigant regarding the citation of non-existent legal authority, specifically 'Fed. R. Civ. P. 5.2(a)(5).' The Court clarified that such conduct is sanctionable and referenced case law concerning the use of AI-hallucinated or otherwise fabricated legal authority in court filings.
- Why does Paige Warthen v. Barclays Bank Delaware (Warthen I, II, III) matter for legal AI risk?
- This case illustrates judicial vigilance against the use of fabricated legal citations in pro se filings. It reinforces that courts will not tolerate the submission of non-existent authorities, even from self-represented litigants, and may issue formal warnings to prevent further procedural abuse.
- What does the public record establish about Paige Warthen v. Barclays Bank Delaware (Warthen I, II, III)?
- 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.
- Which source supports this Paige Warthen v. Barclays Bank Delaware (Warthen I, II, III) 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
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