Paige Warthen v. Barclays Bank Delaware (Warthen I, II, III)
D. Maryland · Jul 13, 2026 · Matthew J. Maddox
- Jurisdiction
- federal
- Court
- D. Maryland
- Record ID
- paige-warthen-v-barclays-bank-delaware-warthen-i-ii-iii-2026-07-13
- Observed outcome
- The Court denied the Plaintiff's motions to seal and for sanctions, and issued a formal warning regarding the citation of non-existent legal authority.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Contract
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 references the risk of 'AI-hallucinated' authority in the context of the Plaintiff's citation.
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
- Implement automated verification checks for all legal citations in filings to ensure they correspond to existing rules and statutes.
- Establish internal review protocols for pro se filings to identify potential reliance on hallucinated or non-existent legal authority.
- Monitor court dockets for judicial warnings regarding citation accuracy to mitigate risk of future sanctions.