Perry v. Merrick Bank Corporation
D. Arizona · Jun 9, 2026
What happened in this matter?
The court did not impose sanctions in this specific case. However, it formally noted the plaintiff's prior use of hallucinated citations and fake quotations in a separate litigation (Perry v. Exeter Finance LLC) as evidence of a pattern of conduct justifying the denial of leave to amend the complaint.
- Why the court cared
- The court reasoned that leave to amend should be denied because the plaintiff's complaint was meritless and part of a pattern of vexatious litigation, citing the plaintiff's prior submission of hallucinated citations and fake quotations in Perry v. Exeter Finance LLC as evidence of this pattern.
- Why it matters now
- This case illustrates how courts track and document a litigant's history of submitting AI-hallucinated or fabricated legal authorities across different dockets. It highlights that such conduct, even if not sanctioned in the immediate case, can influence judicial discretion regarding procedural requests like leave to amend.
Why this matter is tracked
In this federal action, the District Court for the District of Arizona granted the defendant's motion to dismiss a pro se complaint. The court determined that the plaintiff's claims were barred by collateral estoppel, as the underlying issues had been fully litigated and resolved in a prior arbitration proceeding. In its analysis of the plaintiff's request for leave to amend, the court noted a pattern of vexatious litigation tactics. Specifically, the court referenced the plaintiff's conduct in a separate recent matter, Perry v. Exeter Finance LLC, where the court identified that the plaintiff had submitted filings containing at least one hallucinated case citation and fake quotations misattributed to real legal authorities.
This case illustrates how courts track and document a litigant's history of submitting AI-hallucinated or fabricated legal authorities across different dockets. It highlights that such conduct, even if not sanctioned in the immediate case, can influence judicial discretion regarding procedural requests like leave to amend.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
The court granted the defendant's motion to dismiss the plaintiff's complaint with prejudice, denying the plaintiff's request for leave to amend.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Court noted Plaintiff previously filed at least one 'hallucinated citation' (a fabricated case citation) in prior litigation (Perry v. Exeter Finance LLC).
- False Quotes: Case Law | Court noted Plaintiff previously included 'fake quotations' misattributed to real cases in prior filings (Perry v. Exeter Finance LLC).
Questions this record answers
- What happened in Perry v. Merrick Bank Corporation?
- The court did not impose sanctions in this specific case. However, it formally noted the plaintiff's prior use of hallucinated citations and fake quotations in a separate litigation (Perry v. Exeter Finance LLC) as evidence of a pattern of conduct justifying the denial of leave to amend the complaint.
- Why does Perry v. Merrick Bank Corporation matter for legal AI risk?
- This case illustrates how courts track and document a litigant's history of submitting AI-hallucinated or fabricated legal authorities across different dockets. It highlights that such conduct, even if not sanctioned in the immediate case, can influence judicial discretion regarding procedural requests like leave to amend.
- What does the public record establish about Perry v. Merrick Bank Corporation?
- 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 Perry v. Merrick Bank Corporation 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.