Polanco v. Himalayan Real Estate LLC, et al.
E.D. New York · May 27, 2026 · Hector Gonzalez
- Jurisdiction
- federal
- Court
- E.D. New York
- Record ID
- polanco-v-himalayan-real-estate-llc-et-al-2026-05-27
- Observed outcome
- The complaint was dismissed, and the Plaintiff was formally warned that future citations to nonexistent authority could result in sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court issued a formal warning to a pro se litigant for citing a fictitious Supreme Court opinion. The judge cautioned that continued reliance on nonexistent legal authority in future filings could lead to sanctions, including monetary penalties, the striking of submissions, or the imposition of filing restrictions.
The Court reasoned that citing fake opinions is an abuse of the adversary system that wastes judicial resources and harms the legal system's reputation. It noted that while pro se litigants are granted leniency, they are not excused from the obligation to cite genuine legal authorities.
This case illustrates judicial intolerance for fake citations in pro se filings. It serves as a reminder that courts will actively police the integrity of legal research, even when performed by non-lawyers, and will impose escalating sanctions for the use of fabricated precedents.
Failure modes and consequences
- Pro Se
- Fake Citations
- Contract
- Trial
- Warning
- AI attribution
- Reported
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The Court dismissed the pro se complaint sua sponte under 28 U.S.C. § 1915(e)(2)(B) for lack of subject matter jurisdiction and failure to state a claim, while simultaneously issuing a warning regarding the use of fake legal citations.
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
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
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 to cross-reference all cited case law against authoritative legal databases.
- Establish a review protocol for pro se filings to identify and flag potential 'hallucinated' or non-existent citations early in the litigation process.
- Maintain a record of judicial warnings regarding citation integrity to inform future risk assessments for similar filings.