Polinski v. USA
Court of Federal Claims · Oct 15, 2025
What happened in this matter?
The Court of Federal Claims issued a warning to a pro se litigant for citing AI-hallucinated, non-existent case law in multiple motions. The court determined that the plaintiff's reliance on these fabricated authorities violated Rule 11, which requires parties to confirm the existence and validity of legal authorities, and ultimately dismissed the underlying action as frivolous.
- Why the court cared
- The court reasoned that the plaintiff's citation of fake cases violated Rule 11, which mandates that litigants confirm the existence and validity of legal authorities. The court noted that while AI use itself is not prohibited, the submission of fabricated authorities constitutes an abuse of the adversary system.
- Why it matters now
- This case illustrates judicial enforcement of Rule 11 duties for pro se litigants regarding AI-generated content. It serves as a reminder that courts expect verification of all cited authorities, regardless of the research tools employed.
Why this matter is tracked
Fabricated: Case Law | Plaintiff cited 'Shearson Lehman Bros., Inc. v. Wasatch Bank, 788 P.2d 514 (Utah 1990)' in his Emergency Motion for Declaratory Judgment; the court found no such case and noted the citation appears fictitious and may relate to City of Monticello v. Christensen, 788 P.2d 513 (Utah 1990). Outcome: Warning. "On September 3, 2025, Plaintiff filed his response to the court’s order to file copies of the cases he cited (#7). Therein, Plaintiff avers he took “concrete remedial steps” to cure the time wasted by his use of artificial-intelligence-hallucinated case citations, including “submission of the verified opinions as exhibits” (#7 at 2). Indeed, Plaintiff’s response stresses how he“obtained authentic copies” of those cases and “attached” them as exhibits. See (id.).Plaintiff did not attach any exhibits to his response to this court’s order. The court is convinced that those two case citations are AI-hallucinated. Plaintiff’s insistence that they exist—and that he provided copies of them to this court—is bewildering."
This case illustrates judicial enforcement of Rule 11 duties for pro se litigants regarding AI-generated content. It serves as a reminder that courts expect verification of all cited authorities, regardless of the research tools employed.
Record details
What the record establishes about AI use
The court explicitly identified the use of artificial intelligence in drafting.
The court dismissed the plaintiff's complaint and denied his motion to proceed in forma pauperis, while also denying numerous procedural motions as moot.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited 'Shearson Lehman Bros., Inc. v. Wasatch Bank, 788 P.2d 514 (Utah 1990)' in his Emergency Motion for Declaratory Judgment; the court found no such case and noted the citation appears fictitious and may relate to City of Monticello v. Christensen, 788 P.2d 513 (Utah 1990).
- Fabricated: Case Law | Plaintiff cited 'Ivey v. United States, 2019 WL 2080027 (Fed. Cl. 2019)' in his Emergency Motion to Recognize and Enforce Express Trust; the court found that citation does not lead to any actual document and treated it as a fabricated authority.
- Fabricated: Case Law | Plaintiff cited 'Self v. Ray, 61 F.R.D. 666 (E.D. Ark. 1974)'; the court stated the citation actually corresponds to Young v. Trailwood Lakes, Inc., 61 F.R.D. 666 (E.D. Ky. 1974), indicating a misattributed or fictional citation.
Questions this record answers
- What happened in Polinski v. USA?
- The Court of Federal Claims issued a warning to a pro se litigant for citing AI-hallucinated, non-existent case law in multiple motions. The court determined that the plaintiff's reliance on these fabricated authorities violated Rule 11, which requires parties to confirm the existence and validity of legal authorities, and ultimately dismissed the underlying action as frivolous.
- Why does Polinski v. USA matter for legal AI risk?
- This case illustrates judicial enforcement of Rule 11 duties for pro se litigants regarding AI-generated content. It serves as a reminder that courts expect verification of all cited authorities, regardless of the research tools employed.
- What does the public record establish about Polinski v. USA?
- 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 Polinski v. USA 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.