Polinski v. USA
Court of Federal Claims · Oct 15, 2025
- Jurisdiction
- federal
- Court
- Court of Federal Claims
- Record ID
- polinski-v-usa-2025-10-15
- Observed outcome
- The court dismissed the complaint as frivolous and issued a warning regarding the plaintiff's use of AI-hallucinated case citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Civil Rights
- Trial
- Warning
- AI attribution
- Explicitly Recorded
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court dismissed the plaintiff's complaint and denied his motion to proceed in forma pauperis, while also denying numerous procedural motions as moot.
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 explicitly identified the use of artificial intelligence in drafting.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.