Randolph v. Erick Berscheid Trucking, LLC et al
D. Minnesotta · May 5, 2026
- Jurisdiction
- federal
- Court
- D. Minnesotta
- Record ID
- randolph-v-erick-berscheid-trucking-llc-et-al-2026-05-05
- Observed outcome
- The Court denied the plaintiff's motions and issued a formal warning regarding the submission of fabricated citations and quotes.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court issued a formal warning to a pro se litigant after finding that his filings included fabricated case citations and false quotations, which the Court attributed to the unverified use of generative AI. The Court reminded the litigant of his obligations under Rule 11 to ensure legal contentions are warranted by existing law.
The Court reasoned that the plaintiff's inclusion of non-existent cases and false quotes violated the duty under Fed. R. Civ. P. 11(b)(2) to certify that legal contentions are warranted by existing law after a reasonable inquiry.
This case highlights judicial scrutiny of pro se filings involving AI-generated hallucinations. It serves as a reminder that all litigants, regardless of representation status, are bound by Rule 11 to verify the accuracy of citations and quotes before submission.
Failure modes and consequences
- Fabricated Case Law
- False Quotations
- Pro Se
- Fake Citations
- Fabricated Quotes
- Contract
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The Court denied the plaintiff's motions for reconsideration and to vacate, while simultaneously issuing a warning regarding the quality of the plaintiff's legal research and filings.
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 suggested the use of generative AI.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or 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.