Romero v. Goldman Sachs Bank USA
S.D. New York · Jun 25, 2025 · Gregory H. Woods
What happened in this matter?
The court identified fictitious and misrepresented case citations in a pro se filing. While noting these errors resembled generative AI hallucinations, the court expressly declined to find that the plaintiff used AI and took no immediate sanctioning action, instead issuing a formal warning regarding Rule 11 verification obligations.
- Why the court cared
- Before reaching the motion's merits, the court flagged the unsupported and fictitious authorities and reminded the parties of Rule 11's certification obligation.
- Why it matters now
- The order identifies serious citation defects while preserving the distinction between an AI suspicion and a verified finding of AI use.
Why this matter is tracked
Michael Cordero Romero, proceeding pro se, filed a motion in limine concerning evidence on a motion to compel arbitration. The Southern District of New York found that one cited Second Circuit case did not concern the proposition asserted and did not contain the quoted language, while a second purported Beckford decision appeared wholly fictitious. The court noted the hallmarks of generative-AI hallucination but made no AI finding and took no immediate action because Romero was self-represented. It instead reminded the parties of Rule 11 certification obligations.
The order identifies serious citation defects while preserving the distinction between an AI suspicion and a verified finding of AI use.
Record details
What the record establishes about AI use
The court referenced the emblems of generative artificial intelligence tools.
Order issued by the court sua sponte following the plaintiff's filing of a motion in limine.
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.
- False Quotes: Case Law | Plaintiff attributed a quotation to In re Motors Liquidation Co. that the opinion does not contain.
- Fabricated: Case Law | Plaintiff submitted a fictitious case citation; no case exists at the cited Westlaw citation and the identified Beckford cases are different and unrelated.
- Misrepresented: Case Law | Plaintiff misrepresented In re Motors Liquidation Co. as addressing what evidence may be presented in a reply brief; the case is unrelated to that topic.
Questions this record answers
- What happened in Romero v. Goldman Sachs Bank USA?
- The court identified fictitious and misrepresented case citations in a pro se filing. While noting these errors resembled generative AI hallucinations, the court expressly declined to find that the plaintiff used AI and took no immediate sanctioning action, instead issuing a formal warning regarding Rule 11 verification obligations.
- Why does Romero v. Goldman Sachs Bank USA matter for legal AI risk?
- The order identifies serious citation defects while preserving the distinction between an AI suspicion and a verified finding of AI use.
- What does the public record establish about Romero v. Goldman Sachs Bank USA?
- The court described emblems of generative-AI use but expressly did not find that Romero had used a generative-AI tool.
- Which source supports this Romero v. Goldman Sachs Bank 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.