Romero v. Goldman Sachs Bank USA
S.D. New York · Jun 25, 2025 · Gregory H. Woods
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- romero-v-goldman-sachs-bank-usa-2025-06-25
- Observed outcome
- The court issued a warning regarding Rule 11 obligations and the risks of AI-generated hallucinations, but imposed no sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
Before reaching the motion's merits, the court flagged the unsupported and fictitious authorities and reminded the parties of Rule 11's certification obligation.
The order identifies serious citation defects while preserving the distinction between an AI suspicion and a verified finding of AI use.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Contract
- Trial
- AI attribution
- Implied
- Recorded tool
- generative artificial intelligence
- Known monetary consequence
- Not recorded
- Procedural posture
- Order issued by the court sua sponte following the plaintiff's filing of a motion in limine.
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 referenced the emblems of generative artificial intelligence tools.
The court described emblems of generative-AI use but expressly did not find that Romero had used a generative-AI tool.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify quotations against the original opinion, not a generated summary.
- Confirm a citation's docket, reporter, and subject matter before filing.
- Use a neutral correction process when the source does not establish tool attribution.