Ryan Lee v. Capital One Bank et al.
D. Utah · Feb 24, 2026
- Jurisdiction
- federal
- Court
- D. Utah
- Record ID
- ryan-lee-v-capital-one-bank-et-al-2026-02-24
- Observed outcome
- The court recommended dismissal of the complaint and issued a formal warning to the plaintiff regarding the quality and accuracy of AI-assisted filings.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to a pro se litigant regarding the use of generative AI in court filings. The Magistrate Judge admonished the plaintiff to ensure the accuracy of legal citations and representations, warning that future misrepresentations could result in sanctions under Federal Rule of Civil Procedure 11.
The court reasoned that under Fed. R. Civ. P. 11, all litigants, including those appearing pro se, must certify that their filings are based on reasonable inquiry and are supported by existing law. The court found that the plaintiff's reliance on AI resulted in defective citations and misstatements, necessitating an admonition to prevent future procedural abuse.
This record documents a Pro Se Litigant filing issue in D. Utah, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Contract
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Report and Recommendation on a Motion to Dismiss.
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 refers to the plaintiff's use of generative AI.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all legal citations generated by AI tools.
- Ensure pro se litigants are informed of their ongoing duty of candor and Rule 11 obligations regarding AI-assisted submissions.
- Monitor docket filings for patterns of defective citations that may indicate reliance on unverified AI output.