Sample et al v. Hilton Worldwide Holdings, Inc
D. New Mexico · May 26, 2026
What happened in this matter?
The court issued a formal warning to pro se plaintiffs after they submitted a filing containing a fabricated case citation and a false quote. The court clarified that while it provides leeway to pro se litigants, it does not tolerate the use of nonexistent or misleading legal authorities in court filings.
- Why the court cared
- The court reasoned that the plaintiffs' cited case identifier did not exist and the quoted language was absent from the actual Tenth Circuit opinion. It further held that pro se status does not excuse the submission of fabricated or misleading authorities.
- Why it matters now
- This case illustrates judicial intolerance for fabricated legal research, even when presented by pro se litigants. It reinforces the standard that all parties, regardless of representation, are responsible for the accuracy of their cited authorities.
Why this matter is tracked
In a civil rights action, pro se plaintiffs filed a Rule 72(a) objection to a magistrate judge's order striking their motion for ADA accommodations. In their objection, plaintiffs cited 'Gonzales v. Qwest Commc’ns, 2005 WL 366290 (D. Colo.)' and quoted language regarding responses to objections. The district court found the cited database identifier does not exist and the quoted language does not appear in the actual Tenth Circuit decision. The court overruled the objection, noting that while it makes allowances for pro se litigants, it does not excuse the use of fabricated or misleading authorities. The court issued a formal warning that future filings containing citations to nonexistent cases may result in sanctions, including striking filings, filing restrictions, or dismissal.
This case illustrates judicial intolerance for fabricated legal research, even when presented by pro se litigants. It reinforces the standard that all parties, regardless of representation, are responsible for the accuracy of their cited authorities.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
District court order overruling plaintiffs' Rule 72(a) objection to a magistrate judge's order.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiffs cited 'Gonzales v. Qwest Commc’ns, 2005 WL 366290 (D. Colo.)' using a database identifier that does not appear attached to an existing case.
- False Quotes: Case Law | Plaintiffs quoted 'Responses to objections are required unless the court orders otherwise' as from Gonzales, but the court found that language does not appear in the Tenth Circuit decision.
Questions this record answers
- What happened in Sample et al v. Hilton Worldwide Holdings, Inc?
- The court issued a formal warning to pro se plaintiffs after they submitted a filing containing a fabricated case citation and a false quote. The court clarified that while it provides leeway to pro se litigants, it does not tolerate the use of nonexistent or misleading legal authorities in court filings.
- Why does Sample et al v. Hilton Worldwide Holdings, Inc matter for legal AI risk?
- This case illustrates judicial intolerance for fabricated legal research, even when presented by pro se litigants. It reinforces the standard that all parties, regardless of representation, are responsible for the accuracy of their cited authorities.
- What does the public record establish about Sample et al v. Hilton Worldwide Holdings, Inc?
- 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.
- Which source supports this Sample et al v. Hilton Worldwide Holdings, Inc 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.