Sample et al v. Hilton Worldwide Holdings, Inc
D. New Mexico · May 26, 2026
- Jurisdiction
- federal
- Court
- D. New Mexico
- Record ID
- sample-et-al-v-hilton-worldwide-holdings-inc-2026-05-26
- Observed outcome
- The court overruled the plaintiffs' objection and issued a formal warning regarding the use of fabricated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Civil Rights
- Trial
- Warning
- AI attribution
- Reported
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- District court order overruling plaintiffs' Rule 72(a) objection to a magistrate judge's order.
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
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
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.