Sana Hazina Butler v. Fidelity Management & Research Company LLC
S.D. New York · Apr 30, 2026
What happened in this matter?
The court issued a formal warning to a pro se litigant after finding that the plaintiff submitted filings containing fabricated case law, false quotations, and misrepresented holdings, which the court attributed to the use of generative AI tools.
- Why the court cared
- The court reasoned that while the presentation of false citations and holdings is sanctionable conduct, the plaintiff's pro se status warranted a warning rather than formal sanctions, while emphasizing the obligation of all litigants to verify the accuracy of cited authorities.
- Why it matters now
- This case illustrates the judicial response to AI-generated hallucinations in pro se filings, reinforcing that the duty of candor and the requirement to verify legal authority apply to all litigants, regardless of representation status.
Why this matter is tracked
In a pro se civil action, the plaintiff filed a letter requesting administrative corrections to the docket. The court denied the request, noting that the complaint was already properly identified. During review, the court identified that the plaintiff's filing contained five citations to cases that did not support the cited propositions, quotations from three cases that did not appear in the cited opinions, and one citation to a nonexistent judicial opinion. The court attributed these errors to the plaintiff's use of generative AI tools. While the court noted that such conduct is sanctionable, it declined to impose formal sanctions due to the plaintiff's pro se status, instead issuing a formal warning regarding future submissions.
This case illustrates the judicial response to AI-generated hallucinations in pro se filings, reinforcing that the duty of candor and the requirement to verify legal authority apply to all litigants, regardless of representation status.
Record details
What the record establishes about AI use
The court attributed the errors to the plaintiff's use of generative AI tools.
Order issued by a Magistrate Judge in response to a pro se plaintiff's letter requesting administrative docket corrections.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Plaintiff cited Maersk, Inc. v. Neewra, Inc. with quoted language the court determined does not appear in that opinion; case exists but does not support the cited proposition.
- Misrepresented: Case Law | Plaintiff cited Parisie v. Greer, which exists but the court noted it has nothing to do with removal (misstated relevance).
- Misrepresented: Case Law | Plaintiff cited Whitaker v. American Telecasting, which involves removal but does not support the specific proposition about filing a removed complaint as an exhibit; court noted misstatement of holding.
- Fabricated: Case Law | Plaintiff cited 'Rong Zhu v. BNP Paribas, 997 F. Supp. 2d 242 (S.D.N.Y. 2014)', which the court found does not exist.
- False Quotes: Case Law | Plaintiff attributed quoted language to Granny Goose Foods, but the court found the quoted language does not appear in that opinion; case exists but does not support the cited proposition.
- False Quotes: Case Law | Plaintiff cited Azer v. Connell and included quoted language the court found does not appear in the opinion; case exists but the quote is not in it and it is unrelated to the removal issue cited.
Questions this record answers
- What happened in Sana Hazina Butler v. Fidelity Management & Research Company LLC?
- The court issued a formal warning to a pro se litigant after finding that the plaintiff submitted filings containing fabricated case law, false quotations, and misrepresented holdings, which the court attributed to the use of generative AI tools.
- Why does Sana Hazina Butler v. Fidelity Management & Research Company LLC matter for legal AI risk?
- This case illustrates the judicial response to AI-generated hallucinations in pro se filings, reinforcing that the duty of candor and the requirement to verify legal authority apply to all litigants, regardless of representation status.
- What does the public record establish about Sana Hazina Butler v. Fidelity Management & Research Company LLC?
- 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 Sana Hazina Butler v. Fidelity Management & Research Company LLC 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.