Sana Hazina Butler v. Fidelity Management & Research Company LLC
S.D. New York · Apr 30, 2026
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- sana-hazina-butler-v-fidelity-management-research-company-llc-2026-04-30
- Observed outcome
- The court denied the plaintiff's request for administrative corrections and issued a formal warning regarding the submission of inaccurate legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Contract
- Trial
- AI attribution
- Explicitly Recorded
- Recorded tool
- generative AI tools
- Known monetary consequence
- Not recorded
- Procedural posture
- Order issued by a Magistrate Judge in response to a pro se plaintiff's letter requesting administrative docket corrections.
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 attributed the errors to the plaintiff's use of generative AI tools.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.