Sana Hazina Butler v. Fidelity Management & Research Company LLC
S.D. New York · May 22, 2026
What happened in this matter?
The Court issued a formal warning to a pro se litigant for submitting false legal citations. The Magistrate Judge admonished the plaintiff that presenting inaccurate case law is sanctionable conduct, regardless of whether the errors were caused by artificial intelligence or other factors, and warned that future non-compliance could lead to formal sanctions.
- Why the court cared
- The Court reasoned that the presentation of false citations, quotations, and holdings is sanctionable conduct that abuses the adversary system, necessitating a formal warning to ensure future submissions contain only accurate representations.
- Why it matters now
- This case illustrates judicial oversight of pro se filings involving potentially AI-generated or hallucinated legal authority. It reinforces that courts hold litigants responsible for the accuracy of their submissions, regardless of the underlying cause of the error.
Why this matter is tracked
In a civil action before the S.D. New York, the Magistrate Judge issued a warning to a pro se plaintiff regarding the submission of false legal citations. The plaintiff cited 'Rate Technology Inc. v. Speakeasy Inc.' to support a legal argument, but the citation was incorrect and the case actually concerned patent validity and settlement agreements. Although the plaintiff denied using artificial intelligence, the Court admonished the plaintiff that presenting false citations, quotations, or holdings is sanctionable conduct. The Court emphasized that future submissions must contain only accurate representations, regardless of whether errors result from AI or other mistakes. The order also addressed procedural deadlines and granted a stay of discovery.
This case illustrates judicial oversight of pro se filings involving potentially AI-generated or hallucinated legal authority. It reinforces that courts hold litigants responsible for the accuracy of their submissions, regardless of the underlying cause of the error.
Record details
What the record establishes about AI use
The Court noted the plaintiff denied using AI, but referenced the possibility of AI or other mistakes.
Order issued by Magistrate Judge following a status conference regarding discovery stays and the plaintiff's submission of inaccurate legal authority.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Case Law | Plaintiff cited 'Rate Technology Inc. v. Speakeasy Inc.' with an incorrect citation and relied on it for a point; the actual case (Rates Tech. Inc. v. Speakeasy, Inc., 685 F.3d 163 (2d Cir. 2012)) concerns a settlement agreement and patent validity, not the cited proposition.
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 for submitting false legal citations. The Magistrate Judge admonished the plaintiff that presenting inaccurate case law is sanctionable conduct, regardless of whether the errors were caused by artificial intelligence or other factors, and warned that future non-compliance could lead to formal sanctions.
- Why does Sana Hazina Butler v. Fidelity Management & Research Company LLC matter for legal AI risk?
- This case illustrates judicial oversight of pro se filings involving potentially AI-generated or hallucinated legal authority. It reinforces that courts hold litigants responsible for the accuracy of their submissions, regardless of the underlying cause of the error.
- 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.