Scott M. Boger v. City of Harrisonburg, Virginia, et al.
W.D. Virginia · Dec 9, 2025
What happened in this matter?
The court issued a formal warning to the pro se plaintiff regarding the submission of fabricated and misrepresented legal citations, which the court attributed to the likely use of generative AI. The court explicitly stated that future instances of such conduct may trigger Rule 11 sanction proceedings.
- Why the court cared
- Misrepresented: Case Law | Plaintiff cited 'Snider Int’l Corp. v. City of Norfolk, 739 F.3d 140, 150 (4th Cir. 2014)'; the court could not identify a case by that name and noted the reporter corresponds to Snider Int’l Corp. v. Town of Forest Heights, Md., 739 F.3d 140, which does not support plaintiff's assertion. || False Quotes: Case Law | Plaintiff quoted language he attributed to Connelly v. Steel Valley Sch. Dist., 706 F.3d 209, 216 (3d Cir. 2013); the court found the quoted language appears to have been fabricated and does not appear in that opinion.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in W.D. Virginia, with the listed outcome: Warning.
Why this matter is tracked
In a memorandum opinion denying a pro se plaintiff's motions to amend his complaint, the court addressed the plaintiff's use of fabricated and misrepresented legal citations. The court identified that the plaintiff cited a non-existent case and fabricated quotes attributed to a Third Circuit opinion. The court noted that these errors likely resulted from the use of generative artificial intelligence. While the court did not impose formal sanctions at this time, it issued a formal warning to the plaintiff, stating that future filings containing fabricated or misrepresented authorities may result in an order to show cause why Rule 11 sanctions should not be imposed.
This record documents a Pro Se Litigant filing issue in W.D. Virginia, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court attributed the errors to generative artificial intelligence.
Memorandum opinion denying plaintiff's motion to alter or amend judgment and motions for leave to file third and fourth amended complaints.
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.
- Misrepresented: Case Law | Plaintiff cited 'Snider Int’l Corp. v. City of Norfolk, 739 F.3d 140, 150 (4th Cir. 2014)'; the court could not identify a case by that name and noted the reporter corresponds to Snider Int’l Corp. v. Town of Forest Heights, Md., 739 F.3d 140, which does not support plaintiff's assertion.
- False Quotes: Case Law | Plaintiff quoted language he attributed to Connelly v. Steel Valley Sch. Dist., 706 F.3d 209, 216 (3d Cir. 2013); the court found the quoted language appears to have been fabricated and does not appear in that opinion.
Questions this record answers
- What happened in Scott M. Boger v. City of Harrisonburg, Virginia, et al.?
- The court issued a formal warning to the pro se plaintiff regarding the submission of fabricated and misrepresented legal citations, which the court attributed to the likely use of generative AI. The court explicitly stated that future instances of such conduct may trigger Rule 11 sanction proceedings.
- Why does Scott M. Boger v. City of Harrisonburg, Virginia, et al. matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in W.D. Virginia, with the listed outcome: Warning.
- What does the public record establish about Scott M. Boger v. City of Harrisonburg, Virginia, et al.?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Scott M. Boger v. City of Harrisonburg, Virginia, et al. 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.