Sebastian Rako v. VMware LLC (1)
N.D. California · Nov 25, 2025
What happened in this matter?
The court ordered the pro se plaintiff to include a mandatory footnote reading 'Located through AI; Checked' for every future citation in the litigation that was identified using an AI tool, following the plaintiff's submission of fabricated case law in opposition briefs.
- Why the court cared
- Fabricated: Case Law | Plaintiff's opposition briefs cited non-existent case law; Notices of Errata submitted 'corrected' citations that differed substantially from originals; court found likely AI-generated citations.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in N.D. California, with the listed outcome: Order to include a footnote reading 'Located through AI; Checked' for each future citation.
Why this matter is tracked
In a civil rights and employment action, the pro se plaintiff submitted opposition briefs containing non-existent case law. After the defendants identified these errors in their reply briefs, the plaintiff filed 'Notices of Errata' providing 'corrected' citations that differed substantially from the originals. The court determined these were likely AI-generated hallucinations. While the court acknowledged the plaintiff's attempt to correct the record, it expressed concern regarding the failure to verify legal authorities. Consequently, the court ordered that in all future filings, the plaintiff must include a specific footnote for any citation located through an AI tool, confirming the authority was located via AI and that the plaintiff has verified its existence and accuracy.
This record documents a Pro Se Litigant filing issue in N.D. California, with the listed outcome: Order to include a footnote reading 'Located through AI; Checked' for each future citation.
Record details
What the record establishes about AI use
The court refers to AI tools generally.
Order on motions to dismiss; the court granted the defendants' motion to dismiss the False Claims Act retaliation claim with leave to amend and issued a standing order regarding AI-generated citations.
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.
- Fabricated: Case Law | Plaintiff's opposition briefs cited non-existent case law; Notices of Errata submitted 'corrected' citations that differed substantially from originals; court found likely AI-generated citations.
Questions this record answers
- What happened in Sebastian Rako v. VMware LLC (1)?
- The court ordered the pro se plaintiff to include a mandatory footnote reading 'Located through AI; Checked' for every future citation in the litigation that was identified using an AI tool, following the plaintiff's submission of fabricated case law in opposition briefs.
- Why does Sebastian Rako v. VMware LLC (1) matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in N.D. California, with the listed outcome: Order to include a footnote reading 'Located through AI; Checked' for each future citation.
- What does the public record establish about Sebastian Rako v. VMware LLC (1)?
- 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 Sebastian Rako v. VMware LLC (1) 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.