Sehra Waheed v. SM 1 MMS, LLC, et al.
S.D. New York · Oct 28, 2025
What happened in this matter?
The court identified a likely AI-generated hallucination in a pro se filing, specifically a non-existent case citation. While the court noted this as a potential AI hallucination, it did not impose a formal sanction, instead using the observation to support its recommendation to deny the plaintiff's motion for preliminary injunctive relief.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited 'Hughes v. Tennessee Department of Corrections, No. 3:20-cv-00670 (M.D. Tenn. June 11, 2021)'; the court was unable to locate the case in research databases and suggested it may be an AI-generated hallucination.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: no adjudicated outcome recorded.
Why this matter is tracked
In a report and recommendation regarding a pro se plaintiff's motion for preliminary injunctive relief, the U.S. Magistrate Judge addressed the plaintiff's citation of 'Hughes v. Tennessee Department of Corrections, No. 3:20-cv-00670 (M.D. Tenn. June 11, 2021).' The court reported that it was unable to locate this case in any legal research database or the relevant district's electronic filing system. Noting that the plaintiff had also misstated the holdings of other cited cases, the court suggested that the citation was likely a hallucination generated by artificial intelligence. The court ultimately recommended denying the plaintiff's motion for interim monetary payments, finding that the plaintiff failed to meet the requirements for preliminary injunctive relief.
This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: no adjudicated outcome recorded.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Report and Recommendation on Plaintiff's Emergency Motion for Interim Payments.
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 cited 'Hughes v. Tennessee Department of Corrections, No. 3:20-cv-00670 (M.D. Tenn. June 11, 2021)'; the court was unable to locate the case in research databases and suggested it may be an AI-generated hallucination.
Questions this record answers
- What happened in Sehra Waheed v. SM 1 MMS, LLC, et al.?
- The court identified a likely AI-generated hallucination in a pro se filing, specifically a non-existent case citation. While the court noted this as a potential AI hallucination, it did not impose a formal sanction, instead using the observation to support its recommendation to deny the plaintiff's motion for preliminary injunctive relief.
- Why does Sehra Waheed v. SM 1 MMS, LLC, et al. matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in S.D. New York, with the listed outcome: no adjudicated outcome recorded.
- What does the public record establish about Sehra Waheed v. SM 1 MMS, LLC, 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 Sehra Waheed v. SM 1 MMS, LLC, 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.