Smith v. Clarence Smith et al.
N.D. New York · Dec 22, 2025
What happened in this matter?
The court issued a formal warning to a pro se litigant for submitting filings containing fabricated and misrepresented case law, which the court attributed to the misuse of generative AI. The court explicitly warned that continued reliance on hallucinated legal authority in future filings could result in sanctions, including dismissal or monetary penalties.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited 'In re D.C. Judicial Conflicts of Interest, 540 F.2d 711 (D.C. Cir. 1976),' which the court found does not exist and is a fabricated citation. || Fabricated: Case Law | Plaintiff cited 'In re B.W., 352 F.3d 29 (2d Cir. 2003),' which the court determined does not exist and appears to be AI-generated. || Fabricated: Case Law | Plaintiff cited 'Wilkinson v. United States, 13 F.3d 855 (2d Cir. 1994),' which the court found to be nonexistent and unrelated to any real opinion at that reporter citation. || Misrepresented: Case Law | Plaintiff mis-cited Keir v. Schoeberl with an incorrect Westlaw citation ('2025 WL 1123456'); the court identified the correct citation as 2025 WL 437953, noting continued mis-citation of authority. || Misrepresented: Case Law | Plaintiff mis-cited Bennett v. Mnuchin with an incorrect Westlaw citation ('2020 WL 3214565'); the court noted the correct citation is 2020 WL 4432662, indicating miscitation rather than a substantive supporting authority.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in N.D. New York, with the listed outcome: Warning.
Why this matter is tracked
In a civil rights action, the N.D. New York district court identified that the pro se plaintiff submitted filings containing fabricated and misrepresented case law, likely generated by artificial intelligence. The court noted the plaintiff's use of nonexistent citations, such as 'In re D.C. Judicial Conflicts of Interest,' and incorrect Westlaw citations for existing cases. While the court acknowledged the liberal construction afforded to pro se litigants, it determined that the reliance on hallucinated authority violated the duty to confirm the validity of legal citations under Rule 11. Consequently, the court issued a formal warning to the plaintiff, advising that future submissions containing fabricated or hallucinated legal authority may result in sanctions, including monetary penalties or dismissal of the action.
This record documents a Pro Se Litigant filing issue in N.D. New York, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court identified the style and syntax as characteristic of generative AI.
The court adopted a magistrate judge's report-recommendation, denied the plaintiff's motion for reconsideration, and referred the amended complaint for further review of pleading sufficiency.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited 'In re D.C. Judicial Conflicts of Interest, 540 F.2d 711 (D.C. Cir. 1976),' which the court found does not exist and is a fabricated citation.
- Fabricated: Case Law | Plaintiff cited 'In re B.W., 352 F.3d 29 (2d Cir. 2003),' which the court determined does not exist and appears to be AI-generated.
- Fabricated: Case Law | Plaintiff cited 'Wilkinson v. United States, 13 F.3d 855 (2d Cir. 1994),' which the court found to be nonexistent and unrelated to any real opinion at that reporter citation.
- Misrepresented: Case Law | Plaintiff mis-cited Keir v. Schoeberl with an incorrect Westlaw citation ('2025 WL 1123456'); the court identified the correct citation as 2025 WL 437953, noting continued mis-citation of authority.
- Misrepresented: Case Law | Plaintiff mis-cited Bennett v. Mnuchin with an incorrect Westlaw citation ('2020 WL 3214565'); the court noted the correct citation is 2020 WL 4432662, indicating miscitation rather than a substantive supporting authority.
Questions this record answers
- What happened in Smith v. Clarence Smith et al.?
- The court issued a formal warning to a pro se litigant for submitting filings containing fabricated and misrepresented case law, which the court attributed to the misuse of generative AI. The court explicitly warned that continued reliance on hallucinated legal authority in future filings could result in sanctions, including dismissal or monetary penalties.
- Why does Smith v. Clarence Smith et al. matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in N.D. New York, with the listed outcome: Warning.
- What does the public record establish about Smith v. Clarence Smith 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 Smith v. Clarence Smith 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.