Smith v. Clarence Smith et al.
N.D. New York · Dec 22, 2025
- Jurisdiction
- federal
- Court
- N.D. New York
- Record ID
- smith-v-clarence-smith-et-al-2025-12-22
- Observed outcome
- The court issued a formal warning to the plaintiff regarding the use of hallucinated case law and potential future sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in N.D. New York, with the listed outcome: Warning.
Failure modes and consequences
- Hallucinated_case_law
- Misrepresented_case_law
- Pro Se
- Fake Citations
- Misrepresented Authority
- Civil Rights
- AI attribution
- Implied
- Recorded tool
- unspecified generative AI
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court identified the style and syntax as characteristic of generative AI.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.