Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao
D. Oregon · Apr 10, 2026 · Michael H. Simon
What happened in this matter?
The court identified four fabricated case citations in the plaintiff's filings, attributing them to the use of an AI tool. The court did not impose monetary sanctions for this conduct, but it formally noted the hallucinations in its order and granted the defendants' motions to dismiss the underlying claims on other procedural and substantive grounds.
- Why the court cared
- The court reasoned that the cited cases do not exist and that their inclusion resulted from the plaintiff's use of AI tools, which are known to hallucinate. The court cited the national attention surrounding the submission of fictitious cases to courts to contextualize the issue.
- Why it matters now
- This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It highlights that courts are actively identifying and documenting the use of non-existent authorities, even when they do not impose formal monetary sanctions for the conduct.
Why this matter is tracked
In a contract dispute, the pro se plaintiff submitted filings containing four fabricated case citations: Hernandez v. Cnty. of Yamhill, U.S. Bank Nat’l Ass’n v. Taylor, Johns v. County of Douglas, and McNeil v. United States. The District Court for the District of Oregon identified these as AI-generated hallucinations. While the court granted the defendants' motions to dismiss the underlying claims for failure to state a claim and lack of personal jurisdiction, it did not impose monetary sanctions for the fake citations. Instead, the court used the order to admonish the plaintiff regarding the necessity of verifying AI-generated legal research and provided the plaintiff an opportunity to amend the complaint to address identified pleading deficiencies.
This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It highlights that courts are actively identifying and documenting the use of non-existent authorities, even when they do not impose formal monetary sanctions for the conduct.
Record details
What the record establishes about AI use
The court attributed the false citations to the use of an AI tool.
The court granted the defendants' motions to dismiss and denied the plaintiff's motions to strike, while granting the plaintiff leave to amend the complaint by April 27, 2026.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited a non-existent case; the court found Hernandez v. Cnty. of Yamhill (2017) does not exist and treated it as an AI-generated fabricated citation.
- Fabricated: Case Law | Plaintiff cited a non-existent case; the court found U.S. Bank Nat’l Ass’n v. Taylor (2015) does not exist and treated it as an AI-generated fabricated citation.
- Fabricated: Case Law | Plaintiff cited a non-existent case; the court found Johns v. County of Douglas (2013) does not exist and treated it as an AI-generated fabricated citation.
- Fabricated: Case Law | Plaintiff cited a non-existent case; the court found McNeil v. United States (2015) does not exist and treated it as an AI-generated fabricated citation.
Questions this record answers
- What happened in Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao?
- The court identified four fabricated case citations in the plaintiff's filings, attributing them to the use of an AI tool. The court did not impose monetary sanctions for this conduct, but it formally noted the hallucinations in its order and granted the defendants' motions to dismiss the underlying claims on other procedural and substantive grounds.
- Why does Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao matter for legal AI risk?
- This case illustrates judicial scrutiny of pro se filings for AI-generated hallucinations. It highlights that courts are actively identifying and documenting the use of non-existent authorities, even when they do not impose formal monetary sanctions for the conduct.
- What does the public record establish about Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao 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.