Steven Nemec v. Kelsey Kanoelani Alao and Alyssa Jade Alao
D. Oregon · Apr 10, 2026 · Michael H. Simon
- Jurisdiction
- federal
- Court
- D. Oregon
- Record ID
- steven-nemec-v-kelsey-kanoelani-alao-and-alyssa-jade-alao-2026-04-10
- Observed outcome
- The court granted the defendants' motions to dismiss the complaint and denied the plaintiff's motions to strike, while allowing the plaintiff to file an amended complaint.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Contract
- Trial
- None Adjudicated
- AI attribution
- Implied
- Recorded tool
- AI (e.g., ChatGPT)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 attributed the false citations to the use of an AI tool.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.