Viral Bhagat v. Anuja Sharad Shah
S.D. New York · Apr 6, 2026
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- viral-bhagat-v-anuja-sharad-shah-2026-04-06
- Observed outcome
- The court issued a formal admonishment to the pro se defendant regarding the duty to verify legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court admonished a pro se litigant for submitting an AI-generated fabricated case citation. The magistrate judge concluded the citation was a hallucination after failing to locate the case or the quoted text in Westlaw or on the docket, explicitly reminding the litigant of the duty to verify all cited authorities.
The court reasoned that the defendant's cited case did not exist in the form provided and the quoted text could not be located in any Westlaw database, leading to the conclusion that the citation was an AI-generated hallucination.
This case illustrates the judicial response to AI-generated hallucinations in pro se filings. It reinforces that courts expect all litigants, regardless of representation status, to verify the existence and accuracy of legal authorities, and that failure to do so may result in formal judicial admonishment.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Other
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- unspecified
- Known monetary consequence
- Not recorded
- Procedural posture
- Order issued by Magistrate Judge Robyn F. Tarnofsky on April 6, 2026, resolving multiple pending motions, including an order to show cause regarding a previously ordered but unfiled case citation.
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 error to the use of AI-generated filings.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or 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.