Y.S. v. John Doe et al.
D. Colorado · Nov 19, 2025
What happened in this matter?
The court issued a formal warning to a pro se litigant after finding that he submitted multiple fabricated and misrepresented legal citations in support of his motion for expedited discovery. The court attributed these errors to the likely use of AI tools and warned that further non-compliance with Rule 11 obligations could lead to sanctions, including dismissal.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited 'In re Subpoena to Coinbase, Inc., No. 17-MC-80244, 2018 WL 1898913, at *4 (N.D. Cal. Apr. 19, 2018)' to support delayed notice; the court found this cited opinion does not exist. || Fabricated: Case Law | Plaintiff cited 'In re Subpoena to Coinbase, Inc., 2023 WL 177977, at 2 (N.D. Cal. Jan. 12, 2023)'; the court could not locate this citation on Westlaw and noted only an unrelated CourtListener docket for 'In re: Coinbase, Inc.' (23-1779). || Misrepresented: Case Law | Plaintiff relied on Strike 3 Holdings, LLC v. Doe, 964 F.3d 1203 (D.C. Cir. 2020) as approving 'delayed notice' to prevent targets from knowing of subpoenas; the court observed Strike 3 contains no discussion of preventing a subpoena target from learning of the subpoena and therefore does not support plaintiff's proposition. || Misrepresented: Case Law | Plaintiff cited Hard Drive Productions, Inc., 809 F. Supp. 2d 1150 (N.D. Cal. 2011) as supporting nondisclosure/delayed notice; the court found Hard Drive authorized notice to subscribers (the opposite of delayed notice) and does not support plaintiff's position. || Misrepresented: Case Law | Plaintiff cited Arista Records LLC v. Does 1-27, 584 F. Supp. 2d 240, 254 (D.D.C. 2008) to argue courts approved email service for early discovery; the court noted Arista is a decision from the District of Maine (584 F. Supp. 2d 240 (D. Me. 2008)) and did not address Rule 45 email service, so the citation was both jurisdictionally and substantively mischaracterized.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Warning.
Why this matter is tracked
In a pro se civil action, the court denied the plaintiff's motion for expedited discovery and nondisclosure orders. The court identified multiple instances where the plaintiff cited nonexistent case law or misrepresented the holdings of real cases to support his arguments for delayed notice and email service of subpoenas. The court explicitly noted that these errors may stem from the use of artificial intelligence, which is known to hallucinate citations. The magistrate judge issued a formal warning to the plaintiff regarding his obligations under Federal Rule of Civil Procedure 11, cautioning that continued submission of fabricated or improperly attributed legal authority could result in sanctions, including monetary penalties, the striking of filings, or dismissal of the action.
This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court explicitly mentions the suspected use of AI to assist with drafting.
Order denying plaintiff's motion for expedited discovery and nondisclosure, issued by a magistrate judge following multiple supplemental filings.
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 Subpoena to Coinbase, Inc., No. 17-MC-80244, 2018 WL 1898913, at *4 (N.D. Cal. Apr. 19, 2018)' to support delayed notice; the court found this cited opinion does not exist.
- Fabricated: Case Law | Plaintiff cited 'In re Subpoena to Coinbase, Inc., 2023 WL 177977, at 2 (N.D. Cal. Jan. 12, 2023)'; the court could not locate this citation on Westlaw and noted only an unrelated CourtListener docket for 'In re: Coinbase, Inc.' (23-1779).
- Misrepresented: Case Law | Plaintiff relied on Strike 3 Holdings, LLC v. Doe, 964 F.3d 1203 (D.C. Cir. 2020) as approving 'delayed notice' to prevent targets from knowing of subpoenas; the court observed Strike 3 contains no discussion of preventing a subpoena target from learning of the subpoena and therefore does not support plaintiff's proposition.
- Misrepresented: Case Law | Plaintiff cited Hard Drive Productions, Inc., 809 F. Supp. 2d 1150 (N.D. Cal. 2011) as supporting nondisclosure/delayed notice; the court found Hard Drive authorized notice to subscribers (the opposite of delayed notice) and does not support plaintiff's position.
- Misrepresented: Case Law | Plaintiff cited Arista Records LLC v. Does 1-27, 584 F. Supp. 2d 240, 254 (D.D.C. 2008) to argue courts approved email service for early discovery; the court noted Arista is a decision from the District of Maine (584 F. Supp. 2d 240 (D. Me. 2008)) and did not address Rule 45 email service, so the citation was both jurisdictionally and substantively mischaracterized.
Questions this record answers
- What happened in Y.S. v. John Doe et al.?
- The court issued a formal warning to a pro se litigant after finding that he submitted multiple fabricated and misrepresented legal citations in support of his motion for expedited discovery. The court attributed these errors to the likely use of AI tools and warned that further non-compliance with Rule 11 obligations could lead to sanctions, including dismissal.
- Why does Y.S. v. John Doe et al. matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in D. Colorado, with the listed outcome: Warning.
- What does the public record establish about Y.S. v. John Doe 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 Y.S. v. John Doe 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.