McKeown v. Paycom Payroll LLC
- Party
- Pro Se Litigant
- AI Tool
- Implied / unconfirmed
Hallucinated Content
Fabricated
- Case Law
Plaintiff previously filed a brief citing non-existent legal authority; the Court issued a warning against falsified citations (Dkt. 18).
- Case Law
Plaintiff's sur-reply cited a non-existent case; the Court found the citation fictitious and noted the closest real case does not support the asserted proposition.
Outcome
Notes
AI UseAlthough AI was not named and Plaintiff denied intentional fabrication, the court considered the citation (Adamov, 779 F.3d 851, 860 (8th Cir. 2015)) to be plainly fictitious. It noted the possibility that Plaintiff used generative AI tools, given the fabricated citation's plausible-sounding structure and mismatch with existing precedent.Hallucination DetailsPlaintiff submitted fabricated legal authorities in at least two filings, despite being explicitly warned by the court after the first incident. The false case cited in her sur-reply could not be located in any legal database. When asked to produce it, she responded that she had likely “garbled” the citation but provided no plausible alternative or correction.Ruling/SanctionThe court declined to dismiss the action as a sanction, citing the limitations pro se litigants face in accessing reliable legal research tools. However, it granted the defendant’s motion to strike Plaintiff’s two unauthorized sur-replies and formally warned her that further violations of Rule 11 would lead to sanctions, including monetary penalties, filing restrictions, or dismissal.
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