Michael Platt v. Volunteers of America Ohio & Indiana

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

U.S. Dist. LEXIS 100748, at *1–4 (adopting in part a report and recommendation and imposing a $6,000 personal sanction where counsel admitted to filing briefs containing fictitious AI-generated citations); Virgil, 2026 U.S. Dist. LEXIS 29090, at *11 (recommending a $10,000 personal sanction for counsel filing five briefs that contained citations to non-existent cases); Salahuddin v. Coughlin, 999 F. Supp. 526, 529 (S.D.N.Y. 1998); Brown v. Lincoln Towing Serv., Inc., No. 88C0831, 1988 WL 93950 (N.D. Ill. 1988); Pravic v. U.S. Indus.-Clearing, 109 F.R.D. 620, 623 (E.D. Mich. 1986). While these cited cases involve attorneys failing to check the treatment and soundness of case citations, many of the principles on which those decisions are based also apply to pro se parties. See, e.g., Tsupko v. Kinetic Advantage, LLC, 2025 WL 2677157, at *5 (S.D. Ind. Sept. 17, 2025) (admonishing pro se plaintiff for citing non-existent caselaw and warning that "any further non-compliance with all applicable Federal Rules of Civil Procedure and the Local Rules of this Court will result in sanctions against him which may include dismissal of this case . . . ."). In consideration of Mr. Platt's pro se status, the Court will not at this time order him to show cause why the fictitious citations identified did not violate Rule 11(b) and why he should not 3 Case 1:25-cv-01866-SEB-KMB Document 27 Filed 03/10/26 Page 4 of 4 PageID #: 112

Authorities cited in the passage: Salahuddin v. Coughlin · Brown v. Lincoln Towing Serv · Pravic v. U.S. Indus.-Clearing · Tsupko v. Kinetic Advantage · Rule 11(b)