Al-Ali v. CVS Pharmacy, Inc.

What the court wrote

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

First, Plaintiff's objections contain numerous factitious citations. For example, Plaintiff quotes 9 U.S.C. § 5, but the quote is inaccurate. Additionally, Plaintiff purportedly cites cases such as “Cottman Transmission Sys., Inc. v. Metro. Pontiac GMC, Inc., 351 F. Supp. 2d 343, 347 (E.D. Pa. 2004)” and “McMahon v. RMS Electronics, Inc., 951 F. Supp. 923, 925 (S.D.N.Y. 1997),” but these cases do not exist. ... As set forth previously in this opinion, Plaintiff's objections contained factitious citations. These factitious citations appear to be created by generative artificial intelligence (“AI”) tools. ... Nevertheless, “a pro se litigant must not provide the Court with erroneous and factitious citations and has an obligation to review documents filed with the Court to make certain they are scrupulously accurate.” ... The Court warns Plaintiff that, in the future, even one factitious citation will not be tolerated and that she may be sanctioned if future filings contain factitious citations, including but not limited to striking of filings or monetary penalties. The Court warns Plaintiff that factitious citations include case citations to nonexistent cases, but also case citations that, while real, do not stand for their asserted proposition. Plaintiff has an obligation to ensure that she does not submit any factitious citations in the future.

Authorities cited in the passage: 9 U.S.C. § 5 · Cottman Transmission Sys., Inc. v. Metro. Pontiac GMC, Inc., 351 F. Supp. 2d 343 (E.D. Pa. 2004) · McMahon v. RMS Electronics, Inc., 951 F. Supp. 923 (S.D.N.Y. 1997) · United States v. Hayes, 763 F. Supp. 3d 1054 (E.D. Cal. 2025) · Everett J. Prescott, Inc. v. Beall, 2025 WL 2084353 (D. Me. July 24, 2025) · Whiting v. City of Athens, 170 F.4th 455 (6th Cir. 2026) · Ali v. IT People Corp., Inc., 2025 WL 2682622 (E.D. Mich. Sept. 19, 2025)