Calenzo v. Waste Management, Inc.

What the court wrote

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

As a final matter, the undersigned has been unable to locate or verify several of the cases cited by Plaintiff in support of her opposition to Defendant's motion to dismiss. Specifically, Plaintiff's opposition includes citations to at least four nonexistent judicial opinions: LPD New York, LLC v. Adidas Am., Inc., 2020 WL 1501881 (S.D.N.Y. Mar. 30, 2020); Powell v. Monarch Recovery Mgmt., Inc., 2017 WL 102666 (E.D.N.Y. Mar. 23, 2017); Robertson v, Waste Management, Inc., 2019 WL 1238839 (D. Colo. Mar. 18, 2019); and Snyder v. Ply Gem Indus., Inc., 827 F. Supp. 2d 472 (E.D.N.Y. 2011). ... “Although in ‘some circumstances courts will make some allowances for a pro se [p]laintiff's failure to cite to proper legal authority,’ it is ‘no more acceptable for a pro se litigant to submit briefs with fake case citations than it is for a lawyer to do so.’ ” ... Accordingly, the Court directs Plaintiff to refrain from any further use of hallucinated or fabricated case law in submissions before this Court. Plaintiff is further advised that any future filings containing citations to nonexistent cases may result in sanctions, including the striking of such filings from the record, the imposition of filing restrictions, the issuance of monetary sanctions, or the dismissal of this action.

Authorities cited in the passage: LPD New York, LLC v. Adidas Am., Inc., 2020 WL 1501881 · Powell v. Monarch Recovery Mgmt., Inc., 2017 WL 102666 · Robertson v. Waste Management, Inc., 2019 WL 1238839 · Snyder v. Ply Gem Indus., Inc., 827 F. Supp. 2d 472 · Hodges v. McGough Enters. LLC, 2026 WL 1470246 · Park v. Kim, 91 F.4th 610 (2d Cir. 2024)