Santana v. Shook Hardy & Bacon

What the court wrote

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

As a final matter, the Court addresses Defendants’ concern that Plaintiff's opposition brief contained citations and quotations to non-existent case authority, which they attribute to his use of artificial intelligence (“AI”). Dkt. No. 55 (“Forrest Defs. Repl.”) at 1–2; Dkt. No. 58 (“Shook Defs. Repl.”) at 1. The Shook Defendants urge the Court to sanction Plaintiff, including by striking his opposition and treating the motions as unopposed. ... Forrest Defendants do not seek sanctions pursuant to Rule 11 given that Plaintiff is pro se, but express frustration at the unnecessary resources they spent verifying his inaccurate citations. ... Whether this Court has adopted an individual rule regarding the use of AI or not, Rule 11 requires parties to certify that their legal contentions “are warranted by existing law.” Fed. R. Civ. P. 11. Even though he is proceeding pro se, Plaintiff “is required to comply with the Local Rules and Federal Rules of Civil Procedure.” McClellon v. Rickard, 2026 WL 686499, at *9 (S.D.N.Y. Mar. 11, 2026). Accordingly, whether the deficiencies in Plaintiff's filings stem from his use of AI or some other source, the Court cautions him that future submissions to any court must contain only accurate citations and representations. If they do not—because of AI hallucinating case citations or otherwise—he may be sanctioned, id., although the Court declines to do so now.

Authorities cited in the passage: Fed. R. Civ. P. 11 · McClellon v. Rickard, 2026 WL 686499 (S.D.N.Y. Mar. 11, 2026)