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Incident Tracker / United States (federal)

Ashmeade v. Amazon.com Services LLC, No. 7:23-cv-04331-KMK-VR (S.D.N.Y.)

·US District Court, Southern District of New York·US-FEDWarning

In the Southern District of New York, self-represented plaintiff Keith Ashmeade cited two nonexistent Southern District decisions while litigating discovery issues against Amazon. Magistrate Judge Reznik identified the false citations, warned that future filings with false or nonexistent legal authorities may draw sanctions, and tied the warning to Rule 11 duties for pro se litigants.

Court
US District Court, Southern District of New York
Date
2026-08-27
Who used the AI
Litigant in person
AI tool
Not identified in the record
Conduct
Self-represented plaintiff Keith Ashmeade cited two nonexistent Southern District of New York decisions in discovery briefing. The court identified the false authorities, pointed to Rule 11 obligations for pro se litigants, and warned that future submissions containing false or nonexistent authorities may result in sanctions.
Outcome
Warning
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • In re State Street Bank and Trust Co. ERISA Litig., No. 07-cv-10907, 2009 WL 10260136, at *1 (S.D.N.Y. Apr. 8, 2009) — no decision matched the citation as cited
  • SEC v. Collins, No. 01-cv-3065, 2002 WL 31109065, at *4 (S.D.N.Y. Sept. 23, 2002) — no decision matched the citation as cited; SEC v. Collins & Aikman Corp., 256 F.R.D. 403 had a different caption, docket number, date and citation

What the court said

“Plaintiff’s submission cites two authorities that do not exist as cited.”
US District Court, Southern District of New York, p. 1
“The likely explanation is Plaintiff’s use of generative AI in litigating this case, which he has previously acknowledged to the Court.”
US District Court, Southern District of New York, p. 2
“The problem is submitting its output to the Court without verifying its accuracy.”
US District Court, Southern District of New York, p. 2
“Plaintiff is therefore warned that any future submission containing false or nonexistent legal authorities may result in sanctions.”
US District Court, Southern District of New York, p. 2

Timeline

  1. PIVOT Plan later became part of the metadata and native-file discovery dispute.
  2. Parties submitted the joint discovery letter containing the challenged citations.
  3. Court identified two nonexistent authorities and warned that future false citations may be sanctioned.

Why this case matters

Ashmeade adds a pro se discovery-order example from the same district that produced Mata v Avianca. The false citations did not decide the discovery disputes, and the court still resolved the requests. The order is useful because it states the Rule 11 duty in plain terms for an unrepresented party: AI-assisted work may be used, but cited authorities must exist and support the point offered. It also shows the court distinguishing a real, possibly relevant case from the nonexistent citation actually filed.

Practice note

For discovery letters, verify even short case citations before filing. Match the caption, docket number, reporter or Westlaw citation, date and holding. If AI points to a similar real case, cite the real case accurately and explain its relevance instead of filing a mismatched citation.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Ashmeade v. Amazon.com Services LLC, No. 7:23-cv-04331-KMK-VR (S.D.N.Y.)”, safelegalai.com/tracker/ashmeade-v-amazon (accessed 2026-10-07). Data: CC BY 4.0.

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