Incident Tracker / United States (federal)
Carter v. City of Buffalo, No. 25-CV-740 (W.D.N.Y.)
·US District Court, Western District of New York·US-FEDWarning
In the US District Court for the Western District of New York, self-represented plaintiff Zakkiyya Carter used case law the court said did not support her propositions, after an earlier screening order. Judge John L. Sinatra Jr. believed AI may have prepared the amended complaint and warned future misuse could trigger sanctions.
- Court
- US District Court, Western District of New York
- Date
- 2026-09-08
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Self-represented plaintiff Zakkiyya Carter filed an amended complaint using case law that the court said did not support her propositions. The court believed artificial intelligence may have been used to prepare the filing and warned that any future misuse could result in sanctions.
- Outcome
- Warning
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-11
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Similar incidents on the record
- Ashmeade v. Amazon.com Services LLC, No. 7:23-cv-04331-KMK-VR (S.D.N.Y.)2026-08-27 · US District Court, Southern District of New York · WarningIn 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…
- Johnson v. Nationstar Mortgage LLC, No. 1:25-cv-00855-JRR (D. Md.)2026-08-26 · US District Court, District of Maryland · WarningIn the District of Maryland, self-represented plaintiff Darrin Johnson again cited a case the court could not locate, after an earlier Rule 11 warning. Judge Rubin said the authority appeared to be hallucinated from gen…
- Potterf v. Wessels, No. 1:26-cv-10860-MFL-PTM (E.D. Mich.)2026-08-26 · US District Court, Eastern District of Michigan · WarningIn the Eastern District of Michigan, self-represented plaintiffs admitted using artificial intelligence to draft objections with fictitious or erroneous citations and an invented Supreme Court quotation. Judge Leitman d…
- Booker v. U.S. Bank National Association (In re Booker), No. 3:25-cv-01205-VDO (D. Conn.)2026-08-05 · US District Court for the District of Connecticut · WarningThe US District Court for the District of Connecticut formally admonished a self-represented bankruptcy appellant under Rule 11 after finding six nonexistent cases and invented quotations in his briefs, despite his clai…
Summary record: the facts above are verified against the listed sources, but the court's reasoning and later dispositions have not yet been written up. It is excluded from search indexes until that is done.
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Carter v. City of Buffalo, No. 25-CV-740 (W.D.N.Y.)”, safelegalai.com/tracker/carter-v-city-of-buffalo (accessed 2026-09-11). Data: CC BY 4.0.