Incident Tracker / United States (federal)
Booker v. U.S. Bank National Association (In re Booker), No. 3:25-cv-01205-VDO (D. Conn.)
·US District Court for the District of Connecticut·US-FEDWarning
The 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 claim to have cross-checked four AI platforms. Judge Vernon Oliver dismissed the appeal on the merits and affirmed the bankruptcy court's order.
- Court
- US District Court for the District of Connecticut
- Date
- 2026-08-05
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Self-represented bankruptcy appellant Ulish Kerry Terrace Booker III filed briefs containing six fabricated cases and multiple false quotations. He said he had cross-checked his research across four AI platforms; the court inferred that generative AI produced the fabrications.
- Outcome
- Warning
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
What was fabricated or misused
- Federal Rule of Civil Procedure § 17(a), "every action shall be prosecuted in the name of the real party in interest"; incorrect quote
- Fed. R. Bankr. P. § 9011(b) prohibits filing papers "for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation"; incorrect quote from Fed. R. Civ. P. 11
- BCB Contracting Services, LLC v. United States, 104 B.R. 771, 775 (S.D. Ariz. 2021); nonexistent case
- In re Gorges, 590 B.R. 771 (Bankr. D. Ariz. 2018); erroneous citation, because the case is from Michigan
- In re Mann, 513 B.R. 34, 42-43 (Bankr. E.D.N.Y. 2014); nonexistent case
- Carter v. Flagler Hospital, Inc., 411 B.R. 730 (Bankr. S.D. Fla. 2009); erroneous citation, because the case is from M.D. Fla.
- Torres v. First Nat. Bank of Connecticut, 201 Conn. 247, 251 (1991); nonexistent case
- In re Nassau, 411 B.R. 730 (S.D. Fla. 2009); erroneous citation to In re Carter
- Mathews v. Dillon, 489 U.S. 567 (1989); nonexistent case
- Boyd, v. Connecticut, 2022 Conn. Dist. LEXIS 10098140 (D. Conn. Aug. 24 2022); nonexistent case with Lexis number that does not exist
- In re Sherry Easley, 2022 Bankr. LEXIS 10455845 (Bankr. D. Conn. Mar. 30 2022); nonexistent case
- Baerga v. Hartford, 2022 Conn. Dist. LEXIS 10098455 (D. Conn. Nov. l0 2022); erroneous citation with inaccurate Lexis number
What the court said
“In sum, the Court was able to identify at least two inaccurate quotes, four erroneous citations, and six fabricated cases.”
“Booker III’s briefs are riddled with hallucinations, clearly indicating the use of generative artificial intelligence in drafting them.”
“Rule 11, however, requires more than reliance on AI-generated output or cursory review; it requires a reasonable inquiry into the legal and factual basis of every filing before it is presented to the Court.”
“The Court therefore declines to strike the briefs. Instead, the Court concludes that a formal admonishment and warning appropriately balance the seriousness of Booker III’s conduct with Rule 11’s deterrent purpose.”
Timeline
- Booker III filed a Chapter 7 bankruptcy case.
- Booker III filed his notice of appeal.
- Booker III filed his appellant brief.
- Court issued an order to show cause after finding hallucinations.
- Booker III responded to the show-cause order.
- Court held the show-cause hearing.
- Court admonished Booker III, warned him and dismissed the appeal.
Why this case matters
Booker is the District of Connecticut's self-represented-litigant counterpart to Andre v Warden and differs from A.P. v S.K. in scale. The appellant said he checked across several AI products, but the court treated cross-checking AI with more AI as no verification at all. The sanction was an admonishment, not dismissal or a fine, because it was the first time this court had confronted Booker about AI use and the appeal failed on the merits. The record helps define a lower-end Rule 11 response where hallucinations are numerous but the party is pro se.
Practice note
A pro se appellant should verify cited cases the same way a lawyer must: open the decision in an official database, read the cited page, and confirm the quote. Searching the same answer in Gemini, Perplexity, another legal AI tool or ChatGPT is not an independent check. Keep the verified source with the draft before filing.
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, “Booker v. U.S. Bank National Association (In re Booker), No. 3:25-cv-01205-VDO (D. Conn.)”, safelegalai.com/tracker/in-re-booker-d-conn (accessed 2026-10-07). Data: CC BY 4.0.