Incident Tracker / United States (state)
Jurkowski v. Berkowitz
·Superior Court of the District of Columbia, Civil Division·US-STATEWarningprovisional
The Superior Court of the District of Columbia on 2026-04-21 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Jurkowski v. Berkowitz. The self-represented plaintiff filed a pleading with one fabricated case citation and one mischaracterized case citation.
- Court
- Superior Court of the District of Columbia, Civil Division
- Date
- 2026-04-21
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Jurkowski’s pro se proposed second amended complaint and other filings appeared AI-constructed; the proposed complaint cited nonexistent Chisholm v. Kidder Peabody Asset Mgmt., Inc., 810 A.2d 900 (D.C. 2002), and cited Jonathan Woodner Co. v. Breeden for a distinction that case does not discuss.
- Outcome
- Warning
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-07
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, “Jurkowski v. Berkowitz”, safelegalai.com/tracker/jurkowski-v-berkowitz (accessed 2026-10-07). Data: CC BY 4.0.