Incident Tracker / United States (federal)
Morgan v. Community Against Violence, No. 1:23-cv-00353-WPJ/JMR (D.N.M.)
·US District Court, District of New Mexico·US-FEDWarning
In the District of New Mexico, Chief Judge William P. Johnson found that pro se plaintiff Sorchè Morgan cited several fake or nonexistent opinions in her response brief, issued a final warning that further nonexistent citations could bring sanctions including dismissal, and in January 2024 dismissed the case with prejudice after finding more hallucinated cases. No monetary penalty.
- Court
- US District Court, District of New Mexico
- Date
- 2023-10-23
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Pro se plaintiff Sorchè Morgan's response to a motion to dismiss cited several fake or nonexistent opinions, including a fabricated New Mexico case and four citations pointing to unrelated real cases. Chief Judge William P. Johnson warned that future nonexistent citations could bring striking, filing restrictions or dismissal; the case was dismissed with prejudice on Jan 19, 2024 after further hallucinated citations were found.
- 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
- Doe v. United Airlines, Inc., 754 F.3d 576 (7th Cir. 2014) — actually Young v. Builders Steel Co., 754 F.3d 573 (8th Cir. 2014)
- EEOC v. Lockheed Martin Corp., 116 F. Supp. 3d 734 (E.D. Pa. 2015) — actually Caldwell ex rel. La. v. Bristol Myers Squibb Sanofi Pharms. Holding P’ship, 116 F. Supp. 3d 727 (W.D. La. 2015)
- Beck v. University of Kansas Medical Center, 953 F.3d 1215, 1224 (l0th Cir. 2020) — actually United States v. Goldman, 953 F.3d 1213 (11th Cir. 2020)
- Las Cruces Sun-News v. City of Las Cruces (2003-NMCA-099) — nonexistent; actually State v. Foster, 2003-NMCA-099, 134 N.M. 224, 75 P.3d 824 (N.M. Ct. App. 2003)
- Secretary of Labor v. Mega-Construction Co. (2018) — no such case exists
- Linton v. Comm’r of Social Sec., 2014 WL 505984 (D.N.M. Feb. 5, 2014) — no Linton case from the District of New Mexico
- Smith v. United States — quotation attributed to Smith produced no results
- Ortega v. Royer Corp., 151 F. Supp. 3d 1167, 1170 (D.N.M. 2015) — no such District of New Mexico case; citation redirected to Cascadia Wildlands v. Woodruff
- Chavez v. City of Albuquerque, 150 F. Supp. 3d 1196, 1206 (D.N.M. 2015) — nonexistent; citation redirected to Camp Richardson Resort, Inc. v. Phila. Indemnity Ins. Co.
- Tatum v. Oklahoma City, 441 F.3d 1212 (10th Cir. 2006) — fake; actually United States v. Apperson, 441 F.3d 1162 (10th Cir. 2006)
- Chilson v. Experian Information Solutions, Inc., 829 F.3d 869 (10th Cir. 2016) — no such Tenth Circuit case; actually Flournoy v. City of Chicago, 829 F.3d 869 (7th Cir. 2016)
What the court said
“Although courts “make some allowances for the pro se Plaintiff’s failure to cite to proper legal authority,” courts do not make allowances for a Plaintiff who cites to fake, nonexistent, misleading authorities.”
“Any future filings with citations to nonexistent cases may result in sanctions such as the pleading being stricken, filing restrictions imposed, or the case being dismissed.”
“Instead, however, the Court found additional citations to “hallucinated” cases.”
“These factors overwhelmingly favor filing restrictions.”
Timeline
- Court dismissed many claims and warned that future nonexistent citations could bring sanctions.
- Court dismissed the amended complaint with prejudice after finding additional hallucinated cases.
- Court struck post-judgment filings and ordered Morgan to show cause on filing restrictions.
Why this case matters
Morgan extends the 2023 hallucinated-authority pattern beyond lawyer discipline. Unlike Mata v Avianca and Ex parte Lee, the filer was a self-represented civil plaintiff and the false material recurred after direct caution from the court. Together with Thomas v Pangburn, it shows federal judges using Rule 11 and docket-control tools when pro se filings supply case-like citations no database can verify. The District of New Mexico first gave cautionary guidance, then dismissed with prejudice and considered a narrow filing injunction after post-judgment filings. That sequence makes the record more than a warning: fabricated citations affected case management even without a named AI tool.
Practice note
Before filing in federal court, a pro se litigant should open every case in an official reporter or court database, confirm the case name, citation, court, date and quoted point, and delete anything that cannot be verified. After a court warning, the next filing should contain only authorities checked by the filer and should meet local response deadlines; generated text is not a substitute for that check.
Primary sources for this incident
- Morgan v. Community Against Violence, No. 23-cv-353-WPJ/JMR (D.N.M. Oct. 23, 2023), Memorandum Opinion and Order (Doc. 32) — govinfo.gov
- Morgan v. Community Against Violence, No. 23-cv-353-WPJ/JMR (D.N.M. Jan. 19, 2024), Memorandum Opinion and Order granting dismissal (Doc. 35) — govinfo.gov
- Morgan v. Community Against Violence, No. 23-cv-353-WPJ/JMR (D.N.M. Feb. 15, 2024), Order to show cause re filing restrictions (Doc. 41) — govinfo.gov
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, “Morgan v. Community Against Violence, No. 1:23-cv-00353-WPJ/JMR (D.N.M.)”, safelegalai.com/tracker/morgan-v-community-against-violence (accessed 2026-10-07). Data: CC BY 4.0.