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Incident Tracker / United States (federal)

Thomas v. Pangburn, No. 4:23-cv-00046-RSB-CLR (CV423-046) (S.D. Ga.)

·US District Court, Southern District of Georgia (Savannah Division)·US-FEDDismissal

In the Southern District of Georgia, Magistrate Judge Christopher L. Ray found that pro se plaintiff Jerry Thomas cited ten nonexistent cases and never explained their origin, recommended dismissal of his amended complaint as a Rule 11(b) sanction while declining monetary sanctions; District Judge R. Stan Baker adopted the recommendation on January 29, 2024.

Court
US District Court, Southern District of Georgia (Savannah Division)
Date
2023-10-06
Who used the AI
Litigant in person
AI tool
Not identified in the record
Conduct
Pro se plaintiff Jerry Thomas's filings cited ten cases that did not exist but were formatted to look legitimate; after two show-cause orders he apologised but never explained their origin. Magistrate Judge Christopher L. Ray found bad faith and recommended dismissal of the amended complaint as a Rule 11(b) sanction (in addition to judicial immunity), declining monetary sanctions; District Judge R. Stan Baker adopted the recommendation on Jan 29, 2024.
Outcome
Dismissal
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

  • non-existent local rule 55.1 — cited as authority in Thomas’s consolidation response
  • Casanova v. United States, No. 1:18-cv-0276-AT, 2019 WL 2051772 (N.D. Ga. May 9, 2019) — illusory; case number and Westlaw citation led elsewhere
  • Edwards v. O’Riordan, No. 1:18-cv-00553-AT, 2019 WL 1429833 (N.D. Ga. March 29, 2019) — no matching Northern District or Westlaw case
  • Williams v. Real Estate Mortgage Network, Inc., No. 1:17-cv-02368-ELR, 2018 WL 3855047 (N.D. Ga. Aug. 14, 2018) — case number and Westlaw citation led elsewhere
  • Touchstone v. Georgia Department of Corrections, 2:16-cv-00183-WCO, 2016 WL 3460748 (N.D. Ga. June 24, 2016) — no relevant Northern District case or Westlaw result
  • Trosper v. DeKalb County, No. 1:13-cv-03626-WSD, 2015 WL 11920138 (N.D. Ga. Aug. 18, 2015) — case number and Westlaw citation led elsewhere
  • In re Tylenol (Acetaminophen) Mktg., Sales Practices and Prods. Liab. Litig., 906 F. Supp. 2d 976 (E.D. Pa. 2012) — reporter citation was inaccurate and no default-consolidation order was found
  • Lavelle v. Bank of America, N.A., 2020 WL 4360202 (D.N.J. July 30, 2020) — no such case caption found
  • TCA Global Credit Master Fund, LP v. LLC, 2017 WL 2696588 (D.N.J. June 22, 2017) — Westlaw citation returned no results; docket searches were fruitless
  • Lyman v. Town of Boxford, 2015 WL 11234050 (D. Mass. Aug. 14, 2015) — Westlaw citation led to an Eastern District of Arkansas case and docket searches were fruitless
  • Kass v. Canola, 2014 WL 2920569 (D. Del. June 25, 2014) — Westlaw citation led to an administrative decision and docket searches were fruitless

What the court said

“Because they are formally indistinguishable from proper citations, but lack any discernable connection to actual authority, the Court is concerned that Thomas intended them to be deceptive.”
US District Court, Southern District of Georgia (Savannah Division), Doc. 15 p. 3
“The presentation to the Court of a brief supported by citations which do not lead to any valid authority but are designed to appear valid might imply either an “improper purpose” or a complete failure to conduct an “investigation reasonable under the circumstances.””
US District Court, Southern District of Georgia (Savannah Division), Doc. 15 p. 13
“The Court finds Plaintiff has engaged in bad faith by “delaying or disrupting the litigation [through the fictitious citations and by] hampering enforcement of a court order.””
US District Court, Southern District of Georgia (Savannah Division), Doc. 59 p. 16
“The Court believes that dismissal is an appropriate sanction that is sufficient to “deter repetition of the conduct or comparable conduct by other similarly situated.””
US District Court, Southern District of Georgia (Savannah Division), Doc. 59 p. 17

Timeline

  1. Thomas filed two Section 1983 cases against Judge Pangburn.
  2. Court found case-like citations that did not lead to valid authority and ordered a Rule 11 response.
  3. Court directed Thomas to explain how the erroneous citations appeared in his submissions.
  4. Court extended the response deadline to August 1 and warned dismissal could follow.
  5. Magistrate judge recommended dismissal as a Rule 11 sanction and declined money sanctions.
  6. District judge adopted the recommendation and dismissed the amended complaint.

Why this case matters

Thomas is the federal pro se counterpart to Morgan, but with a fuller source-checking record. The May order traced each citation to wrong case numbers, unrelated Westlaw entries or no docket result. The October recommendation then treated the unanswered origin question as part of the sanction analysis. Unlike Ex parte Lee, the result was not only waiver of an inadequately briefed appeal; after repeated show-cause orders, the court found bad faith and recommended dismissal. Compared with Mata v Avianca, the court chose no money sanction and no professional referral, yet still used Rule 11 to end the case.

Practice note

A litigant who cites authority should keep a source trail for each case: reporter page, database result, docket number and the proposition being used. If a judge orders an explanation for invalid citations, the response must identify the research source and how each error entered the filing. An apology without that audit left the court unable to treat the citations as excusable mistakes.

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, “Thomas v. Pangburn, No. 4:23-cv-00046-RSB-CLR (CV423-046) (S.D. Ga.)”, safelegalai.com/tracker/thomas-v-pangburn (accessed 2026-10-07). Data: CC BY 4.0.

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