Pro se litigants are increasingly using GenAI tools like ChatGPT, Claude, Perplexity, Gemini, or CoPilot to file and maintain lawsuits against their employers – and corporate counsel and defense attorneys need new tools to fight back. We’ve assembled a collection of helpful rulings from the past few months where courts have given relief to defendants against these ChatGPT plaintiffs, laying out a blueprint you can put to use in your cases. While docket searches are replete with examples of courts warning or even admonishing pro se plaintiffs, these rulings provide support for stronger sanctions: monetary penalties, denied motions, and claims dismissals.
Monetary Sanctions
Allen v. Cass Casper (N.D. Ill. March 10, 2026)
- Case Background: A pro se plaintiff sued her former employment attorney for legal malpractice and other related claims, alleging he removed claims from her lawsuit without her consent.
- The AI Misconduct: In opposing a motion to dismiss, the pro se plaintiff submitted a 112-page brief containing at least two entirely fabricated case citations. The court found the brief also contained AI-generated content sections and repeated inaccurate factual assertions unsupported by the record, concluding the plaintiff had over-relied on AI to generate her legal arguments.
- Sanction Imposed: $1,500 payable to the Clerk of the Court for violating Rule 11 of the Federal Rules of Civil Procedure.
- Notable Court Quotes: “Pro se status does not shelter plaintiffs from sanctions pursuant to Rule 11. … Filing a document that contains citations to nonexistent cases, quotes language that comes from no real case, or that contains arguments wholly unsupported by the record violates Rule 11. Allen did just that. This demonstrates that Allen failed to make a reasonable inquiry into the supporting law or facts.”
Brownfield v. Cherokee County School District No. 35 (E.D. Okla. March 19, 2026)
- Case Background: A former substitute teacher and volunteer wrestling coach sued Tahlequah Public Schools and individual administrators under Title IX, Title VII, and the First Amendment, alleging he was retaliated against after reporting gender-based mistreatment of female student athletes.
- The AI Misconduct: While representing himself, the plaintiff filed a Rule 11 sanctions motion against the defendants that contained fictitious and inaccurate case citations generated by AI.
- Sanction Imposed: $500 payable directly to the defendant school district, representing approximately two hours of defense counsel’s billable time spent researching and identifying the bogus citations.
- Notable Court Quote: “The Court finds the Plaintiff’s submission of a pleading containing fictitious cases and inaccurate case references warrants sanctions.”
Hulvat v. Gumina (Ill. App. Ct. April 9, 2026)
- Case Background: A self-represented former husband sued his ex-wife, her divorce attorney, and her law firm for civil conspiracy and related claims.
- The AI Misconduct: The plaintiff’s initial appellate brief contained nine citations to entirely nonexistent cases, including fabricated quotations attributed to a real case that bore no resemblance to the actual opinion. The plaintiff filed an amended brief, which also contained unsupported arguments and illegitimate citations.
- Sanction Imposed: Attorneys’ fees and costs of $3,178 awarded to defendants.
- Notable Court Quotes: “Robert’s reliance on fictitious authority is a pervasive, nascent, and very serious issue afflicting courts as the use and reliance on generative AI in preparing legal filings becomes more commonplace. … Robert’s self-represented status does not excuse his misuse of AI. … A monetary penalty in this context should impress upon all litigants the caution one must undertake when utilizing AI in brief preparation and the solemnity of filing documents before the court.”
Briefs Stricken / Motions Denied
Hardy v. Genesee County Community Action Resource Department, et al. (E.D. Mich. April 6, 2026)
- Case Background: A pro se plaintiff brought a Section 1983 civil rights lawsuit against a social services agency and related defendants.
- The AI Misconduct: The plaintiff’s motion to consolidate several cases cited fabricated quotations attributed to two real 6th Circuit opinions. A companion motion to compel discovery similarly cited a Supreme Court opinion for a proposition that does not appear in that opinion.
- Sanction Imposed: The motion to consolidate was stricken as frivolous and the motion to compel was denied.
- Notable Court Quotes: “Courts and opposing counsel are burdened by the careless use of AI by pro se filers.”
Adams v. Kiewit Infrastructure West Company (D. Ariz. April 29, 2026)
- Case Background: A pro se plaintiff brought suit against an infrastructure contractor and related defendants in federal court in Arizona.
- The AI Misconduct: While moving for leave to file a revised second amended complaint, the plaintiff submitted a brief containing at least two fabricated case citations alongside a real case that was entirely irrelevant to the proposition for which it was cited. The court concluded these hallucinations were evidence that the plaintiff had used generative AI to prepare her filing without verifying its accuracy.
- Sanction Imposed: The motion was stricken from the record for the AI errors and other procedural violations.
- Notable Court Quotes: “While the use of [generative AI] is not necessarily problematic, the failure to confirm the accuracy of the filing is. ... Plaintiff’s pro se status does not relieve her of this requirement.”
Monetary Sanctions + Briefs Stricken
Obi v. Cook County, Illinois, et al. (N.D. Ill. April 9, 2026)
- Case Background: A pro se plaintiff filed a federal civil rights lawsuit seeking to challenge the outcome of state family court proceedings.
- The AI Misconduct: After the court dismissed her complaint, the plaintiff filed a motion to alter or amend the judgment that was riddled with AI hallucinations, including fabricated case citations, invented quotes attributed to real cases, and language falsely attributed to the court’s own prior order. The court identified at least 13 hallucinated cases, quotes, and statements of law across the motion and reply briefs.
- Sanction Imposed: $5,000 payable to the Clerk of the Court for Rule 11 violations. The motion and reply briefs were also stricken from the record for violating local page-limit rules.
- Notable Court Quotes: “Normally the Court, recognizing Plaintiff’s pro se status, would offer leeway and consider Plaintiff’s briefs despite violating Local Rule 7.1. Plaintiff’s egregious, repeated, and ongoing Rule 11 violations, however, foreclose any such possibility. … Filing a document that contains citations to nonexistent cases, quotes language that comes from no real case, or that contains arguments wholly unsupported by the record violates Rule 11.”
Claim Dismissal
Mills v. City of St. Louis, et al. (E.D. Mo. Jan. 30, 2026)
- Case Background: A pro se plaintiff sued the City of St. Louis and two individual defendants alleging age and sex discrimination and retaliation in employment.
- The AI Misconduct: The plaintiff’s filings contained misquotations, misrepresentations of cited case law, and citations to cases that do not exist.
- Sanction Imposed: Dismissal with prejudice as a Rule 11 sanction.
- Notable Court Quotes: “All litigants – represented and unrepresented – must read their filings and take reasonable care to avoid misrepresentations, factual and legal. … Every filing in a federal court that contains citations to phony case law amounts to a violation of Rule 11(b) of the Federal Rules of Civil Procedure. … There is no pro se exception to Rule 11(b). … Even a pure heart and empty head is not enough to avoid the sting of Rule 11 sanctions.”
Samuel K. v. Focia (Cal. Ct. App. 2d Dist. Feb. 26, 2026)
- Case Background: A self-represented defendant appealed a one-year domestic violence restraining order entered against her.
- The AI Misconduct: The appellant’s opening brief contained 12 legal quotations, 11 of which were fabrications – either attributed to nonexistent cases or misrepresenting the holdings of real ones.
- Sanction Imposed: Appeal dismissed in its entirety.
- Notable Court Quote: “Simply stated, no brief, pleading, motion, or any other paper filed in any court should contain any citations – whether provided by generative AI or any other source – that the person responsible for submitting the pleading has not personally read and verified.”
Donaldson v. Hiland Dairy, et al. (N.D. Tex. April 9, 2026)
- Case Background: A pro se plaintiff sued his former dairy employer and individual supervisors under Title VII and Texas state law, alleging he was wrongfully terminated on pretextual grounds after reporting what he claimed was an inappropriate hug from an HR manager.
- The AI Misconduct: After the magistrate judge recommended dismissal as time-barred, the plaintiff filed 29 separate objections totaling 677 pages. The district court noted that the plaintiff attached hundreds of pages of AI-generated responses to Google searches on various legal topics, content that was cryptic, conclusory, and entirely unresponsive to the magistrate’s statute of limitations analysis.
- Sanction Imposed: The complaint was dismissed with prejudice.
- Notable Court Quote: “Courts still require pro se parties to fundamentally abide by the rules that govern the federal courts. So pro se litigants must properly plead sufficient facts that, when liberally construed, state a plausible claim to relief.”
Nisland Asset Investment, LLC v. Gericke (Iowa Ct. App. April 29, 2026)
- Case Background: A self-represented homeowner appealed a summary judgment ruling in a quiet title action.
- The AI Misconduct: In her appellate brief, the defendant cited two cases that do not exist and a third that exists but had no relevance to the proposition for which she cited it.
- Sanction Imposed: The court deemed every issue on appeal waived for failure to cite valid legal authority, effectively ending her case. The court affirmed summary judgment against her in full.
- Notable Court Quotes: “We do not have a double standard for those represented by counsel and those who are unrepresented – we expect all to follow our procedures. … We have repeatedly stressed that self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.”
Claims Dismissal + Monetary Sanctions
Shaw v. Coast Dental of Georgia, P.C., et al. (Ga. Super. Ct. Jan. 6, 2026)
- Case Background: A pro se plaintiff sued a dental practice and an individual dentist.
- The AI Misconduct: The plaintiff’s motions to strike cited a total of six case citations across two motions, the majority of which were AI hallucinations. In one motion, two of four cited cases were entirely fictional. In the other motion, all four cited cases were fictional AI-generated hallucinations, including fabricated direct quotations attributed to nonexistent Georgia authority.
- Sanction Imposed: $2,632 in attorneys’ fees, representing defense counsel’s reasonable and necessary fees in responding to the AI-hallucinated filings, and dismissal of the complaint with prejudice.
- Notable Court Quotes: “There is no ‘liberal’ way to construe a lie or an AI-generated falsehood – such citations demonstrate bad faith to the Court, and they are sanctionable as to the pro se litigant.”
In the Matter of the Estate of Thomas W. Kuerschner (Ariz. Ct. App. March 5, 2026)
- Case Background: A self-represented widow appealed attorney fee sanctions imposed during her deceased husband’s probate proceedings, in which she had lost on all claims.
- The AI Misconduct: The appellant’s briefs contained 25 citations that were either fabricated or contained substantial errors including fake quotes and unsupported propositions. Examples identified by the court included: a case that could not be located under the name cited; a real case cited for a quote that does not appear in that opinion; and a real case cited for a proposition it does not address.
- Sanction Imposed: Appeal dismissed in its entirety under state civil procedure rules. The court also awarded the opposing party reasonable attorney fees and costs for counsel’s time spent identifying the violations.
- Notable Court Quotes: “We dismiss her appeal and impose sanctions because she continues to violate our rules by fabricating case citations and omitting record references. … We find Stefanie’s repeated and unrepentant violations warrant sanctions under ARCAP 25 to discourage similar behavior. Although we are generally reluctant to impose such sanctions, recidivism after a warning justifies this result.”
Allen v. Western Governors University, et al. (D. Nev. March 31, 2026)
- Case Background: A pro se plaintiff sued Western Governors University and 10 individual administrators, alleging wrongful academic expulsion and related claims.
- The AI Misconduct: Defendants identified over 60 misrepresented or fabricated case citations across the plaintiff’s filings.
- Sanction Imposed: Case dismissed with prejudice under the court’s inherent powers, plus monetary sanctions in the form of defendants’ attorney fees and costs incurred as a direct result of the citation misconduct.
- Notable Court Quote: “Although courts make some allowances for a 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.”
