New York · federal district court · 2026

Hodges v. McGough Enterprises LLC

District Court, S.D. New York, 26 May 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · S.D.N.Y.

  1. Court. District Court, S.D. New YorkCOURT
  2. Level. federal district courtLEVEL
  3. Date. 26 May 2026DATED
  4. Docket. No. 7:23-cv-05016DOCKET
  5. Judge. Nelson Stephen RomanJUDGE
  6. Documents. one document, 3 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 135, 26 May 2026 · source · PDF · 14 pages

Docket text. ORDER denying 125 Motion for Protective Order; denying 132 Motion for Protective Order. For the foregoing reasons, Plaintiff's motion for a protective order is denied. Plaintiff is ordered to file copies of the cases cited in his brief ing within one week of the entry of this Order, see supra Section II.A, and Plaintiff is advised that future filings with citations to nonexistent cases may result in sanctions, including but not limited to dismissal of the case. The Clerk of Court is respectfully requested to te1minate the pending motion (Docket Nos. 125, 132), and mail a copy of this Order to the prose Plaintiff. SO ORDERED. (Signed by Magistrate Judge Judith C. McCarthy on 5/26/2026) (vfr)

125 at 15). This raises concern that these cases may be the result of generative artificial intelligence hallucinations.7 See Smith v. Smith, 5:25-CV-1077 (MAD/DJS), 2025 WL 3706691, at *2-3 (N.D.N.Y.

6 All page number citations herein refer to the page number assigned upon electronic filing unless otherwise noted. 7 “Generative artificial intelligence tools can fabricate or ‘hallucinate’ legal precedent.” Romero v. Goldman Sachs Bank USA, 1:25-cv-2857-GHW, 2025 WL 1916119, at *1 (S.D.N.Y.

7.2 (“Upon request, counsel must provide the pro se litigant with copies of such unpublished cases and other authorities as are cited in a decision of the court and were not previously cited by any party.”). - 7 - Therefore, Plaintiff is directed to provide copies of the aforementioned cases to the Court within one week of the entry of this Order. Further, Plaintiff is advised that “filings with citations to nonexistent cases may result in sanctions, such as [his] submissions being stricken, filing restrictions or monetary penalties being imposed, or the case being dismissed.” Dukuray, 2024 WL 3812259, at *12. B.

What the text mentions

Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.

Where this fits

This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.

More from District Court, S.D. New York, from New York, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

Show me on one of my files →

This case is about a cite nobody opened. See a cite checked against the record before it renders, on your own file.

Show me on my files