Docket entry 33, 30 January 2026 · source · PDF · 11 pages
Docket text. ORDER signed by Chief Judge Pamela Pepper on 1/30/2026 GRANTING 30 plaintiff's motion to strike defendant Nantomah's response (Dkt. No. 26). Nantomah to file amended answer/responsive pleading by end of day 2/28/2026. (cc:all counsel and mailed to Joseph Nantomah, 597 Pembridge Ct., Orange Park, FL 32073)(cb)
Construing the document liberally, the court concludes that it is likely that Nantomah intended the letter to be an answer to the complaint. Even if the court were to construe the document as a motion to dismiss, the court would be required to deny it because at least two of the cases Case 2:25-cv-01130-PP Filed 01/30/26 Page 6 of 11 Document 33 7 Nantomah cites in support of his argument for dismissal do not exist. Nantomah cites Goldberg v.
Nantomah’s citations bear the hallmarks of generative artificial intelligence. In recent years, courts and the legal community have learned that generative artificial intelligence programs like ChatGPT regularly produce inaccurate or false case citations (often referred to as “hallucinated” cases) and that they misstate or misrepresent the law. See In re Martin, 670 B.R.
Ill. 2025) (collecting cases discussing the proliferation of AI hallucinated cases and the risks of AI-assisted legal research). Courts across the country have imposed sanctions (both monetary and non-monetary) on attorneys and self-represented litigants for filing AI-generated documents that cite to nonexistent cases or that misrepresent the law.
Nov. 4, 2025) (“The pitfalls of submitting court filings that contain hallucinated citations are obvious, and courts have sanctioned licensed attorneys and self- represented litigants alike for their failure to exercise diligence.”); Davis v. Marion Cnty.
Sept. 2, 2025) (reviewing monetary sanctions imposed on parties citing to nonexistent cases); Attaway v. Illinois Dep’t of Corr., Case No.
Apr. 14, 2025) (warning self-represented plaintiff that future use of hallucinated citations may result in monetary sanctions). Case 2:25-cv-01130-PP Filed 01/30/26 Page 8 of 11 Document 33 9 When an attorney or self-represented party files a document in federal court, that attorney or party is certifying to the court that the legal contentions contained in it “are warranted by existing law.” Fed.
Filing a document that contains citations to nonexistent cases or that quotes language that does not appear in a cited case violates Rule 11 because it demonstrates that the filing party has not made a reasonable inquiry into the supporting law.