A federal district court judge in New York’s Southern District recently used her discretion to warn a self-represented litigant about submitting false and nonexistent legal authority to the Court.

Sanctions may be imposed for submitting false and nonexistent legal authority to the Court. See, e.g., Park v. Kim, 91 F.4th 610, 613-16 (2d Cir. 2024) (per curiam) (sanctioning attorney whose brief, drafted in reliance on ChatGPT, included citations to fake opinions); Mata, 678 F. Supp. 3d at 459-66 (same). That said, the Court is mindful of its “obligat[ion] to afford a special solicitude to pro se litigants,” which “includes leniency in the application of procedural rules.” Rosa v. Doe, 86 F.4th 1001, 1007 (2d Cir. 2023) (citation omitted). Therefore, the Court declines to sanction Plaintiff at this time and instead warns Plaintiff that the Court will not look kindly on similar infractions in the future.

The July 18, 2024 opinion and order was issued in Anonymous v. New York City Department of Education (1:24-cv-04232)