Jesse Andre v. Warden, FCI Danbury
U.S. District Court, District of Connecticut · D. Conn. · Connecticut bar guidance
Conduct
Pro se inmate had paralegal service draft Rule 60(b) habeas motion using AI; one fake case, two fake quotes, plus mischaracterized cites.
Consequence
Rule 11 admonishment plus motion stricken with prejudice; pro se solicitude denied for ghostwritten + AI-laundered filings.
Lesson
Ghostwriting plus generative AI plus a fake signature image is a triple Rule 11 violation; don't combine them.
Verified May 8, 2026
- Citation
- Andre v. Warden, FCI Danbury, No. 3:24-cv-01295 (VDO), Memorandum and Order at ECF No. 45 (D. Conn. Nov. 25, 2025)
- Decided
- November 25, 2025
Summary
Petitioner Jesse Andre, an inmate at FCI Big Spring proceeding pro se, filed a Federal Rule of Civil Procedure 60(b) motion for relief from the Court's prior denial of his 28 U.S.C. § 2241 habeas petition challenging Bureau of Prisons placement decisions. Judge Vernon D. Oliver, suspecting from inconsistencies in formatting, signature images, and writing style that Andre was receiving undisclosed third-party drafting help, issued an order to show cause on July 31, 2025 directing Andre to identify under penalty of perjury who drafted his filings. Andre's response (drafted, ironically, by the same third party) characterized the assistance as "merely clerical." The Government's response attached emails between Andre and "Alan Adamz" of "Nuline Legal" (help@nulinelegal.com) showing the show-cause response had been sent to Andre as a pre-drafted document under the subject line "Your draft as requested." At the October 16, 2025 show-cause hearing, Andre admitted to "heavy" reliance on artificial intelligence, instructing "friends" to ask AI questions and "draft up motions." The Court's review of the Rule 60(b) motion identified one fully fabricated case (Harriot v. Jamison, 2025 WL 456789, S.D.N.Y. Feb. 4, 2025), two fabricated quotes, and over a dozen real cases and rules cited for propositions they do not support, including Levine v. Apker, Woodley v. Warden, Komando v. Luna, Sierra v. Jacquez, Perttu v. Richards, Mayle v. Felix, and Rivers v. Guerrero. The Court found that Andre's filings bore electronic signature images rather than handwritten ones, that the envelope mailing the Rule 60(b) motion bore a Jacksonville, Florida postal stamp despite Andre being incarcerated in Texas (the Nuline operator resided in Florida), and that the initial habeas petition itself likely was not signed personally by Andre.
- AI tool:
- Generative artificial intelligence (Petitioner admitted to 'heavy' reliance on AI; tool not specifically identified by name on the record; drafting service was 'Nuline Legal' / Alan Adamz, help@nulinelegal.com)
What sanction did the court impose?
ADMONISHMENT of Petitioner under Rule 11 for (1) using a third party to draft and file the motion, (2) including multiple fabricated arguments generated by artificial intelligence, (3) affixing an image of his signature rather than personally signing, and (4) making affirmative misrepresentations to the Court about the nature and extent of the assistance received. STRIKING of the Rule 60(b) motion with prejudice. No monetary sanction; no referral; outcome documented in a 22-page Memorandum and Order applying the Mattox v. Product Innovation framework for AI-related Rule 11 violations.
Why does Jesse Andre v. Warden, FCI Danbury matter for law firms using AI?
Andre v. Warden is the most procedurally elaborate of the November 2025 batch of D. Conn. AI-related orders. Judge Oliver’s 22-page memorandum systematically walks through each of the four conditions the Court found independently sufficient for Rule 11 sanctions: third-party drafting, AI-generated hallucinations, electronic signature images, and affirmative misrepresentations about the nature of the assistance. The opinion includes a chart identifying each fabricated or mischaracterized authority (Harriot v. Jamison fully fabricated; Levine v. Apker, Woodley v. Warden, Sierra v. Jacquez, Perttu v. Richards, Mayle v. Felix, Rivers v. Guerrero either misquoted or relied on for propositions they don’t support).
Two structural details elevate this case above the routine pro se hallucination order:
First, the Court’s Rule 11(a) signature analysis. Judge Oliver found that Andre’s filings bore an electronic image of his signature pasted onto the documents rather than a handwritten signature, that prison computers don’t provide image-pasting capability, and that the postal stamp on the envelope mailing the Rule 60(b) motion was Jacksonville, Florida (where the Nuline operator resided) rather than Big Spring, Texas (where Andre was incarcerated). The Court extended this finding back to Andre’s initial habeas petition, concluding that the original signature on that petition “appears in no other filing” and that the petition itself likely was not personally filed by Andre.
Second, the Court’s use of the Wayback Machine to establish Nuline Legal’s business model. After Nuline took its website offline between August 4 and September 3, 2025, the Court took judicial notice of the August 4 archived snapshot, which described Nuline as a “dedicated team of experienced professionals” providing “comprehensive and reliable paralegal services” with “First Step Act Litigation” listed as the first practice area. That archived text was load-bearing for the Court’s finding that Nuline’s self-characterization to Andre (as a typing service providing “clerical” help) was contradicted by Nuline’s public-facing positioning as a legal drafting business.
Andre is the first D. Conn. case to apply the Mattox v. Product Innovation Research two-factor AI Rule 11 framework (verification-and-inquiry; candor- and-correction) explicitly. It also cross-references Braica v. Frankowski (Dec. 15, 2025) as a parallel Vernon Oliver chambers ruling on AI conduct, issued three weeks after this opinion. Together with the May 30 and July 3, 2025 orders in Roark v. American Airlines (also Vernon Oliver), Andre marks this judge as one of the most active D. Conn. judges on AI-related Rule 11 issues in the 2025 term.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- If a client mentions 'a service' (paralegal mill, jailhouse-lawyer network, online drafting platform) preparing their drafts, treat that disclosure as a Rule 11 trigger and verify authorship before signing.
- Train staff that scanned signature images on documents the lawyer didn't see line-by-line are functionally a third-party signature; they don't satisfy Rule 11(a) personal-signing.
- When a third-party drafter uses AI, two compounding diligence failures stack on each other; neither the lawyer nor the drafter has personally verified the filing.
- For inmate-litigant matters, the Andre opinion's Wayback-Machine reasoning is a useful template; courts can and will pull archived snapshots of paralegal-mill websites to establish the drafter's identity.