Jeramiah Brown v. Fat Dough Incorporated, d/b/a Domino's Pizza
U.S. District Court, Northern District of New York · N.D.N.Y. · New York bar guidance
Conduct
Pro se plaintiff cited a non-existent N.D.N.Y. Lynch case; the cited Westlaw number actually corresponds to a different S.D.N.Y. case.
Consequence
Warning from N.D.N.Y. U.S. District Judge Coombe; no monetary sanction.
Lesson
Westlaw-cite reuse (real WL number paired with fabricated case name) is a recurring AI-hallucination pattern in N.D.N.Y.
Verified May 14, 2026
- Citation
- Brown v. Fat Dough Inc., No. 5:22-cv-00761 (N.D.N.Y. Sept. 17, 2025) (Coombe, J.)
- Decided
- September 17, 2025
Summary
Pro se plaintiff Jeramiah Brown filed papers in an employment matter against Fat Dough Incorporated (Domino's Pizza franchisee) that included the fictitious citation "Lynch v. U.S. Postal Service, 2016 WL 7338415 (N.D.N.Y. Dec. 19, 2016)." The court found that the Westlaw citation actually corresponds to Green v. New York, No. 14-cv-2073, 2016 WL 7338415 (S.D.N.Y. Dec. 19, 2016), and that no Lynch decision exists from N.D.N.Y. in 2016. U.S. District Judge Elizabeth C. Coombe issued a warning to the plaintiff; the plaintiff testified that he used ChatGPT to draft his legal papers.
- AI tool:
- ChatGPT
What sanction did the court impose?
Warning issued by Judge Coombe; no monetary sanction or formal disciplinary referral imposed.
Why does Jeramiah Brown v. Fat Dough Incorporated, d/b/a Domino's Pizza matter for law firms using AI?
Brown v. Fat Dough is a clean example of the Westlaw-cite reuse hallucination pattern: a real Westlaw number (2016 WL 7338415) paired with a fabricated case name (Lynch v. U.S. Postal Service). The Westlaw number resolves to a real case (Green v. New York) at a different district (S.D.N.Y. rather than N.D.N.Y.). The pattern is consistent with how generative AI tools assemble citations from training-data fragments without preserving the integrity of the case-to-citation pairing. Judge Coombe’s warning treats this as a hallucination on par with a fully fabricated citation.
For firms with N.D.N.Y. employment-defense practices, the operational lesson is that cite-checking pro se opposition requires reconciling case name to citation, not just verifying citation existence. A WL number that resolves to a different case is a hallucination signal, not a typo. The warning-only disposition signals that N.D.N.Y. is following the broader S.D.N.Y. pattern of first-occurrence pro se warnings rather than escalating to monetary sanctions.
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.
- When responding to pro se employment plaintiffs in N.D.N.Y., verify Westlaw citation numbers actually correspond to the cited case name, not just that the WL number resolves. AI models routinely re-pair real WL numbers with fabricated case captions.
- Move-to-warn or move-to-strike practice in N.D.N.Y. employment matters now has Brown as a precedent for the warning-only disposition; manage client expectations accordingly when discussing sanctions strategy.