Crudup v. City of Atlanta
U.S. District Court, Northern District of Georgia, Atlanta Division · N.D. Ga. · Georgia bar guidance
Conduct
Here a pro se plaintiff's objections to a report and recommendation cited at least four cases the court could not locate and concluded likely do not exist.
Consequence
Here the court dismissed the complaint with prejudice on limitations grounds and held that whether to sanction the citations to likely nonexistent cases was moot.
Lesson
Here the court recorded a likely-fabricated-citation finding in a footnote and treated sanctions as moot once the case was dismissed.
Verified September 29, 2026
- Citation
- Crudup v. City of Atlanta, No. 1:24-CV-04497-JPB, Order Adopting Final Report and Recommendation (N.D. Ga. Oct. 24, 2025), ECF No. 62
- Decided
- October 24, 2025
Summary
Darshon Crudup, who filed the action pro se, sued the City of Atlanta over his employment. A magistrate judge recommended dismissing the amended complaint as time-barred, and Crudup filed several sets of objections. In a footnote to its order adopting the recommendation, the district court noted that Crudup "incorporates several legal citations into his R. & R. objections" and that "[a]fter an exhaustive database search, the Court was unable to locate at least four of Plaintiff's cited cases. As such, the Court concludes that the hard-to-find cases in Plaintiff's submissions likely do not exist." Citing decisions from the Northern District of Alabama and the Southern District of Georgia, it observed that fabricating case law "is serious misconduct that demands a serious sanction."
- AI tool:
- Not mentioned (the order concludes that at least four cases cited by the pro se plaintiff "likely do not exist" but does not mention AI)
How did the court address the AI-related conduct?
The court overruled the objections, adopted the recommendation, and dismissed the amended complaint with prejudice. It held that "the issue of whether to apply sanctions to Plaintiff's conduct is moot because his complaint is hereby dismissed." No sanction or warning was imposed.
Why does Crudup v. City of Atlanta matter for law firms using AI?
Crudup v. City of Atlanta is an order adopting a magistrate judge’s recommendation to dismiss an employment case as time-barred. The citation issue appears only in a footnote. The pro se plaintiff had incorporated legal citations into his objections, and after “an exhaustive database search” the court could not locate at least four of them and concluded that they likely do not exist.
The court quoted another decision describing fabricated case law as “serious misconduct that demands a serious sanction” and cited a second, but it did not reach the question: because the complaint was being dismissed with prejudice, it held that whether to sanction the conduct was moot. The order does not mention artificial intelligence or identify the cases it could not find.
Firms documenting compliance may wish to consider that, here, a finding that cited cases likely do not exist was made and recorded in the order even though no sanction followed.
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.
- Verify every case cited in objections to a report and recommendation. Here the court ran an exhaustive search and concluded that at least four cited cases likely did not exist.
- Note that the court here treated sanctions as moot because the case was dismissed; the finding itself remains in the court's order.
Sources
Primary sources
- AI attribution: the order does not mention artificial intelligence. It finds that at least four cited cases likely do not exist; the Ropes & Gray tracker's AI coding rests on that finding.
- The order does not identify the four cases it could not locate.