Fantini v. Westrock Co.
U.S. District Court, District of New Jersey · D.N.J. · New Jersey bar guidance
Conduct
Pro se employment plaintiff cited a nonexistent 'Pruco Life Ins. Co. v. Carrasco' opinion in his summary-judgment cross-motion; Judge O'Hearn confirmed the authority does not exist.
Consequence
Summary judgment granted for defendants on all counts; Rule 11 reminder issued in footnote 5; no monetary sanction, with future sanctions reserved for failures of 'reasonable inquiry.'
Lesson
The footnote-warning template (warn in footnote tied to dismissal on independent grounds, reserve sanctions for repeat conduct) is now the standard D.N.J. response to pro se AI-citation conduct on dispositive motions.
Verified May 10, 2026
- Citation
- Fantini v. Westrock Co., No. 1:22-cv-04351-CPO-AMD, Opinion (D.N.J. Dec. 19, 2025) (O'Hearn, J.), ECF No. 171
- Decided
- December 19, 2025
Summary
Pro se plaintiff Nicholas Fantini brought employment and discrimination claims (common-law wrongful termination, Title VII / NJLAD hostile work environment and reverse-gender-discrimination, common-law workplace negligence, negligent misrepresentation) against WestRock Services LLC and seven individual defendants in D.N.J. (Camden Vicinage). Plaintiff's cross-motion for summary judgment (ECF No. 157 at 7) cited 'Pruco Life Ins. Co. of New Jersey v. Carrasco, 2022 WL 1210718 (D.N.J. Apr. 25, 2025).' Judge Christine P. O'Hearn found, after diligent search, that the cited authority does not exist. The procedural backdrop included a long pattern of stricken pro se filings during 2025 for noncompliance with Federal Rule 56 and Local Rules 56.1 and 7.1(h).
- AI tool:
- Unspecified generative AI
- Sanction amount:
- None (Rule 11 reminder in footnote 5 of summary-judgment opinion; sanctions reserved for any future failure to conduct 'reasonable inquiry')
What sanction did the court impose?
On December 19, 2025, Judge O'Hearn entered an OPINION (ECF No. 171) and Order (ECF No. 172) granting Defendants' summary-judgment motion in full and denying Plaintiff's cross-motion. On the AI conduct, the Court declined to impose monetary sanctions but issued a Rule 11 caution in footnote 5: 'While some of the procedural deficiencies in Plaintiff's pro se submissions may be excused, the Court cannot ignore Plaintiff's citation to what appears to be non-existent case law, (see Pl.'s Cross-Mot., ECF No. 157 at 7 (citing Pruco Life Ins. Co. of New Jersey v. Carrasco, 2022 WL 1210718 (D.N.J. Apr. 25, 2025)), which, despite the Court's diligent search, does not appear to exist). The Court reminds Plaintiff that an 'unrepresented party' is still subject to Rule 11 and may be sanctioned for failing to conduct a 'reasonable inquiry' into whether 'the claims, defenses, and other legal contentions are warranted by existing law.' FED. R. CIV. P. 11(b)–(c).' The Court cited Powhatan Cnty. Sch. Bd. v. Skinger, No. 24-874, 2025 WL 1559593, at *10 (E.D. Va. June 2, 2025) (collecting cases) as cross-circuit authority that 'Courts have also routinely threatened to impose sanctions on litigants proceeding pro se who cite AI-hallucinated or otherwise nonexistent legal authority to support their positions.'
Why does Fantini v. Westrock Co. matter for law firms using AI?
The structural choice in O’Hearn’s opinion mirrors her January 12, 2026 footnote in Doe v. United States. In both cases, the Court reached the dispositive question on independent grounds (Title VII exhaustion + NJLAD preemption in Fantini; Rule 8 + section 1915(e)(2) in Doe), and added the Rule 11 reminder in a footnote tied to the next-filing opportunity. The pattern signals that the warning is functionally a “do not repeat this conduct” note rather than a finding that the AI-cited authority materially prejudiced the dispositive analysis.
The Powhatan v. Skinger cite continues to do heavy lifting in this corpus. Three D.N.J. orders in this database now anchor their AI-citation analysis to that E.D. Va. collecting-cases opinion (Doe v. United States, Baker v. Rastelli, Fantini), suggesting Powhatan is functioning as the working canonical authority for pro se AI-citation sanctions framing across at least D.N.J. and likely other Third Circuit districts. Partners drafting AI-citation sanctions briefs in 2026 should treat Powhatan as the first-choice cross-circuit citation, paired with the local-judge application.
The defense-side procedural point worth noting: the underlying summary judgment was the merits resolution. AI-citation issues surfaced in plaintiff’s cross-motion, ECF No. 157, not the complaint. Firms screening pro se filings for AI-citation patterns should treat dispositive-motion papers as a high-yield surface, not just the initial pleading. The AI-conduct flag here came from the cross-motion brief at page 7, embedded in a Pierce-claim discussion, not from a separate brief identifying AI use.
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.
- Track Judge O'Hearn's footnote-warning template across multiple AI-citation matters: same chambers issued the Doe v. United States footnote 3 warning on January 12, 2026. This is now a documented chambers pattern in D.N.J. for pro se AI-hallucinated citations: warning on first occurrence, sanctions reserved for repeat conduct.
- Note the procedural shape: the Court did not need to reach the AI conduct to decide summary judgment; Title VII exhaustion and NJLAD preemption were independently sufficient. Placing the warning in footnote 5 puts the issue on the docket without making it the operative basis for the dismissal.
- Document the Powhatan v. Skinger (E.D. Va. June 2, 2025) cite as the cross-circuit anchor; this is one of three 2025-2026 D.N.J. orders in this database (Fantini, Doe v. United States, Baker v. Rastelli) anchoring AI-citation analysis to Powhatan's collecting-cases authority.
- Recognize the cross-claim-type pattern: AI hallucination appeared in plaintiff's summary-judgment cross-motion, not the complaint. Defense counsel screening pro se filings should pre-verify cited authority in dispositive-motion papers, not just initial pleadings.