Hayes v. Chipotle Mexican Grill, LLC
U.S. District Court, Middle District of Florida · M.D. Fla. · Florida bar guidance
Verified May 14, 2026
- Citation
- Hayes v. Chipotle Mexican Grill, LLC, No. 8:25-cv-03286-TPB-SPF (M.D. Fla. Jan. 9, 2026) (Barber, J.)
- Decided
- January 9, 2026
Summary
Ryan Hayes, proceeding pro se, sued Chipotle in Florida state court over a hostile exchange with an employee during an October 2025 restaurant visit; Chipotle removed the case to the Middle District of Florida. In opposing Chipotle's motion to dismiss, Hayes cited four cases that do not exist: Capistrano v. Financial Industry Regulatory Authority, Department of Fair Employment & Housing v. Law School Admission Council, Perez v. Zazo, and Byrd v. Shumann. He also cited complaint paragraphs that either do not exist or do not say what he claimed. Judge Tom Barber found it "likely that Plaintiff is perhaps utilizing automated, artificial intelligence tools to research and draft his filings," and grounded the court's response in its "inherent authority to sanction the misuse of AI."
- AI tool:
- Unidentified (the court found it 'likely' Hayes used 'automated, artificial intelligence tools'; no specific tool named)
What sanction did the court impose?
The court granted Chipotle's motion in part and dismissed the complaint without prejudice, giving Hayes until January 30, 2026 to file an amended complaint curing the defects identified in the order. Failure to amend would convert the dismissal into a final judgment. The court imposed no sanction for the fabricated citations. It warned Hayes that "if he continues to misrepresent the record or cite non-existent legal authority, he may be subjected to sanctions," noting that pro se status does not relieve a litigant of the duty of candor owed by any other party.
Why does Hayes v. Chipotle Mexican Grill, LLC matter for law firms using AI?
Hayes v. Chipotle is a reminder that the AI-citation problem is not confined to complex commercial litigation. The underlying dispute is small: a customer says a Chipotle employee was rude to him and the manager then refused to serve him. Hayes filed an ADA public-accommodation claim, Chipotle removed it and moved to dismiss, and Hayes opposed with a brief containing four cases that do not exist.
Judge Barber’s response is the now-familiar Middle District of Florida pattern. The court dismissed the complaint with leave to amend on the merits, addressed the fabricated citations in a separate section, and issued a warning rather than a sanction. What makes the order useful is its framing of the duty. The court grounded its authority in the “inherent authority to sanction the misuse of AI,” and reminded Hayes that pro se status carries “the same duty of candor to the court as imposed on any other litigant.” For a firm defending a public-accommodation or consumer claim against a pro se plaintiff in the Middle District of Florida, that framing is the citable hook: the duty of candor does not bend for an unrepresented opponent, and the court will say so on the record.