Jeter v. ADUSA Transportation LLC
U.S. District Court, District of South Carolina · D.S.C. · South Carolina bar guidance
Conduct
Pro se employment plaintiff cited 2 defective cases (Andrews v. Va. Union, reporter mismatch; Grant v. N. Myrtle Beach, fabricated).
Consequence
R&R recommends partial dismissal; AI verification warning issued; no formal sanction. R&R adopted by Austin Jan 12, 2026.
Lesson
Magistrate R&Rs are now part of AI-citation case law; the warning attaches at recommendation, not adoption.
Verified May 8, 2026
- Citation
- Jeter v. ADUSA Transp. LLC, No. 6:25-cv-06713-JDA, R&R Dkt. 14 (D.S.C. Dec. 15, 2025) (Brown, M.J.); adopted Jan. 12, 2026 (Austin, J.)
- Decided
- December 15, 2025
Summary
The plaintiff (a pro se employee) filed a civil rights employment action against ADUSA Transportation LLC alleging race discrimination, retaliation, racially hostile work environment, and retaliatorily hostile work environment claims. The defendants moved to dismiss. In responding to the motion, the plaintiff cited authorities the court could not locate or that did not say what the citations attributed to them. Magistrate Judge William S. Brown issued a December 15, 2025 Report and Recommendation that recommended partial dismissal and separately addressed the citation defects. The R&R identified two specific problematic citations: Andrews v. Virginia Union University, 2021 U.S. App. LEXIS 12460 (4th Cir. Apr. 27, 2021), which the court found actually corresponds to a Ninth Circuit Social Security case (Davis v. Saul); and Grant v. Mayor of North Myrtle Beach, 2020 WL 550069, which the court was unable to locate in any reporter.
- AI tool:
- Generative AI implied; the magistrate's R&R discusses AI use generally
What sanction did the court impose?
R&R recommended granting in part and denying in part the defendants' motion to dismiss: race discrimination and racially hostile work environment claims dismissed without prejudice; retaliation and retaliatorily hostile work environment claims to proceed. The R&R also warned that "use of generative AI without proper verification may violate Rule 11" and cautioned that continued citation failures could constitute evidence of bad faith warranting sanctions. District Judge Jacquelyn D. Austin adopted the R&R on January 12, 2026. No formal sanction was imposed at the R&R stage; subsequent discovery and sanctions disputes have continued through May 2026.
Why does Jeter v. ADUSA Transportation LLC matter for law firms using AI?
Jeter v. ADUSA Transportation LLC is one of three D.S.C. AI-citation orders catalogued in this collection from late 2025 and early 2026 (the others are Cherleatha B. v. Bisignano, Dec. 29, 2025, and Sevilla v. Ross, Dec. 31, 2025; followed by Bruce v. United States on Feb. 9, 2026). The Jeter R&R is procedurally distinctive: the AI-verification warning attaches at the magistrate-judge stage rather than at district-judge adoption, and the order distinguishes between two failure modes (fabricated cases that do not exist in any reporter, and reporter-mismatch cases where the cited volume and page actually contain a different case). The Andrews v. Virginia Union University citation is a textbook example of the latter: the citation reads as a Fourth Circuit employment case but the LEXIS reporter combination actually corresponds to a Ninth Circuit Social Security case. Cross-reference: Sevilla v. Ross (D.S.C. Dec. 31, 2025) (Austin, J.) (same district judge ultimately adopting the R&R here); Cherleatha B. v. Bisignano (D.S.C. Dec. 29, 2025) (Lydon, J.); Bruce v. United States (D.S.C. Feb. 9, 2026) (Lydon, J.).
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 defending an employment-discrimination claim brought pro se, screen the plaintiff's response brief for citations that mismatch the cited reporter; the Brown R&R surfaces both fabricated cases (Grant v. Mayor) and reporter-mismatch cases (Andrews v. Va. Union), and naming both types in the reply is the standard surfacing mechanism.
- Track the chambers practice of attaching AI-verification warnings at the magistrate-judge R&R stage rather than at district-judge adoption; the warning is operative as of the R&R, even if final disposition awaits the district judge's order.
- Document the firm's litigation timeline so that subsequent motions in the case can reference the prior R&R's AI warning; the Brown order becomes part of the law-of-the-case for purposes of any later sanctions motion.
Sources
Primary sources
- The Jeter case is not in the Charlotin tracker as of May 2026; verification of the AI-related findings relied on the RECAP-archived order text rather than a third-party catalog cross-reference.
- The fabricated case names (Andrews v. Virginia Union University; Grant v. Mayor of North Myrtle Beach) are extracted from a third-party reading of the R&R; the verbatim reporter mismatches and the magistrate's exact characterization of each citation may differ slightly from the extraction.
- The case continued through subsequent motion practice; an April 22, 2026 sanctions order addressed multiple discovery motions. That later order is not part of this entry but suggests the AI-citation issue may have evolved over time.