Kabir v. WebMD LLC

What sanction did the court impose?

In a Memorandum Order entered February 3, 2026 (ECF No. 192), Judge Padin found that the plaintiff's latest opposition to THOUGHTi's motion to dismiss (ECF No. 159) "relies on hallucinated quotations," including a citation to a non-existent Fairfield Industries decision, and noted that the court had struck that filing (p. 7 and n.7). The order quotes the court's earlier warnings (ECF Nos. 117 and 138) and cautions that further reliance on hallucinated citations or undisclosed generative AI may bring a pre-filing injunction or another sanction. In the same order the court revoked the plaintiff's Alternate Document Submission (ADS) privileges and denied his motions at ECF Nos. 158 and 165 with prejudice; that revocation rests on his repeated circumvention of the filing rules and direct contact with chambers, not on the citations (pp. 2, 5-6). No monetary sanction or bar referral appears.

Why does Kabir v. WebMD LLC matter for law firms using AI?

Kabir v. WebMD is a pro se patent and trade-secret action filed by Azad Alamgir Kabir in the District of New Jersey. Judge Evelyn Padin’s December 2, 2025 Text Order (ECF No. 117) is the first AI-citation moment in the docket. The order denies plaintiff’s request to file overlength briefs and flags a citation in plaintiff’s papers to “United States v. Schiff, No. 17-7306, 2020 WL 1234567 (D.N.J. Mar. 12, 2020).” The court explains that the cited Westlaw identifier exists for no case and the case number corresponds to a different matter (Vandium LLC v. Datamotion, Inc.). The order warns: “Hallucinated citations will not be excused, and the Court may sanction Plaintiff for further uses of hallucinated citations.” It also references the court’s Judicial Preferences, which include guidelines on the use of generative artificial intelligence.

Plaintiff had separately filed a Notice Regarding Use of Cognitive Artificial Intelligence on September 6, 2025 (ECF No. 58). Judge Padin’s February 3, 2026 Memorandum Order (ECF No. 192) addresses two different problems. It revokes the plaintiff’s Alternate Document Submission (ADS) privileges and denies his motions at ECF Nos. 158 and 165 with prejudice, because he “has repeatedly attempted to circumvent various applicable rules,” including by contacting chambers directly (pp. 2, 5-6). Separately, it finds that his latest opposition to THOUGHTi’s motion to dismiss “relies on hallucinated quotations,” including a citation to a non-existent Fairfield Industries decision, and notes that the court struck that filing (p. 7 and n.7).

For firms litigating against pro se plaintiffs in the District of New Jersey, Kabir shows a court separating two responses in one order: a restriction on filing channels for procedural abuse, and a strike for hallucinated quotations, backed by a warning that further reliance on hallucinated citations may lead to a pre-filing injunction. The case also shows how readily a fabricated citation can be detected: the Westlaw identifier “2020 WL 1234567” is on its face implausible, and a quick cross-check against the underlying case number was enough to expose the error.