Maturin v. T-Mobile USA, Inc.
U.S. District Court, District of New Mexico · D.N.M. · New Mexico bar guidance
Conduct
Pro se ADA plaintiff cited 3+ fabricated cases (Rogers v. NYU Langone; Ford v. BNSF; Keller v. Bd. of Ed.) across multiple filings.
Consequence
Adverse cost order ($8,640 recommended); forward-looking AI-disclosure certification rule imposed for all future filings.
Lesson
Forward-looking AI-disclosure certification is now a chambers tool; first D.N.M. example tying Rule 11 to AI verification.
Verified May 14, 2026
- Citation
- Maturin v. T-Mobile USA, Inc., No. 1:24-cv-01125 JCH/SCY (D.N.M. Dec. 15, 2025) (Yarbrough, M.J., Amended Report and Recommendation, Doc. 91); adopted by Herrera, J., Jan. 8, 2026 (Doc. 95)
- Decided
- December 15, 2025
Summary
Carlos Maturin, a pro se plaintiff, brought an Americans with Disabilities Act employment-discrimination action against T-Mobile USA, Inc. The defendant moved for sanctions after Maturin's filings were found to contain non-existent case citations characteristic of generative AI output. Magistrate Judge Steven C. Yarbrough issued an initial Report and Recommendation on November 25, 2025 (Doc. 84), which the magistrate then amended on December 15, 2025 (Doc. 91). The R&R identified at least three fabricated citations: Rogers v. NYU Langone Hospitals, 2023 WL 2705769; Ford v. BNSF Railway Co., 709 F.3d 715 (10th Cir. 2013); and Keller v. Board of Education, 182 F.R.D. 871 (D.N.M. 1998). The R&R reminded Maturin that "any information from artificial intelligence must be reviewed for accuracy" and recommended attorney's fees and costs, declining terminating sanctions as too severe.
- AI tool:
- Generative AI implied; the magistrate's recommendation discusses AI use generally; the district judge's adoption order requires future AI-disclosure certifications
- Sanction amount:
- $8,640 (recommended; final amount to be set on supplemental affidavit)
What sanction did the court impose?
On January 8, 2026, Senior District Judge Judith C. Herrera adopted the magistrate's Amended R&R as modified, declining terminating sanctions but requiring T-Mobile to file a supplemental affidavit detailing requested fees and costs (the Charlotin tracker reports the recommended amount as $8,640, with final cost determination set for early 2026). Critically, the adoption order also imposed a forward-looking AI disclosure rule: "In all future court filings, Plaintiff must disclose whether he used artificial intelligence in drafting the filing and, if he did, he must certify, under Rule 11, that he has verified all information, including all case citations." Maturin's competing motion seeking $355.69 quintillion in sanctions against T-Mobile was denied as "quite simply ludicrous." The plaintiff appealed to the Tenth Circuit (No. 26-2005, filed Jan. 13, 2026).
Why does Maturin v. T-Mobile USA, Inc. matter for law firms using AI?
Maturin v. T-Mobile USA, Inc. is the first published D.N.M. case to impose a forward-looking AI-disclosure certification rule as part of a sanctions order. Under the January 8, 2026 adoption order by Senior Judge Judith C. Herrera, Maturin must affirmatively disclose AI use on every future filing and certify under Rule 11 that he has verified all information including every case citation. The case spans three orders (the November 25, 2025 R&R, the December 15, 2025 Amended R&R, and the January 8, 2026 adoption order); the R&G tracker uses the Amended R&R date, which is the single entry that surfaces in this collection. The cost figure (approximately $8,640) is the Charlotin tracker’s recorded amount and reflects fees and expenses related to (1) investigating false citations, (2) responding to sanctions motions, and (3) preparing for a missed deposition. Maturin’s appeal to the Tenth Circuit (No. 26-2005) was filed five days after the adoption order. Cross-reference: Lowrey v. City of Rio Rancho (D.N.M. Nov. 5, 2025) (Robbenhaar, M.J.) and Tomlin v. State of New Mexico (D.N.M. Sept. 30, 2025) (Browning, J.) for adjacent D.N.M. AI-citation orders.
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 the emerging chambers practice of forward-looking AI-disclosure rules; the Herrera order requires Maturin to certify AI verification under Rule 11 on every future filing, a model some firms may want to anticipate when seeking conduct-modification relief against pro se litigants.
- When seeking sanctions against a pro se litigant for AI-fabricated citations, prepare cost affidavits at the outset; courts in this district increasingly award fees and costs incurred specifically in (a) investigating false citations, (b) responding to sanctions motions, and (c) related discovery disputes.
- Document deposition-attendance protocols separately from citation issues; the Maturin order awarded costs covering both citation-investigation and a missed deposition, and the bundling of those bases supports a fuller fee award than either alone.
Sources
Primary sources
Further reading
- https://www.damiencharlotin.com/documents/1092/Maturin_v._T-Mobile_USA_25_November_2025.pdf
- https://www.damiencharlotin.com/documents/1301/Maturin_v._T_Mobile_USA_USA_8_January_2026.pdf
- The R&G entry dates this matter December 15, 2025, which corresponds to the Amended R&R (Doc. 91). The original R&R (Doc. 84) was issued November 25, 2025, and the district judge's adoption order (Doc. 95) was entered January 8, 2026. The case generated multiple AI-related orders across a six-week span; this entry treats the December 15, 2025 Amended R&R as the primary entry per the R&G dating.
- The $8,640 cost figure is sourced from the Charlotin tracker's metadata; the R&R recommends an award of fees and costs but does not quantify a dollar amount, and the precise figure in the supplemental affidavit was not independently verified for this entry.