Romero v. Goldman Sachs Bank USA
U.S. District Court, Southern District of New York · S.D.N.Y. · New York bar guidance
Conduct
Pro se misattributed a quote to In re Motors Liquidation, misrepresented its holding, and cited a non-existent Beckford case.
Consequence
Warning from S.D.N.Y. Judge Woods; no monetary sanction.
Lesson
Bankruptcy-precedent misuse is a recurring AI-hallucination pattern; verify In re cases against opinion text, not citation.
Verified May 14, 2026
- Citation
- Romero v. Goldman Sachs Bank USA, No. 1:25-cv-02857 (S.D.N.Y. June 25, 2025) (Woods, J.)
- Decided
- June 25, 2025
Summary
Pro se plaintiff Romero filed papers in an action against Goldman Sachs Bank USA that contained three identified citation defects: a quotation attributed to In re Motors Liquidation Co. that the cited opinion does not contain; a misrepresentation of In re Motors Liquidation Co. as addressing what evidence may be presented in a reply brief (the case is unrelated to that topic); and a fictitious Beckford case citation, with no case existing at the cited Westlaw citation and the actual Beckford cases on Westlaw being different and unrelated. Judge Gregory H. Woods issued a warning.
- AI tool:
- Implied (court suspected AI-generated citations; specific tool not identified)
What sanction did the court impose?
Warning issued by Judge Woods; no monetary sanction or formal disciplinary referral imposed.
Why does Romero v. Goldman Sachs Bank USA matter for law firms using AI?
Romero v. Goldman Sachs is part of an emerging cluster of S.D.N.Y. AI sanctions cases involving consumer plaintiffs against financial institutions where the misattribution target is bankruptcy precedent. The In re Motors Liquidation Co. citation pattern (real case, fabricated quotation, fabricated proposition) appears across multiple 2025 sanctions orders, suggesting that generative AI tools are routinely associating well-known In re bankruptcy cases with whatever proposition the user prompted for, regardless of whether the case actually addresses that proposition.
For firms representing financial institutions in S.D.N.Y. consumer matters, the operational lesson is to maintain a verified-quote and verified-proposition file for the most-commonly-misattributed bankruptcy cases (In re Motors Liquidation Co., In re Lyondell Chemical Co., In re Adelphia Communications, and similar). When opposing briefing cites these cases for propositions outside the bankruptcy holding, the misattribution can be flagged quickly with a one-line citation to the actual holding. Judge Woods’s warning-only disposition is consistent with the S.D.N.Y. pro se pattern; sanctions escalation depends on volume, on-the-record AI admission, or recurrence.
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 opposing pro se plaintiffs in S.D.N.Y. consumer-finance matters, expect bankruptcy-court precedent (In re cases) to be a frequent target for AI misattribution; verify both the case exists and that the proposition cited is supported.
- In re Motors Liquidation Co. specifically has appeared as a hallucination target in multiple AI sanctions orders; the case is real but the propositions attributed to it are routinely fabricated.