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Romero v. Goldman Sachs Bank USA

U.S. District Court, Southern District of New York · S.D.N.Y. · New York bar guidance

Pro-se party

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.

Court sanction

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)
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

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.

Sources

Primary sources

Further reading